Effective December 10, 2002

As a customer of First Service Bank, you provide us with important information about yourself.  We believe it is our responsibility to safeguard your personal and financial information.  While some financial institutions share account owner information with other businesses, we are committed to keeping it confidential.

We have developed the following privacy policy to ensure you the confidentiality you deserve.  You have our promise to adhere to these guidelines.  It is our pledge to you.

Notice of your Financial Privacy Rights

We, our, and us, when in this notice, means First Service Bank.  When we use the words “you” and “your” we mean the following types of customers:

All of our consumer customers who have a continuing relationship with us, such as:

·         Deposit Account

·         Loan Account

·         Credit Card

·         Safe Deposit Box

·         Self – Directed Individual Retirement Account where we act as custodian or trustee

We will tell you the sources for nonpublic personal information we collect on our customers.  We will tell you what measures we take to secure that information.

We first define some terms.

NONPUBLIC PERSONAL INFORMATION means information about you 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.

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 company that is not an affiliate of ours.

The information that we collect

We collect 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;

Information about your transactions with our affiliates;

Information about your transactions with nonaffiliated third parties;

Information from a consumer- reporting agency;

Information that is generated electronically when you visit our website and use our Internet Banking and Portal services;

Information you provide when you choose to customize the portal.

Information that we disclose about you

We do NOT disclose any nonpublic personal information about you to anyone, except as permitted by law.

The confidentiality, security, and integrity of your nonpublic personal information

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 standards to guard you nonpublic personal information.

Nonpublic personal information and former customers

We do not disclose nonpublic personal information about former customers, except as permitted by law

  ___________________________________________________________________________

Privacy for Internet Users

Our commitment to safeguard your privacy also extends to the Internet. If you are just browsing through our website, we do not request any personally identifiable information, nor do we collect unique identifying information about you unless you voluntarily and knowingly provide us that information, such as when you send us an email or complete an application online. If you provide us this information, it is only used internally and in furtherance of the purpose for which it was provided.

Service providers hosting our website and Internet banking service may collect general information on our website visitors simply to help us provide banking and other financial services to you online. They collect information on our behalf for security and statistical purposes. The information collected for these purposes may include:

·          The Internet address (referral site) which brought you to our web site;

·          The date and time you access our site;

·          The name and version of your web browser;

·          The Internet service provider you used when you accessed our site;

·          Your Internet Protocol (IP) address; and

·          The pages visited in our website and Portal.

Our service providers may use cookies to collect this type of general information on all website visitors and they may use cookies for security purposes within our Internet Banking product.  Cookies may also be utilized for customization and personalization of the Portal.

In the future, we may use aggregate, general, non-personally identifiable information collected through the Internet to help us market our products and services.     

Additional information about IP addresses and cookies are provided below.

Internet Protocol (IP) Addresses

An IP address is a number that's automatically assigned to your computer whenever you're on the Internet.  Web servers, the computers that "serve up" Web pages, automatically identify your computer by its IP address.

When collecting information for us, FundsXpress does not link IP addresses to anything personally identifiable, which means that a user's session will be logged, but the user remains anonymous.

FundsXpress may use IP addresses to audit the use of our site. They can and will use IP addresses to identify a user when necessary for security purposes. 

What is a Cookie?

A cookie is a very small text file sent by a web server and stored on your hard drive, your computer’s memory, or in your browser so that it can be read back later.  Cookies cannot “read” information about you from your computer or be used to “steal” information about you; and cookies don’t carry viruses.  Cookies are a basic way for a server to identify you (most cookies actually identify the computer you happen to be using at the time, not you personally). Cookies are used for many things from personalizing start up pages to facilitating online purchases.  Cookies help sites recognize return visitors and they perform a very important function when you engage in secure Internet banking.  For your security, our Service Providers do not store any of your personal information in cookies. The cookies used in our Internet banking system and Portal are further described below. 

Internet Banking Cookies 

Our Internet banking product uses encrypted cookies that do not pass to your computer’s hard drive.  Instead, the cookie is stored in your computer’s memory, identifying only your computer while you are logged on. Only our service provider can read the information in these cookies. This Internet banking cookie allows us to process multiple transactions during your session without requiring you to reenter your pass code for each individual transaction. The cookies for Internet banking simply provide another level of security for our Internet banking product. When you log off, or close your browser, the cookie is destroyed. A new cookie is used for each session. That way, no one can use the prior cookie to access your account. For additional security, the cookie expires after 10 minutes of inactivity. It must then be renewed by reentering your pass code. We do not (and cannot) use this cookie to collect or obtain new personal information about you.  You must allow your browser to accept this cookie so you can use the Internet banking product.

Portal Cookies:

Our service provider uses several cookies to provide features within the Portal.  The “Web Trends” cookie is sent to all Portal visitors in order to help us collect general information on all Portal visitors. This cookie is sent to your computer hard drive and provides us information such as; when you accessed our site, which pages you accessed in the portal, and what Internet provider you used when you accessed our site. The information collected through this cookie is not personally identifiable and is only used for statistical purposes to assist us in our planning process and our marketing program.

When visitors register on the Portal and select the “Remember Me” checkbox, our service provider sends an additional cookie to your hard drive, which enables you to customize the Portal and bypass the login process each time you revisit the Portal. These cookies are retained on your computer until you either delete them or click on the Logout link within the Portal. These cookies only contain a unique user identification number and do not contain or collect any personally identifiable information.

When registered users login to the Portal, our service provider sends an additional cookie called a "per-session" cookie or "server-side" cookie. This "server-side" cookie resides in the browser and is only used to monitor the session by a unique identification number. This cookie is used for security purposes and you must allow your browser to accept the "server-side" cookie to use the Portal. The cookie is destroyed after eight hours. 

When you click on advertisements of 3rd party merchants within they Portal, they may also send you a cookie.  You do not have to accept these cookies to use the Portal. 

Disclosure of Information

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

We must provide certain customer account information to service providers, so that we may process your Internet banking transactions.

We do not sell any of your personal information.

We will not disclose any medical information that you provide to us, unless you specifically authorize its disclosure.

We may disclose a portion of the customer information that we collect on our Website and/or Portal to financial institutions that perform marketing services on our behalf and with whom we have joint marketing agreements.  Our contract requires these financial institutions to protect the confidentiality of your personal information to the same extent that we must do. The disclosure of certain information to these financial institutions can help us market financial products and services that may be of particular interest to you or save you money.

Email Policies

In the future we may send you email notices for certain required disclosures if you choose to accept electronic disclosures or account statements.  We may also send you emails marketing our products and services. We will always provide you an opportunity to opt-in or opt-out of email advertising promotions.

We offer secure email through our Internet Banking service.  You should use the secure mail service anytime you send us sensitive personal information.

External 3rd Party Links 

Our website  has numerous links to other 3rd party sites.  These links to external third parties are offered as a courtesy and a convenience to our customers.

First Service Bank IS not responsible for the privacy and security practices or the content of linked 3rd party sites. AS A GNERAL RULE, YOU SHOULD ALWAYS LOOK FOR AND REVIEW A SITE’S PRIVACY POLICY BEFORE GIVING OUT ANY PERSONAL INFORMATION.

When using our Portal, you may still see our logo when visiting other 3rd party sites.  A technique called “Framing” allows us to display our logo while allowing you to browse another site at the same time.  While you may still see our logo in the top frame of 3rd party sites, we are NOT responsible for the privacy and security practices of these 3rd party sites.

Third party merchants may collect personal information from you when you visit their websites.  For example, they collect personal information from you when you provide billing information or send them an email.  Some third party merchants may also send you a cookie to collect data on your Internet usage and preferences.  When you click on advertisements at third party sites, the advertising company may also send you a cookie.  With the exception of our service providers, we do NOT have access to the information collected by any third party, nor can we control how they use this information.  If you have questions or concerns about the privacy policies and practices of linked third parties, please review their websites and contact them directly.

Security

This financial institution has developed strict policies and procedures to safeguard your personal information. We restrict employee access to your sensitive personal information to a "need to know" basis. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We educate our employees about the importance of confidentiality and customer privacy.  We take appropriate disciplinary measures to enforce employee privacy responsibilities.

Our Internet Banking service provider, FundsXpress Financial Network, Inc. has also developed security policies and procedures to protect the customer information that they must collect and maintain to help us process your banking transactions over the Internet. They have developed a top-of-the line security system to ensure your customer information is protected on the Internet and within the data center environment. For more information on the FundsXpress security measures, please visit their website at http://www.fundsxpress.com.

Privacy of Children

First Service Bank respects the privacy of children.  We do not knowingly collect names or any other personally identifiable information from children.  We do not knowingly market to children nor do we allow children to open accounts online without parental consent. 

Our website may include linked 3rd party sites that would be of interest to children.  We are not responsible for the privacy and security practices of these sites.  Parents should review the privacy policies of these sites closely before allowing children to provide any personally identifiable information.  

Questions

If you have any questions on our privacy policy or concerns about our privacy practices, please contact us at 1-800-669-2517 or ebanking@1stservicebank.com or write to us either of the following addresses:

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