The Bank of Zumbrota is implementing this privacy policy because a fundamental component of the bank-customer relationship is a customer's trust in this institution and because we respect the expectations of our customers regarding privacy and confidentiality. Protecting your privacy along with your financial assets is at the core of our business. You have chosen to do business with us and we recognize our obligation to limit access to the information you provide us.

The Bank's Board of Directors has adopted this policy. Bank management reviewed a variety of issuances from federal banking agencies as well as the US Banking Industry Privacy Principles and carefully considered the policy in light of the bank's particular needs. Including the bank's size, the bank's involvement with third parties and the needs of our customers.

COLLECTION AND USE OF INFORMATION

The bank collects, retains and uses information about customers only when it is useful and lawful for our standard business purposes. Our business, referred to in the preceding sentence, includes opening and maintaining accounts or providing loans, providing additional financial products or services and advising you of new products or services. For example; we will obtain personal information about you when you apply for a loan and we may obtain a credit report from a third party.

MAINTENANCE OF ACCURATE INFORMATION

Keeping your financial information accurate and up to date is very important. You have the right to request your own account information to assure that it is accurate. If you ever find that your account information is incomplete, inaccurate or not current, please call us at 507-732-7555 or write us at BANK OF ZUMBROTA, PO BOX 8, ZUMBROTA, MN 55992-0008. We will correct any erroneous information.

EMPLOYEE ACCESS TO INFORMATION AND ENFORCEMENT

The Bank of Zumbrota limits employee access to customer personal information to only those bank personnel with a business reason for knowing such information. We also educate our staff about the importance of confidentiality and customer privacy.

SAFEGUARDING THE SECURITY OF CUSTOMER INFORMATION

We have very strict internal controls in place that safeguard your paper and computer based financial records. Our internal controls are periodically updated to reflect the use of developing technologies.

RESTRICTION ON DISCLOSURES OF ACCOUNT INFORMATION

We may disclose information to third parties about your credit, your accounts and your transactions under any one of the following conditions:

1. When it is necessary to complete a transaction initiated by you.
2. To verify the existence and conditions of the account or loan for reputable information from reporting agencies such as Chex Systems and Credit Bureaus.
3. In order to comply with a government agency directive, court order or regulatory examination. 
4. When you give the bank permission.
5. Our check printing company receives limited information about you (account number, name, driver's license, address, phone).
6. In order to protect you, your interest, the interests of the Bank, or if we suspect fraud or illegal activity.

MAINTAINING CUSTOMER PRIVACY IN BUSINESS RELATIONSHIPS WITH THIRD PARTIES

The Bank will take steps to ensure protection of customer information. Except as otherwise stated in this policy, the Bank will not sell or share customer information with third parties. In some cases, the Bank may need to share information with third party business partners. If the Bank uses a third party business partner, we will make reasonable efforts to verify that the business partner treats customer information in a manner no less stringent than the Bank.

DISCLOSURE OF PRIVACY PRINCIPLES TO CUSTOMERS

We will periodically review the methods available for communicating the Bank's Privacy Policy and determine whether the Bank's current practices are meeting the needs of the Bank and our customers.
 

NOTICE OF YOUR FINANCIAL PRIVACY RIGHTS

We, our, and us, when used in this notice, mean Bank of Zumbrota.
This is our privacy notice for our customers. When we use the words "you" and "your" we mean the following types of customers:

• Our consumer customers who have a continuing relationship by purchasing or holding financial products or services such as a(n):
  • Deposit account
  • Loan account
  • Safe deposit box
  • Retail installment contract we hold and service
  • Self-directed Individual Retirement Account

We will tell you the sources of the information we collect about you. We will tell you what measures we take to secure that information.

We first define some terms.
 
Nonpublic personal information means information about you that we collect in connection with providing a financial product or service to you. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records. Hereafter, we will use the term "information" to mean nonpublic personal information as defined in this section.

An affiliate is a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control.

A nonaffiliated third party is a person we do not employ or a company that is not an affiliate of ours. This is also known as nonaffiliated third party, or simply, an "other party."

THE INFORMATION WE COLLECT
We collect information about you from the following sources:

• Information you give us on applications or other forms
• Information about your transactions with us
• Information about your transactions with other parties
• Information from a consumer reporting agency
• Information we receive as a result of verifying customer information

THE CONFIDENTIALITY, SECURITY, AND INTEGRITY OF YOUR INFORMATION
We restrict access to information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to protect this information.

YOUR INFORMATION AND OUR AFFILIATES
We may disclose information about you to our affiliates. Here are the kinds of information and the source of that information:

Transaction and experience information from our account records:

• Information about your transactions and experience with us, such as:
  • Name
  • Address
  • Account balances
  • Types of accounts
  • Payment history
  • Deposit history

Federal law allows us to disclose the information listed above with our affiliates. You do not have a right to opt out of the disclosure of this information.

Types Of Affiliates
We may disclose information about you to the following types of affiliates:

• Financial service providers, such as:
  • Bankers
  • Insurance agents

Future Affiliate Disclosure
We also reserve the right to disclose information about you in the future with the following additional types of affiliates:

• Financial service providers, such as:
  • Mortgage bankers
  • Securities broker-dealers

YOUR INFORMATION AND OTHER PARTIES
We will not disclose information about you to anyone except as disclosed in this policy or as permitted by law. Examples of this might include disclosures necessary to service your account or prevent unauthorized transactions.

INFORMATION ABOUT FORMER CUSTOMERS
We do not disclose information about former customers, except as permitted by law.

507-732-7555
P.O. BOX 8, ZUMBROTA, MN 55992
www.bankofzumbrota.com 

126383-020
© 2000 Bankers Systems, Inc., St. Cloud, MN
Form PRIV-DISC 9/4/2001 2.0/2894