CUSTOMER PRIVACY POLICY

At CHEQ Processing, LLC. the privacy and security of our customers’ personal information is of the utmost importance. We never take for granted the trust our customers have placed in us and we honor that trust by managing our customers’ personal information with the highest level of care.

Safeguarding the privacy and security of customer information is a complex and dynamic process. This public statement is provided to help you understand what is involved in this process.

From time to time we may revise and redisclose this policy to reflect changes in technology, privacy law or changes in our operations and practices. If you have any questions about this policy statement please contact.

Throughout the Customer Privacy Policy, “we”, “us” and “our” refer to CHEQ Processing, LLC. “You” and “your” refer to the customers of CHEQ Processing, LLC.

Privacy Principles
CHEQ Processing, LLC. has adopted the Privacy Principles that were cooperatively established by the leading U.S. banking industry trade associations. Therefore, we pledge to:

Recognize a customer’s expectation of privacy.
We recognize and respect the privacy expectations of our customers and want to explain principles of financial privacy to our customers in an appropriate fashion. These principles and the accompanying policy statement are provided to explain how we continuously work to meet our customers’ expectation of privacy.

Collect, use and retain a customer’s information only if we believe that the customer will benefit.
We collect, retain and use information about individual customers only where required by law, regulation or we reasonably believe it is useful and allowed by law in order to administer our business and to provide products, services and other opportunities to our customers.

Maintain accurate information.
We have established procedures so that the customer’s financial information we collect is accurate, current and complete in accordance with reasonable commercial standards. We will respond to requests from our customers to correct inaccurate information under our control in a timely manner.

Limit employee access.
We limit employee access to personally identifiable information to those with a business reason for knowing such information. Our employees are trained to understand the importance of confidentiality and customer privacy and security. We have employee privacy and security guidelines in place and will take the appropriate disciplinary measures to enforce these guidelines.

Protect information via established security procedures.
We have adopted appropriate security standards and procedures to guard against unauthorized access to customer information.

Restrict the disclosure of account information.
We will not reveal specific information about customer accounts or other personally identifiable data to unaffiliated third parties for their independent use with the following exceptions: 1) the information is provided to help complete a customer initiated transaction; 2) the customer requests it; 3) the disclosure is required by/or allowed by law (e.g., subpoena, investigation of fraudulent activity, etc.); 4) the customer has been informed about the possibility of disclosure for marketing or similar purposes through a prior communication and has not exercised the right to opt out; 5) the information is exchanged with reputable information reporting agencies to maximize the accuracy and security of such information; or 6) in the performance of bona fide corporate due diligence for merger or asset sales.

Maintain customer privacy in business relationships with third parties.
At times, we rely on third parties to help us do business. Examples include check printers and processors. Each of these companies is bound by contract to honor these Privacy Principles. If personally identifiable customer information is provided to other third parties, we will require them to keep our customer information private and secure.

Make our privacy principles and policies known to the customer.
We will always provide our customers with reasonable access to our privacy policy.

With the above stated privacy principles as a foundation, the policy language that follows is a detailed explanation of how and why we collect, use and share information.

Information Collection and Use.
We collect the information we believe necessary to deliver our products and services according to your specifications and expectations. Due to the complex nature of the financial services business, we must collect certain types of nonpublic personal information about you in order for us to deliver the products and services you request. We collect nonpublic personal information about you in a variety of ways, including:

Information we receive from you on applications or other forms to open a deposit or investment account or to obtain insurance or information necessary to evaluate a loan request. Depending on the product or service requested, the information we may request could include (but is not limited to) your name, address, employment, taxpayer identification number, telephone and fax numbers, email address, income, assets and liabilities, deposit account balances, tax returns and financial statements.

Information about your transactional experience and account history with us, our affiliates, or others. This information helps us to identify and protect your account against unauthorized access as well as identify additional products and services that may benefit you.

Information from a consumer-reporting agency, such as that which establishes your creditworthiness or verifies your employment. This information enables us to determine eligibility for a requested product.

When you visit our company web sites, we may collect transaction, site navigation, customer contact and optional survey information. We use this information to enhance and personalize our online services. Refer to the “Online Information Privacy and Security” section below for more information regarding online privacy.

If you choose not to provide the information necessary for us to fulfill a request for a specific product or service, we may not be able to process your request.

Information Sharing
CSI does not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted or required by law or as described below.

Information sharing at CHEQ Processing, LLC.
Our organization offers traditional banking services, mortgages, personal loans, student loans, credit cards, investment services and insurance products through bank branches, automated teller machines, and the Internet. This policy statement covers all our consumers who use any of these channels of product delivery, or customers who have an established relationship with any of the companies affiliated with CHEQ Processing, LLC.

From time-to-time we may share customer information within the CHEQ Processing, LLC. family of banks and financial services companies for a variety of reasons:

• Your protection. The information we maintain about your accounts enables us to identify you and to prevent unauthorized access to your account information.
• Product development and enhancement. Your information helps us to understand your needs and to continually improve our products and services. By understanding your needs we are able to recommend other products or services offered through our company, which may help you to achieve your financial goals.
• Conducting transactions. In order to serve you better, many specialized banking services are performed by one affiliate on behalf of another. In particular, wire services, international transactions and corporate services may be conducted by one affiliate for the customer of others.
• Support and administrative functions. Service units within our family of companies that perform vital support functions such as servicing your accounts.

Fair Credit Reporting Act Requirements
Under the federal Fair Credit Reporting Act (FCRA), CHEQ Processing, LLC. is permitted by law to share certain credit information with our affiliates. The information which can be shared includes account history and customer experience. In addition, although we are permitted under the FCRA to share non-experience credit information (e.g., credit report information obtained from a credit bureau) with our affiliates, consumers must be informed of this information sharing and provided a reasonable opportunity to opt out of such sharing.
In situations where an affiliate of the company plans to share non-experience credit information with another affiliate, will honor CHEQ Processing, LLC. your request not to share this information. It is important to remember that a FCRA request to not share applies to certain information about your applications with us, such as your account number, and information about your credit report or similar information obtained from credit bureaus and other sources outside CHEQ Processing, LLC.
Refer to “Respecting Your Preferences” section below for more information on how to opt out of affiliate sharing of credit information.

Trust Accounts
Information on trust accounts where CHEQ Processing, LLC is acting as a trustee or fiduciary is subject to more restrictive information sharing protection, both within and outside of our company.
Information sharing with unaffiliated third parties
In order to provide the products and services you request, we may disclose the following information to reputable companies that perform outsourced operational support, provide marketing services on our behalf or other financial institutions with which we have joint marketing agreements:

• Information we receive from you on applications or other forms, such as your name, address, social security number, assets, and income;
• Information about your transactions with us, our affiliates, or others, such as your account balance, payment history, parties to transactions, and credit card usage; and
• Information we receive from a consumer reporting agency, such as your creditworthiness and credit history.
• The information we furnish to outside companies can only be used for providing the specific services they are hired to perform.

The types of companies that we contract with include payment processing specialists, insurance companies, mail fulfillment companies, check printers and data processing companies. All outside companies hired to perform specific services on our behalf are prohibited by contract from disclosing or using the information in any manner other than to fulfill the products or services requested by our customers.
At times we may become aware of companies that offer products and services that may be of interest to you. If so, we may share your name, address, transaction experience and other identifying information with these companies for purposes of marketing their products or services to you. If you do not want us to share your information with non-affiliated companies for their marketing purposes, refer to “Respecting Your Preferences” section below for more information on preventing such sharing.
Information sharing with outside parties - other situations There are certain situations where we may, in good faith, disclose information requested by government agencies, consumer reporting agencies and other outside parties as permitted or required by law. Examples include:

• Responding to legal process or to comply with federal, state or local laws, rules and other applicable legal requirements (e.g., a court order or subpoena for information);
• Providing information to facilitate a fraud investigation;
• Making information a matter of public record (e.g., recording a mortgage or filing a financial statement);
• Facilitating an audit or examination by a government regulatory agency or other request in accordance with the Right to Financial Privacy Act;
• Enforcing an obligation, including filing lawsuits or bankruptcy claims;
• Providing information to a consumer reporting agency in accordance with the Fair Credit Reporting Act;
• Obtaining credit enhancements for loans (such as SBA guarantees);
• Providing information necessary to fulfill customer expectations (e.g., enabling a connection to a national ATM or debit card network); and
• The proposed or actual sale, merger or transfer of accounts to another financial institution.

Former customers
CHEQ Processing, LLC. provides the same private and secure treatment for the nonpublic personal information of applicants and former customers as it provides for existing customers. Information previously collected from former customers is maintained on file in accordance with state and federal regulatory requirements for record retention.

Employee Access to Customer Information
CHEQ Processing, LLC. trains its employees to adhere to policies regarding customer information privacy and security. Each of our employees must sign an agreement that carries with it the responsibility to protect the privacy and security of our customers’ information. In addition, all CHEQ Processing, LLC. employees are bound by this policy and are trained on privacy requirements. Only employees having an appropriate business reason have authorized access to customer information.

Information Accuracy
CHEQ Processing, LLC. strives to maintain the accuracy of the information you provide. If you have reason to believe that the information we have about you and your account is inaccurate or incomplete, please contact. We will take immediate action to correct any inaccuracy under our control.

Respecting Your Preferences
CHEQ Processing, LLC. offers a wide range of financial products and services to help you meet your needs and achieve your financial goals. On occasion we may want to contact you to offer information on products and services that could benefit you. We recognize, however, that you may have a preference about how we contact you. Furthermore, you may also prefer for us not to share your non-transaction related information among our family of affiliated companies. We also want you to know that if you apply for credit through any of CHEQ Processing, LLC. affiliates, we will not treat your application differently (for example, provide you less favorable pricing terms or apply more stringent credit underwriting standards) if you should decide to opt out of having your personal information shared with any of our affiliate companies. A request by one joint account holder will apply to all other associated account holders.