PRIVACY POLICY

This privacy statement reaffirms our realization of and respect for the privacy expectations and rights of our customers regarding financial information and other related information, which the bank has or gathers in the normal course of business. It is intended to provide guidance to bank personnel as well as assurance to our customers. We will also, of course, act in compliance with all applicable laws and regulations.

Recognition of Customer’s Expectation of Privacy

Customers of the bank are entitled to the absolute assurance that the information concerning their financial circumstances and personal lives, which the bank has obtained through various means, will be treated with the highest degree of confidentiality and respect. Certain expectations of privacy also contain legal rights of customers which are either granted or confirmed to them through various federal and state laws and regulations. All employees are directed by policy to assure customers of our commitment to preserving the privacy of their information.

Use, Collection, and Retention of Consumer Information

We collect, retain, and use information about consumers and customers (both individual and corporate) only where the bank reasonably believes the gathering of such information would be useful and allowed by law to administer the bank’s business and/or to provide products, services, or opportunities to its customers.

Maintenance of Accurate Information

We have established procedures to ensure that, to the extent practicable, all customer financial information is accurate, current, and complete in accordance with reasonable commercial standards. We will respond promptly and affirmatively to any legitimate customer request to correct inaccurate information, including forwarding of corrected information to any third party who received the inaccurate information. We will further undertake to record that such corrective action was requested by the customer and follow up with any third parties to ensure that they have processed the correction.

Limitation on Employee Access to Information

We have taken steps necessary to ensure that only employees with a legitimate business reason for knowing personally identifiable customer information shall have access to such information. To the extent practicable, access will be limited by computer access codes and granting limited access to areas in which sensitive customer information is retained. Employees will be informed at the time of their initial employment of these standards and periodically reminded of these standards during training sessions at least once during each calendar year. Willful violation of this element will result in disciplinary action against the offending individual. Inadvertent violations will be dealt with in a manner to ensure that such violations are not repeated

Protection of Information via Established Security Procedures

We will maintain appropriate security standards and procedures to prevent unauthorized access to customer information. Such procedures should prevent access by not only unauthorized employees, but others as well. Such others include but are not limited to all non-employees with otherwise legitimate reasons for being on bank premises, computer “hackers,” and all intruders on bank premises.

Restrictions on the Disclosure of Customer Information

We will not, except in cases allowed under the law, reveal specific information about customer accounts or other nonpublic personal information to any nonaffiliated third parties.

Maintaining Customer Privacy in Business Relationships with Third Parties

Sometimes it is necessary to provide personally identifiable information about you to a party, such as to a vendor or service company that we hire to provide support or services for one or more of our products. These vendors and service companies agree to safeguard our confidential information about you and your products and services with us and must abide by applicable law.

Disclosing Our Privacy Commitment to You

We want you to understand our commitment to personal privacy and our use of information. For this reason, we have prepared this Privacy Statement. These materials will answer most of the important questions that you may have about how we gather, protect, and use information. Our Privacy Protection Notice is included as part of this statement and is posted below.

TrustBank™

NOTICE OF PRIVACY PRACTICES

At TrustBank, we know how important personal privacy is to you. We recognize that you expect privacy and security for your personal and financial affairs. We understand the need to safeguard our sensitive information about you that you have entrusted to us. Because of our interest in protecting your privacy and to reaffirm our continued commitment to respect your privacy, we have adopted this Privacy Protection Notice.

TrustBank collects, retains, and uses information about you only when we believe it would be useful (and allowed by law) in administering our business and to provide products, services, and other opportunities to you. This nonpublic personal information is obtained from the following sources:

· Information we receive from you on applications or other forms, including any forms or other data received through the internet or other electronic means;

· Information about your transaction with us or others, including any transaction conducted through the internet or other electronic means;

· Information we receive from a consumer reporting agency.

TrustBank may share certain information with other nonaffiliated third parties as permitted by law to provide you with services and products. We may also share such information with financial service providers and with our affiliates as permitted by law that they might be able to offer you desirable products or services.

We restrict access to nonpublic personal 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 that comply with federal and state standards to guard your nonpublic personal information.

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted or required by law.