At Fortune Bank (“the Bank”) our mission is to meet the expectations of our customers. As financial service professionals entrusted with sensitive financial information, we respect the privacy of our customers and are committed to treating customer information responsibly. Our Privacy Policy serves as a standard for all Bank employees as it pertains to the collection, use, retention, and security of customer information.

The descriptions in this Policy apply to our relationships with individual and business customers who inquire about and/or obtain products or services from the Bank.


Categories of Information We Collect

The Bank collects nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms
• Information about your transactions with us or third-party verification systems
• Information we receive from a consumer-reporting agency

Customer Benefits of Institution’s Information Management Practices

We collect, retain, and use information about you only where we reasonably believe that it will help administer our business or provide products, services, and other opportunities to you. We collect and retain information about you only for specific business purposes – and we will tell you why we are collecting and retaining it upon your request. We use information to protect and administer your records, accounts, and funds: to comply with certain laws and regulations; to help us design or improve our products and services; and to understand your financial needs so that we can provide you with quality products and superior service.


Categories of Information We Disclose

The Bank does not disclose any nonpublic personal information about our customers or former customers to anyone, unless: 1) you request or authorize it; 2) the information is provided to help complete a transaction initiated by you; 3) the information is provided to a reputable consumer-reporting agency; or 4) the disclosure otherwise is lawfully permitted or required (e.g, subpoena). We do not provide account or personal information to external companies for the purpose of independent telemarketing or direct mail marketing. It is our policy not to reveal specific information about customer accounts or other personally identifiable data to unaffiliated third parties for their independent use, except for the exchange of information with reputable information reporting agencies to maximize the accuracy and security of such information or in the performance of bona fide corporate due diligence or business matters.


Maintenance of Accurate Information

We continually strive to maintain complete and accurate information about you and your accounts. Should you ever believe that our records contain inaccurate or incomplete information about you, please notify us. We will investigate your concerns and correct any inaccuracies.


Confidentiality and Security

The Bank is committed to the security of your financial and personal information. All of our operational and data processing systems are in a secure environment that protects your account information from being accessed by third parties. We maintain and grant access to customer information only in accordance with our internal security standards.

At the bank, employee access to personally identifiable customer information is limited to those with a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of customer information and on these privacy principles. Because of the importance of these issues, all Bank employees are responsible for maintaining the confidentiality of customer information and employees who violate these privacy policies will be subject to disciplinary measures.


Maintaining Customer Privacy in Third-Party Relationships

When the Bank conducts business with third parties, it requires its vendors and suppliers to maintain similar standards of conduct regarding the privacy of personally identifiable customer information provided to them.


Training

We will implement privacy training programs that include annual training of employees and initial training for all new employees. The initial training includes a review by the new employee of the bank’s Customer Information Security Policy and Procedures. All employees acknowledge in writing their understanding of these policies and procedures.


Audit

The Bank’s Internal Audit Function will review the Bank’s compliance with the privacy regulation annually. Results of this review will be reported directly to the Bank’s Board of Directors.

This policy will be reviewed and approved by the Bank’s Board of Directors annually.


Providing Privacy Information and Responding to Inquiries

The Bank recognizes and respects the privacy expectations of our customers. We want our customers to understand our commitment to privacy in our use of customer information. As a result of our commitment, we have developed Privacy Principles that are readily available to our customers.