Important Notice About Customer Information

Waterfield Bank (WB) and its affiliate Waterfield Financial Services (WFS), recognize and value each and every customer relationship. Customers such as you have entrusted us not only with your finances, but also with your personal information. To protect and maintain this relationship, we have adopted the following Privacy Principles as a commitment to you, our valued customer.

Recognition of Your Expectation of Privacy

WB and WFS recognize that you expect privacy and security for your personal and financial affairs. We understand the need to safeguard our sensitive information about you that you have entrusted to us. We maintain standards and procedures designed to prevent misuse of this information.

Use, Collection, and Retention of Customer Information

WB and WFS collect, retain, and use information about you only where we reasonably believe that it will help administer our business or provide products, services, and other opportunities to you. We collect and retain information about you only for specific business purposes, and we will tell you why we are collecting and retaining it upon your request. We use information to protect and administer your records, accounts, and funds; to comply with certain laws and regulations; to help us design or improve our products and services; and to understand your financial needs so that we can provide you with quality products and superior service.

Sources of Information WB and WFS Collect

To assist us in making informed decisions about extending services to our customers, we may collect nonpublic personal information about you from several sources:

• Information that you have provided on applications or other forms via the internet, by telephone or other means;
• Information about your transactions with us or others; and
• Information about you that we obtain from consumer credit reporting agencies, real estate appraisers, and employers.

Nonpublic Personal Information Means: (1) Personally identifiable financial information; and (2) Any lists, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information other than publicly available information.

Maintenance of Accurate Information

WB and WFS have procedures in place to help us assure that your financial information is accurate, current, complete and in accordance with commercial standards. We also have procedures in place to respond to your requests to correct inaccurate information in a timely manner.

Security Procedures to Protect Information

WB and WFS have procedures that limit employee access to personally identifiable information to those employees with a business reason to know such information about you. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our policies on business ethics. We maintain security standards and procedures to help prevent unauthorized access to confidential information about you.

Sharing of Nonpublic Personal Information within the Bank and Affiliates and Nonaffiliated Third Parties

Within WB and WFS, the primary purposes for which we share your nonpublic information is to develop or improve the products and services currently offered to our customers. Your customer information allows us to respond quickly and efficiently to inquiries and to protect the security of your accounts with us. As part of our efforts to offer you the best and most current banking opportunities, we may contact you with information about new services and special marketing promotions. If you would like to be taken off our mailing list or email list, please submit your request to Waterfield Bank.

WB and WFS do not disclose nonpublic personal information about you to any nonaffiliated third parties except as permitted by federal law. The confidentiality of your nonpublic personal information will continue to be maintained consistent with this privacy notice even if you decide to close your account(s), your account becomes inactive, or when you otherwise cease to do business with us.

WB and WFS work with a variety of nonaffiliated third parties in order to bring you the best quality financial services possible. We disclose information about you as necessary to fulfill these third party service agreements. For example, we may disclose information about you to third parties that assist us in servicing or maintaining your loan or deposit account, or other business relationship, such as printing checks or billing you for loan payments. We may also disclose information about you to governmental entities, such as sending annual income statements to the IRS, and to other third parties, such as credit reporting agencies, or in response to subpoenas.

WB and WFS may also disclose information we collect or generate to companies that perform marketing services on our behalf or to other financial institutions, such as insurance providers, with whom we have joint marketing agreements. These companies must agree to strict confidentiality provisions to assure the protection of your information. Because we already limit the sharing of your nonpublic personal information as outlined above, no action is necessary on your part to limit such sharing.

Disclosure of Our Privacy Principles To You

WB and WFS want you to understand our commitment to your personal privacy and our use of information. For this reason, we have prepared these Privacy Principles. The above information should answer most of the important questions that you may have about how we gather, protect, and use information. If you have additional questions, please respond to us in writing and we will provide a prompt reply.

These Privacy Principles apply only to individuals. We reserve the right to change them, along with related provisions from time to time and will provide adequate notice to you should a change occur.

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