Drake Bank Privacy Statement

It is the policy of Drake Bank to safeguard the financial information of our customers. We take every precaution to keep your information confidential due to the sensitive nature of the information you provide to us. You have the right to expect the information you provide to be accessible only to those who must know the information to meet your needs. You also have the right to expect this information to be used in an appropriate business manner.

Drake Bank collects nonpublic personal information only to provide services our customers' request, that will be used to meet our customers' financial needs, and is allowed by law. With regard to loans, we will collect information relative to previous banking relationships, employment status, income, monthly expenses, assets and liabilities as supplied on your credit application and other written information provided by you. With regard to deposit accounts, we will collect information relative to employment status and previous banking relationships.

We will also collect nonpublic personal information from third parties, i.e., credit reporting agencies, other creditors and your previous banking relationships. This information will only be used relative to your request for specific services provided by Drake Bank. We will not collect information about you from third parties without a valid reason.

The nonpublic personal information that we collect about you will be from the following sources:

• Information we receive from you on applications or other forms, whether in writing, electronic or internet transmission;
• Information about your transactions with us or others; and
• Information we receive from a consumer reporting agency.

The nonpublic personal information we obtain about you is restricted, within the bank, to employees who must have the information to provide the products and services you request. Drake Bank has in place specific policies and procedures to ensure the confidentiality of your records, how and when the information will be used, how to handle external requests for information and how to handle your information when they have received a legal request. To comply with federal standards, we maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.

The nonpublic personal information we may disclose about you is information we receive from you on applications and other forms, such as your name, address, social security number, assets, income and employer and/or transaction information such as your account balance, payment history, parties to transactions and debit card usage. We will only disclose this information about you to our affiliates; non-financial companies (insurance companies, vendors of nondeposit investment products and processors) so that together we can provide products and services that you request or currently have with us; or companies that perform marketing services on our behalf or other financial companies with whom we have joint marketing agreements.

If we use companies to provide transaction services for our customers, we provide only the information necessary to complete the transaction. We obtain written agreements to maintain this information solely for this purpose and in accordance with our state or federal privacy policy. All companies that act on our behalf are contractually obligated to treat information that we provide to them as strictly confidential, use the information only to provide services we ask them to perform for you and us.

Under no circumstances will we sell our customer information to anyone. We will not share your information with nonaffiliated third parties for their independent use. We will report the credit history of our transactions with our bank to appropriate credit reporting agencies.

We will provide information if you request it; if we are required by law to provide requested information (subpoena, investigation of fraudulent activity); or you have been informed about the possibility of our disclosure of your name, address, and telephone number for the purposes of marketing a product we believe will be of use to you.

Once you cease to be our customer, we may disclose your nonpublic personal information in the same manner as we do for current customers. Two years after you cease to be our customer, we will not disclose your nonpersonal public information except as permitted by law.

We do not disclose nonpublic personal information about you to nonaffiliated third parties other than disclosures permitted by law. If, in the future, we change our policy, we will provide you with the required opt out option prior to disclosing your nonpublic personal information.

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