Silverton Bank, N.A. is dedicated to protecting your privacy and handling your information in a secure and confidential manner. We know that having trust and confidence in the companies you do business with is important to you. We value the trust you have placed in us to protect your information. Our commitment to you is to protect your information according not only to Federal and State laws, but also to the standards established by our company. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard customer information.
In this Policy, the words “we,” “our,” and “us,” means Silverton Bank, N.A.; the words “you” and “your” mean our consumer customers and former customers.
This Privacy Policy includes information about:
1. The information about you we collect
2. Our management of information about you
3. The confidentiality, security, and integrity of your personal information
This Policy covers “Customer Information,” which means personally identifiable information about you and your relationship with us.
1. The Information About You We Collect
We collect and use information about you and your accounts to service your accounts, respond to your needs, and manage our business and risks. There are 5 categories of Customer Information we collect:
A. Identification Information: Information that identifies you, including your name, address, telephone number and social security number.
B. Application Information: Information we receive from you on applications or other forms that helps us to determine your eligibility for products or services you request, such as your assets, income, and debt.
C. Transaction and Experience Information: Information about your transactions and account experience with us, such as payment history, account balances, and account transactions.
D. Consumer Report Information: Information that we receive from a consumer-reporting agency such as your creditworthiness, credit score, and credit history.
E. Information From Other Sources: Information from other sources regarding your employment, credit and other relationships that we use to help us determine your eligibility for products or services you request from us. This would include your employment history, your loan and account balances, and your payment history.
2. Our Management of Information About You
We manage how and when your Customer Information is shared within our company and with our affiliated companies (our parent company and other companies owned or controlled by our parent company). We also manage how and when your Customer Information is shared with companies that work for us, other third parties, and in other situations.
Managing information within our company and our affiliated companies
The parent company of Silverton Bank, N.A. is Silverton Financial Services, Inc. We have additional affiliated companies which are financial service providers. We may share any of the categories of Customer Information among our affiliated companies. We share this information only as permitted by law in order to manage our business and risks, and none of these companies will use your Customer Information for any other purposes. For example, none of these companies will use your Customer Information received from us to market to you or otherwise to offer you any products or services.
Managing information with companies that work for us
We may share any of the categories of your Customer Information with companies that work for us. All of these companies are required to keep the information we provide them confidential and may use your Customer Information only on our behalf to provide us services we request from them. These companies may include account or transaction processing companies, mailing services, and data processing companies.
These companies also can provide marketing services on our behalf so that we may better offer you those of our products and services that we believe will be of interest to you. None of these companies are permitted to use your Customer Information for their own marketing or other purposes.
Sharing Information for Co-Branded Credit Cards
We issue certain of our credit cards under co-branded credit card arrangements with banks and other companies. A “co-branded” credit card is a credit card that bears the name or logo of us as well as a third party company. Examples of these third party companies include other banks, other financial institutions, or non-financial organizations, such as sporting teams, member associations (such as NASCAR), or retailers.
For our co-branded credit card programs with other financial institutions, such as banks, we may share any of the categories of your Customer Information with those financial institutions. Those financial institutions are permitted to use that information only for purposes of the co-branded credit card program and may not use the information for their own marketing or other purposes.
For our co-branded credit card programs with companies that are not financial institutions, the information we share will depend on our arrangement with the third party, as follows: MXT Card Services (“MXT”) is a company that is not affiliated with us but which assists us with our credit card account marketing efforts and guarantees certain credit card accounts. With MXT we may share any of the categories of your Customer Information. MXT is permitted to use that information only for purposes of our credit card program and may not use the information for its own marketing or other purposes. For non-financial companies other than MXT that participate in our co-branded credit card program, we will not share any of your Customer Information except as permitted by law.
Rebate and Rewards Programs
We may share certain of your Customer Information with those companies that provide rebates or rewards to our credit card customers under the terms of our credit card agreements. With those companies we may share the following information about you:
• Your Identification Information, but not including your social security number; and
• Your Transaction and Experience Information relating to the product or service for which the rebate or reward program is provided.
Other Permitted Disclosures
We may disclose your Customer Information to credit bureaus when required or permitted by law. We also may disclose your Customer Information in connection with subpoenas or other legal processes, or fraud investigation or prevention, institutional risk management, and for other legally permitted reasons.
Other Applicable Laws
The practices described above are in accordance with federal law. You may have other privacy rights in some states, such as Vermont and California. To the extent these state laws apply, we will comply with them when we share information about you. For example, if you are a Vermont resident, except with your consent or as permitted by law we will not disclose any information about you to other financial institutions with which we have co-branded credit card programs other than your name, contact information, and your Transaction and Experience Information related to your co-branded credit card account with us, and will not share Application Information, Consumer Report Information or Information from Outside Sources about you with our affiliated companies.
3. The confidentiality, security, and integrity of your personal information
Maintaining the accuracy of your personal information is important. We maintain physical, electronic and procedural safeguards that comply with federal standards to protect your information and to help assure that your personal information is accurate, current and complete. We also have procedures to correct inaccurate information in a timely manner, including processes to update information or remove outdated information. If you discover any information we have about you that is incorrect, please let us know.
Internally, 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. Our employees are educated and trained on the importance of confidentiality and privacy of customer information.
Silverton Bank, N.A. is a national banking association primarily regulated by the Office of the Comptroller of the Currency. Deposit accounts are Federal Deposit Insurance Company (FDIC) insured.
© 2008 Silverton Financial Services, Inc. All rights reserved.
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