Deposit Account Agreement and Disclosure
Privacy Policy
Effective May 17, 2006
What this Policy Covers
Our concern for safekeeping your personal information goes far beyond this brochure. Our Privacy Policy covers the practices of First Federal – including our banking, investment and financial planning. It applies to all personally identifiable information about you that is obtained by First Federal (“personal information”). At any time you decide to close your account or become an inactive customer, we will continue to adhere to the procedures described in this notice and any proper opt-out requests you make. This Privacy Policy also serves as our Privacy Notice. This Privacy Policy contains important information about your choices in relation to certain information sharing and marketing offers within First Federal. You should be sure to review carefully the Sharing Information within First Federal section and your ability to opt out as set forth in this policy. This policy does not apply to business or commercial customers.
Recognition of a Customer’s Expectation of Privacy
You regard your personal information as yours, and so do we. Because we do not sell or share your information with third parties not associated with services or activities of First Federal (except as allowed by law), there is no need for you to tell us not to share your personal information with non-affiliated third parties.
Collection, Retention and Use of Customer Information
We collect and use various types of information to service your accounts, save you time and money, and better understand your needs. We collect personal information about you from the following sources:
• Information we receive from you on applications on other forms
• Information about your transactions with us
• Information we receive from a consumer reporting agency
Security Standards
We maintain physical, electronic and procedural safeguards to protect the integrity and confidentiality of your information. First Federal also limits access to your nonpublic personal information to those employees who need to know that information in order to provide products and services to you. All our employees are trained to understand and comply with these information principles. First Federal has implemented internal controls and procedures designed to maintain accurate records concerning your personal information. Should you ever believe that our records contain inaccurate, incomplete or non-current information about you, please notify us. We will respond to requests to correct the information in a timely manner.
Disclosure of Information to Nonaffiliated Third Parties
We do not disclose any nonpublic personal information about our customers or former customers to non-affiliated third parties, except as permitted by law as described below.
Service Providers and Joint Marketing Agreements
We may disclose all of the information we collect, as described under the heading Collection, Retention and Use of Customer Information, to companies that perform marketing or other services on our behalf or to other financial institutions with whom we have joint marketing agreements.
Looking Out for Children
We recognize that protecting children’s identities and privacy is important. We do not knowingly market to or solicit information from children under 13 without parental consent.
Sharing as Required by Law
We may disclose information to non-affiliated third parties as allowed by law. For example, this may include a disclosure in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, an audit or examination, or the sale of your account to another financial institution. We may also share information:
• If you initiate a request for us to share information with an outside party
• If the information is provided to help complete a customer initiated transaction
Sharing Information within First Federal
First Federal consists of financial service providers and the number of companies may change from time to time. There are no non-financial companies, or other organizations within First Federal, with whom we share information. We share the personal information we collect about you within First Federal in order to:
• Provide customer service or account maintenance
• Tell you about other products or services offered by First Federal that we believe you will find useful
We may share information about our experiences or transactions with you or your account, such as account balance, payment history and services purchased, among First Federal. Additionally, unless you tell us not to as described below, we may also share other information about you not based on our transactions or experiences with you within our family of affiliates. This “non-experience information” includes information that is used, expected to be used, or collected for the purpose of establishing your eligibility for consumer credit, insurance and deposit accounts, including information:
• From your applications, such as your income, assets or marital status
• From a credit report, such as your credit score or credit history
• From sources used to verify representations made by you, such as open lines of credit or employment history
Notice of Your Opportunity to Opt Out of Certain Information Sharing and Marketing within First Federal
If you prefer that we not share non-experience information about you within First Federal, you may opt out; that is, you may direct us not to share this information by calling us at (931) 552-6176. Note: Your opt-out decision in the above paragraph covers certain information about you that we might otherwise share. However, we may share other types of information about you as permitted by law.
Your decision to opt out will continue until it is revoke by you. If you have already notified us of your election to opt out, you do not need to contact us unless you choose to modify your previous directive. For any accounts that you hold jointly with another person, your opt-out directive will apply to all of the associated joint account holders.
Our Privacy Protections
You may have other privacy protections under some state laws. We will comply with applicable state laws as to information about you. For example, certain state laws may restrict the types of information we may disclose about you or require us to provide you with an additional notice.
USA Patriot Act
To help the government fight the funding of terrorism and money laundering activities, the USA Patriot Act requires all financial institutions to obtain, verify and record information that identifies each person (including business entities) who opens an account. What this means for you: When you open an account, we will ask for your name, physical address, date of birth, taxpayer identification number and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. We will let you know if additional information is required.
Keeping Up to Date with our Privacy Policy.
We will provide notice of our Privacy Policy annually, as long as you maintain an ongoing relationship with us. The Privacy Policy may also be found online at the First Federal website, www.firstfederalsb.com. We reserve the right to change this policy at any time upon proper notice to you.
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