Privacy Policy

At Sutton Bank we believe that your privacy should not be compromised. You can count on our belief that “Old Fashioned Innovation” will provide you with the services you want, need, and deserve, to accomplish your financial goals. This is our Privacy Notice to our customers.

We, our and us will refer to Sutton Bank.

You and your will refer to all consumer customers who have a continuing relationship with us through products such as: deposit and loan accounts, credit card accounts, safe deposit boxes, retail installment contracts held and serviced, custodial individual retirement accounts, certificate of deposit accounts, as well as any former customers. You and your also refers to any consumer that uses a bank service but does not have a continuing relationship, such as ATM transactions and loan applicants.

Affiliate is any company we own, control or who owns or controls us.

Non-affiliated Third Party is any company that is not an affiliate.

Information Collected

We collect non-public information about you:

• From applications and other forms: your name, address, social security number, income
• From your transactions with us or others: account balance and credit card usage
• From consumer reporting agencies such as a credit bureau: your credit history

Information Disclosed

We may disclose all information collected, as described above, to companies which perform marketing services on our behalf or other financial institutions with which we have joint marketing agreements. We do not disclose any non-public personal information regarding our customers to any non-affiliated third parties, except as permitted by law. Should you close all your accounts with us and become a former customer, we protect your privacy as if you were a current customer.

Confidentiality and Security

We restrict access to your non-public personal information to only those employees who require such information to provide products and services to you. We maintain physical, electronic and procedural safeguards to protect this information. Our employees understand and uphold the importance of maintaining the confidentiality of our customer information.

Fact Act Notice

We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may reflect on your credit report.

Internet Privacy Policy

Respect for Your Right to Privacy

Sutton Bank is dedicated to making your online banking experiences with us the most rewarding and satisfying available. We provide our customers with the highest level of customer service and convenience by continuing to utilize the latest technological innovations. We recognize, however, that privacy and security of personal financial information may also be a concern as a result of using this technology.

As a community bank, our most important asset is our customers' TRUST. As such, privacy and confidentiality is at the forefront of everything we do.

If you ever have any questions or concerns other than those listed below, you are encouraged to contact us at rbauer@suttonbank.com. All other inquiries should be directed to our customer service center.

Maintaining Accurate Customer Information

It is in the best interest of both you and Sutton Bank to maintain complete, up-to-date, and accurate records regarding your non-public personal and financial information. Our systems and internal controls are monitored and tested on a regular basis to verify the integrity of the non-public personal and financial data we maintain and process on your behalf. If we are made aware of any inaccurate information, we have procedures in place to correct this information. Please notify us immediately if you believe our records are incorrect or out-of-date. We will investigate the situation and, when appropriate, update our records accordingly.

Collection, Use and Retention of Personal Information

In an effort to provide you with the most secure and current banking opportunities, Sutton Bank may collect and retain non-public personal information provided by you during the application, information request, or survey process. Non-public personal information may also be collected through the submission of secure online banking transactions or use of online financial planning tools.

Online Banking and Account Application

During the Online Application process, we collect non-public personal information in order to evaluate your request to open an account. Such information is maintained and reviewed through automated and manual processes, in order to protect you --- we must identify, distinguish, and verify all information submitted during the Online Application process to prevent unauthorized individuals from using or accessing your non-public personal information. Information received and transmitted during your Online Banking sessions is also retained on our systems in order to service your account(s). Please also review our Security policies and procedures.

Customer Service

Our high standards of customer service include maintaining your written and electronic correspondence. Your letters, including the post-mark and mailing address, are filed in a secure location, and the content of email inquiries, including your email address and our responses, may be retained to support Sutton Bank management's efforts to monitor and review communications. Sutton Bank uses this information to handle further questions you may have or provide necessary follow-up assistance; to review our success in properly addressing your questions or concerns; and to ensure compliance with internal policies and procedures.

When we contract with other organizations not affiliated or controlled by us to provide account maintenance and servicing functions on our behalf, these outside agents, third party product providers, or account processing providers agree to safeguard customer information in accordance with this Privacy Policy, and must abide by applicable law.

We may also gather information through the use of cookies in order to make your online experience easier, more personalized and, thus, more convenient.

Financial Planning Tools

If you use any of the financial tools, calculators or questionnaires on our website, you will provide some level of personal and financial information. This information will only be used by Sutton Bank to provide you with services you have requested or are likely to be interested in now or in the future.

General

Sutton Bank collects information on its visitors in order to:

• Identify you and your products and services to prevent access by unauthorized persons
• Administer and service your records, accounts and funds
• Implement security measures and fight fraud for your continued protection
• Comply with certain laws and regulations
• Improve the content of our Web site for your future visits
• Customize the content and/or layout of our pages for each individual consumer, or
• Notify you of special promotions, updates to our website, or additional products and services that may be of interest to you.

Please be assured that non-public personal information will not be collected, used or retained unless Sutton Bank has a specific business purpose, to protect your accounts and transactions, comply with federal banking regulations, or help us better understand your financial needs. If, for any reason, you would like to be taken off our mailing list, contact us at 800-422-3641.

Children under the age of 13 cannot open accounts online or apply for access to their accounts through Internet Banking. We do not knowingly collect, maintain, or use personal information from our websites about children under age 13. If a child whom we know to be under age 13 sends personal information to us online, we will only use that information to respond directly to that child, notify parents, or seek parental consent. We are not responsible for the collection and use of information by companies or organizations outside of the Sutton Bank family that may be linked to our website.

Limited Employee Access to Information

Sutton Bank permits only authorized employees, who are trained in the proper handling of customer information and have a legitimate business need, to access that information. Each employee has been made aware of his or her responsibilities to safeguard your personal information, and employees are continuously reminded of the importance of confidentiality and personal privacy. Whenever we hire other organizations to provide support services, we require them to conform to our privacy standards and to allow us to audit them for compliance. Our goal is to ensure that customer privacy is respected at all times.

Disclosure of Information to Third Parties

Sutton Bank has a strict policy that prohibits the selling or providing of personal information to third parties for independent use. We may, however, in the normal course of business, make information available to Sutton Bank affiliates and business partners if the information is needed to fulfill an authorized service, requested by you, such as opening a new deposit account, applying for a VISA Debit Card or providing you with additional products and services. We may also exchange information with reputable reference sources or reporting agencies for credit reporting, risk management, and verification, in order to maximize the accuracy and security of your personal information. Only information needed to conduct your banking business or protect against fraud will be used or provided, in accordance with standard banking industry practice, unless we are required or allowed to do so by law.

Monitoring Policies

Sutton Bank continues to monitor and review the privacy measures it has in place to protect customer information. These measures are updated as practices change and new technology becomes available. Please periodically check this page for updates to our Privacy Policy.

Customer Identification Program

Important Information About Procedures For Opening A New Account:

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What This means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

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