Privacy and security:

Information Policy

Introduction
In accordance with Regulation P, Bank of St. Augustine acknowledges the legal restrictions on the disclosure of nonpublic personal information. It is Bank of St. Augustine’s policy to disclose such information only under the following circumstances:

• As required by law
• As specifically allowed by law
• As requested by the customer, directly or indirectly

Customers with relationships established for personal, family and household use are to receive an initial written disclosure describing this policy prior to establishing a customer relationship and annually thereafter. Distribution of initial disclosures will be made no later than July 1, 2001 and to all new customer relationships thereafter. The time frame for annual notices will be the calendar year, beginning in 2001.

Information Collected
Bank of St. Augustine collects the following categories of nonpublic personal information about our consumer customers: information received on applications and other forms, information about transactions with us (such as information about a deposit or loan), information about transactions with nonaffiliated third parties, and information from consumer reporting agencies.

Nonpublic Personal Information and Affiliates
According to Federal law, Bank of St. Augustine may disclose certain nonpublic personal information about our customers to our affiliates. The information we are allowed to, by law, and may disclose to our affiliates includes:
Transaction and experience information from our account records.
Information about our customers’ transaction and experience with Bank of St. Augustine, such as:
• Name
• Address
• Account balances
• Account activity
• Types of accounts
• Payment history
• Deposit history
• Parties to the transaction

Reasons for Disclosure to Affiliates
Bank of St. Augustine may disclose nonpublic personal information about our customers to our affiliates for the following reasons:
• To provide our customers with information about additional products and services.
• To evaluate our total relationship with a customer and our family of companies in order to give the best price that relationship deserves.
• Many customers want us to know the individual pieces of their overall plan.
• To give our customers the benefit of the entire customer relationship when paying overdrafts and determining credit limits.

Future Affiliate Disclosure
Bank of St. Augustine also reserves the right to disclose nonpublic personal information about customers to anyone except as disclosed in this policy or as permitted by law.

Information Disclosed
This institution may disclose the following categories of nonpublic personal information about our consumer customers and former customers: information received from applications and other forms such as name, address, social security number, assets and income; and information about transactions with the institution such as account balance, payment history, parties to the transaction, and information from other consumer reports such as a consumer’s creditworthiness and credit history. We will only disclose this information under the circumstances addressed in this policy. An example of when we might disclose this information would be to a consumer-reporting agency.

Parties to Whom Information is Disclosed
Bank of St. Augustine does not currently, but reserves the right in the future to disclose nonpublic personal information about our customers and former customers to companies that provide financial services, securities broker-dealers, and insurance agents, however we will only disclose information required to process the transaction or provide the service. Under no circumstances will we disclose customer account numbers to companies providing joint marketing services. Bank of St. Augustine also discloses nonpublic personal information to other nonaffiliated third parties as permitted by law.

Confidentiality and Security Of Nonpublic Personal Information
Bank of St. Augustine maintains the following policies and practices designed to protect the confidentiality and security of consumers’ nonpublic personal information. Bank of St. Augustine has extensive security measures that insure this policy is followed. We restrict access to confidential customer financial information to those employees who need to know that information to provide products or services to our customers. Our employees are trained to understand the importance of customer financial privacy and to properly handle confidential information. 

Internal Control
This policy will be reviewed annually in conjunction with a review of the Bank’s practices to ensure that the Bank’s practice and disclosures continue to accurately reflect the Bank’s policy. Compliance will be tested semiannually through external compliance reviews.

The Compliance Officer will be responsible for ensuring that all vendor contracts are in compliance with the Bank’s regulatory requirements, that the policy will be updated as needed, and that disclosures are provided as required.