Privacy Statement
Revised August 2006
We Value Your Trust. Trust is the foundation of our relationship with you. You have selected us to provide financial products and services because you trust us to act with integrity, to process your financial transactions and administer your accounts accurately, to handle information about you responsibly and to preserve the confidentiality of your financial affairs. We strive every day to earn your trust and confidence.
We recognize and respect your privacy expectations and are committed to protecting your privacy rights. At the outset, we want to assure you that:
- We do not sell our customer mailing lists or other customer information to outside marketing firms.
- We do not disclose medical information except as necessary to process insurance applications and claims or as otherwise required or permitted by law.
- We will continue to protect your privacy rights even after you close your accounts or become an inactive customer.
About This Notice. This notice summarizes our consumer privacy policies and practices and certain rights you have under the federal Fair Credit Reporting Act. Our consumer privacy policies and practices protect the confidentiality of information about individuals who obtain financial products or services from us primarily for personal, family or household purposes. They apply with equal force to both current and former customers. When we use the term “information” in this notice, we mean information about you that is not publicly available. The policies and practices described in this notice do not apply to or protect information about you that is publicly available, information about business entities or information about individuals who obtain financial products or services for business, commercial or agricultural purposes. We have included examples in this notice of information we collect, how we use it, with whom we share it and what we do to protect it. The examples we use are for the purpose of illustration only – you should not consider them to be a comprehensive description of our privacy practices. This notice does not apply to your relationships with other financial service providers (such as other banks, mortgage brokers, independent insurance agencies, insurance companies, securities broker-dealers, or mutual funds). Their privacy policies will govern how they collect, use and disclose personal information about you.
We Collect and Use Information Responsibly. We collect and use information about you to administer our business and provide you with high quality financial products and services. We collect information about you from a variety of sources, including:
- Information about your experiences and transactions with us, with our affiliates or with others. For example, this information may include your account balance, payment history or credit card usage.
- Information you provide us on applications, personal financial statements or in other oral, written or electronic communications. For example, this information may include your name, address, Social Security number, employer, assets, income and health information. The only information we collect about you through our websites is information you voluntarily provide.
- Information we receive from consumer reporting agencies (credit bureaus). For example, this information may include your credit history, credit score and other information about your creditworthiness.
- Information we receive from third parties such as government agencies and health care providers. For example, in insurance transactions this information may include your driving record, medical history or current health condition.
- We use information about you, for example, to process your applications, administer your accounts and insurance products, process your transactions, serve your financial needs, determine your eligibility for products and services we offer and provide you with information about products, services and other opportunities that may interest you. We Protect Information Internally. The only people authorized to access customer information are those who have a legitimate business reason to do so in connection with their job responsibilities. Our employees are bound by our Code of Ethics to access customer information only for legitimate business purposes and to keep information about you confidential. We emphasize this confidentiality obligation in our training and procedures and maintain appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
In addition, we maintain physical, electronic and procedural safeguards that comply with federal standards to prevent unauthorized access to information about you. Information you provide us through our websites is similarly protected. Information Sharing.
With Related Companies to Serve You Better. We call the companies that are related to us by common ownership or control our “affiliates.” Our affiliates are all financial service providers, including banks, securities broker-dealers, insurance companies, and insurance agencies. When we are permitted to share information about you with our affiliates, we can serve you more efficiently, make it easier for you to do business with us and offer you a wider variety of financial products and services. For example, if you open an account with us and want to open an account with our affiliate, you may not have to furnish application information twice.
We are permitted by federal law to share certain types of information about you with our affiliates, including identification information and information about your transactions and experiences with us. In addition, unless you tell us not to, we may share other information about you with our affiliates that we call “eligibility information.” We use eligibility information to determine your eligibility for our products and services. Eligibility information may include, for example:
- Information we obtain from your applications, personal financial statements or other forms, such as your income, employment and marital status;
- Information we obtain from a consumer report or a credit bureau, such as your credit history or your credit score;
- Information we obtain to verify your representations to us, such as open lines of credit you may have with others; and
- Information we obtain from others regarding employment, credit or other relationships you may have with them, such as your employment history.
How to Tell Us Not to Share Eligibility Information with Our Affiliates
If you prefer that we refrain from sharing eligibility information about you with our affiliates, you may direct us not to by calling us at 804.897.3900. When two or more customers jointly obtain a financial product or service from us, we will treat a request not to share eligibility information made by one of the joint customers as applying only to that person unless that customer tells us that he or she is acting on behalf of other joint customers. We will process your request as quickly as we reasonably can .
Note: We are required by law to send a summary of our consumer privacy policies and practices to you each year for as long as you remain our customer. If you tell us not to share eligibility information about you with our affiliates, we will honor your instructions until we receive instructions from you to the contrary. You do not need to notify us each time you receive a copy of our privacy notice.
With Companies that Work with Us to Serve You Better. We may use outside companies to assist us in processing your transactions, maintaining and servicing your accounts and insurance products and in the day-to-day conduct of our business. For example, other companies perform specialized support services for us when they imprint checks, provide data processing support, process payments or assist us in our marketing efforts. In addition, we may enter into joint marketing agreements with other financial institutions to offer you a wider variety of financial products and services. We may disclose any of the information we collect to companies that perform services (including marketing services) for us and to other financial institutions with which we have joint marketing agreements. However, when we do so, the company’s right to use and redisclose the information we provide is limited by law or contract.
In Other Situations. We do not otherwise disclose information about you without your consent except as required or permitted by law. For example, we are permitted or required to disclose information about you to process your transactions and maintain and service your accounts with us and the insurance products you purchase from or through us, to report our experiences with you to credit bureaus in accordance with well-established banking practices and the federal Fair Credit Reporting Act, to protect against fraud or loss, or to respond to a subpoena or court order.
We Handle Medical Information with Special Care. In connection with insurance transactions, we may gather medical-record and health information about you, privileged information relating to insurance claims or court proceedings, and information about your character, personal habits, mode of living, or general reputation. We use information of this type that we gather in connection with insurance transactions to process, underwrite and administer insurance applications, products, accounts and claims, and for other permissible business purposes. We do not share this insurance information or any classification based on this information with our affiliates or others except as required or permitted by law. In addition, we do not share health or medical-record information that we gather in connection with insurance transactions for marketing purposes.
In connection with insurance transactions, we may gather personal information from persons other than those proposed for coverage. You have certain rights to access and make corrections to personal information we gather about you in connection with insurance transactions. In certain circumstances required or permitted by law, we may disclose personal insurance information without your authorization. We will provide you at your request with more detailed information about our insurance information practices and your right to access and correct insurance information.
We Make Every Effort to Maintain and Report Accurate Information. We make every effort to maintain accurate, current and complete records of financial information about you in accordance with reasonable and prudent commercial standards. When we learn of inaccuracies, we promptly make corrections.
If you believe we have incorrectly reported information about you or your account to a credit bureau, please notify us promptly. Your notice to us should be in writing and include your complete name, current address, Social Security number, telephone number, account number, the affiliate company you believe incorrectly reported the information, the specific item of dispute and the reason you believe the information we reported is inaccurate.
Other Privacy Protections. You may have additional privacy rights under the laws of some states, and we may be required to send you additional notices or disclosures. We will comply with all applicable state and federal laws that protect the privacy of information about you.
Reporting Information to Credit Bureaus. We may report information about your account or accounts to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report .
