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Disclosures - Privacy Statement

Privacy Statement

First State Bank of East Detroit has only one affiliate, First State Bank Mortgage Company, LLC (the two entities will be referred to collectively as “First State”).  We have a long history of meeting the needs of our customers and providing high levels of service.  We respect the privacy of our customers and are committed to treating customer information responsibly.  This Privacy Statement (“Statement”) applies to current and former customers, and to consumers. It is intended to comply with the requirements of Title V of the Gramm-Leach-Bliley Act, as well as applicable privacy regulations.

 Definitions

Consumer means any individual who is seeking to obtain a financial product or service from a financial institution for personal, family, or household purposes.  The definition of consumer includes individuals who:

·         Apply for a financial product or service (e.g. a loan or deposit account) for personal, family, or household purposes; and

·         Actually obtain a financial product or service (e.g. a loan or a deposit account) for personal, family, or household purposes.

Customer means a consumer with whom a financial institution has a continuing relationship.  Consumers who have a deposit account, obtain a loan, or obtain an investment advisory service are considered customers.

Nonpublic personal information means personally identifiable information provided by a consumer to a financial institution collected in connection with providing or obtaining a financial product or service.  This information does not include publicly available information.

Affiliate means any company that controls, is controlled by, or is under common control with another company.

Nonaffiliate third party means any entity that is not an affiliate of, or related by common ownership or affiliated by corporate control with, the financial institution, but does not include a joint employee of such institution.

Privacy Statement Distribution

First State recognizes and respects the privacy expectations of our customers.  We want our customers to understand our commitment to the security of their nonpublic personal information as well as the use of customer information.  For this reason, First State developed this Statement, which describes the sources of nonpublic personal information we collect on our customers, our information sharing practices and the measures we take to protect and secure that information.  This Statement is made readily available to all customers and is provided at the beginning of their relationship with First State.  In addition, we will mail a copy of this Statement (which will include any amendments or modifications) to all of our customers on an annual basis.

 Collection, Use and Sharing

First State collects, retains and uses public and nonpublic information about customers when required by statute or regulation in order to identify you and protect your accounts from unauthorized access or identity theft, to service your accounts and process your service requests, and where we reasonably believe that it will help administer business or provide products, services and other opportunities to you. 

 Nonpublic information is collected from:

·         Information received from you when opening an account;

·         Information we receive from you on applications and other documents including identifying information such as name, address, telephone number, e-mail address and social security number and credit related information such as your assets, income and liabilities;

·         Transactions with us or with others such as payment history, account balances and usage; and

·         Information from consumer reporting agencies such as your credit worthiness and credit history or real estate appraisals.

First State may share customer information to:

·         Protect and administer your records, accounts and funds;

·         Provide information to assist us in processing applications or managing your accounts;

·         Help us design or improve our products and services;

·         Understand your financial needs so that we can provide quality products and superior service;

·         Send brochures and/or literature to you regarding new or upcoming products and services offered by First State in an effort to offer you the array of financial products and services needed to meet your financial goals;

·         Comply with certain laws and regulations (such as a subpoena, summons, garnishment, levy or other court order); and/or

·         Identify and mitigate potential risks or losses.

 First State does not reveal specific information about customer accounts or other personally identifiable data to other parties unless:

·         You request or authorize it;

·         The information is provided to help complete a transaction initiated by you;

·         It is permitted pursuant to statute, such as the Fair Credit Reporting Act; and/or

·         The disclosure is lawfully permitted or required.

Sharing with Nonaffiliate Third Parties

First State does not share our former or current customers’ nonpublic information with nonaffiliated third parties except in those situations listed above.

 Sharing with our Affiliates

First State may share the information it collects about present and former customers with its affiliates as required or permitted by law.  This information sharing is limited. Shared information may include identifying information, and this information is only used as a normal part of conducting company business.

Accuracy and Maintenance

We continually strive to maintain complete and accurate information about our customers and their accounts.  If you become aware that our records are inaccurate, please help us correct them by contacting our Customer Service Department at (866) 372-1275 or visiting one of our branch offices.

 Securing Information

We understand and recognize that information is vital in providing quality service to our customers.  We also realize that our customers’ trust must be maintained by protecting that information from improper disclosure. This is one of our fundamental responsibilities.  For this reason, operational and data processing systems are in a secure environment that protects our customer account information.  First State maintains and grants access to customer nonpublic information only in accordance with its internal security standards.  We are continuously reviewing our physical, electronic, and procedural safeguards to ensure compliance with federal and state standards to protect your nonpublic information.

 Employee Access & Training

First State employees are prohibited from disclosing to any unauthorized person any information contained in our records. Employee access to customer information is restricted to those employees with a business reason to access such information.  Employees are trained on the importance of maintaining the confidentiality of customer information and First State’s privacy practices on an on-going basis. 

 Service Provider Arrangements

Due diligence is exercised in selecting outside service providers.  Appropriate measures are defined in service contracts which detail operative controls to avoid the unauthorized release of customer information.  All service providers are required to treat and maintain the privacy of customer information to at least the same extent and with the same degree of diligence and careful attention that is required of First State.

Additional Information

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

 Customers who have questions about the treatment of their nonpublic personal information should contact First State’s Compliance Officer at (866) 372-1275.

This Privacy Statement applies to individuals and covers information obtained in connection with consumer transactions.  First State’s Privacy Statement is reviewed periodically as may be required by applicable laws or regulations.  First State reserves the right to change or revise this Statement at any time.

Rev. Dec. 2007