Citizens State Bank: Privacy Policy and Disclosure

Citizens State Bank Privacy Policy and Disclosure

The directors, management and staff of Citizens State Bancorp, Citizens State Bank and its affiliates are concerned about and respect the privacy of customers’ and consumers’ personal financial information. We understand that our customers furnish sensitive information to the bank in the course of our daily business and the bank is committed to treating such information responsibly. We know that our customers expect privacy and security for their personal and financial affairs.

The bank will take all the necessary steps to safeguard sensitive information that has been entrusted to us by our customers. The following privacy policy and disclosure outlines our bank’s practice regarding personally identifiable financial information for bank customers and consumers. To obtain more information, you may call us toll-free at 1-888-598-8900 or visit our web site: www.mycommunitybank.com.

Types of Information the Bank Collects

At Citizens State Bank we collect nonpublic, personal information about you from many sources, including the following:

Information we receive from you on applications or other forms when you visit us in person, over the phone, through the mail or through our website;
Information about your transactions with us, our affiliates, or others;
Information we receive from a consumer reporting agency;
Your browser, when you visit us at our website and your browser interacts with us;
Other sources, in connection with providing you a financial product or service.

Nonpublic, personal information does not include that which is available from government records, widely distributed media or government-mandated disclosures.

Types of Information the Bank Discloses

The bank may disclose the following types of information about current or former customers to our family of affiliated businesses as permitted by law:

Identification information, such as name, address and telephone number
Transactional information
Deposit or loan account experience

Examples of the types of businesses we are affiliated with are listed below:

Insurance Company
Brokerage Company

The bank may also share all of the information we collect from you, as described in the previous section, with certain nonaffiliated third parties. The types of businesses these parties represent are:

Mortgage banking companies
Insurance companies

Service Providers and Joint Marketing Ventures

The bank may disclose the following information to companies that perform marketing services on our behalf or to other financial institution with which we have joint marketing agreements:

Information we receive from you on applications or other forms, such as name, address, social security number, assets and income.
Information about your transactions with us, our affiliates, or others, such as account balances, payment history, credit card usage, parties to transactions
Information we receive from a consumer reporting agency, such as your creditworthiness and credit history

Although you will not have the option to opt out of this sharing agreement, if the bank shares information with a third-party nonaffiliated marketing firm for the purpose of telling you about our new products or services, the bank will enter into a written agreement with the third party that will require the third party to maintain the confidentiality of the information in the same manner the bank would and to restrict its use.

The bank will not provide your personal information to non-bank companies for the purpose of their independent telemarketing or direct mail marketing of any non-financial products or services.

Safeguarding Customer Information

At Citizens State Bank, we protect consumer privacy by having procedures in place that limit access to personal information to those employees, representatives and service providers who need to know such information in order to perform business services or market products on our behalf. For example, information in loan files can only be accessed by employees who work in the loan origination or loan operations departments.

All employees have a copy of this policy and are trained at least annually regarding the importance of safeguarding customer information. The security officer, the human resources director and the appropriate department manager will take disciplinary action against any employee who violates the bank’s privacy policy and procedures.

The bank maintains physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic, personal information.

If we change our policy or practice by, for example, adding a category of information that we will disclose to a third party, we will notify existing customers and give them an appropriate time period to opt out of the disclosure.

Website

We are not responsible for the collection, use of security of information by companies or organizations outside of the Citizens State Bank family that may be linked to our websites. We encourage you to read the privacy policies of websites reached through the links from Citizens State Bank’s website.

Information About Cookies

Cookies are small pieces of information stored directly on your personal computer. Cookies help web sites to keep track of your preferences and to recognize you as a return visitor. Citizens State Bank does not use persistent “cookies” or tracking mechanisms that collect personally identifying information on our site. Customers will only be contacted through our web site in response to an email sent to us or by choosing to opt-in to our informational email system.

Children’s Online Information Privacy

In accordance with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect, maintain, or use personal information from our websites about children under age 13. If a child who 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. For information concerning the Children’s Online Privacy Protection Act , visit the Federal Trade Commission’s web site at www.ftc.gov.

Changes to Online Practices

We reserve the right to change our practices by posting changes to our practices at this location.

Your Right to Opt Out of Sharing Agreements

You have the option of opting out of the bank’s sharing agreements with nonaffiliated parties (other than disclosures permitted by law) by completing the Opt-Out Notice form and returning it to the bank in the manner described on the form.

If you sign the opt-out notice at the time your account is opened or application processed, we will honor your request immediately.

However, you may opt-out of the bank’s sharing agreements at any time. If you notify the bank after your account is opened or application processed, we agree to stop sharing your information within 60 (sixty) days from the date we receive your request.

A single privacy and opt-out notice will be used when tow or more consumers jointly obtain a financial product or service. However, any of the joint account holders have the ability to opt-out on behalf of all the joint account holders.

EXCEPTIONS TO YOUR OPT-OUT RIGHTS

By law the bank may share personal information about consumer without allowing consumers the opportunity to opt-out in the following circumstances:

With companies who perform transaction processing for the bank in the following circumstances:
1. If the transaction, service or product is requested or authorized by the consumer
2. To maintain or service a consumer’s account as part of a private label credit card or other loan extension program
3. In connection with a securitization, secondary market sale (including servicing rights) or similar transaction related to a consumer
For disclosures that are necessary to enforce the bank’s legal or contractual rights or the right of any other person who is engaged in the financial transaction
For disclosures required in the ordinary course of banking business, such as the settlement of claims or benefits, the confirmation of information to the consumer or the consumer’s agent and the billing, processing or clearing of items in the normal course of business
To provide information to insurance rate advisory organizations, guaranty funds or agencies, agencies that are rating the bank, persons who are assessing the bank’s compliance with industry standards and the bank’s attorneys , accountants and auditors
To the extent permissible under the Right to Financial Privacy Act
To a consumer reporting agency under the Fair and Accurante Credit Transactions Act of 2003 (FACT Act)
To comply with federal, state, or local laws, rules and other applicable legal requirements
To on-line privacy protection under Gramm-Leach-Bliley Act (GLBA).

Citizens State Bank Companies Providing this Notice

This policy is provided by the Citizens State Bancorp Inc., and Citizens State Bank and its affiliates is listed below. Separate disclosures of additional information or opt out choices may be provided to you if required under applicable state law.

Citizens State Bank
Citizens State Mortgage Services LLC

The board of directors approved and adopted this policy on May 20, 2003, and amended and approved on September 14, 2004.

Consumer’s Right to Opt-Out of Citizens State Bank’s Information Sharing Agreements

I/we wish to opt-out of any customer information sharing agreement that Citizens State Bank has with
_______Affiliated companies

_______Nonaffiliated companies

If you sign the opt-out notice at the time your account is opened or application processed, the bank will honor your request immediately.

However, you may opt-out of the bank’s sharing agreements at any time. If you notify the bank after your account is opened or application processed, the bank agrees to stop sharing your information within 60 (sixty) days from the date the bank receives your request.

You may return this notice by mail to the bank at the address below or send a written request to opt-out of the bank’s information sharing agreements at a later time to:

Compliance Department
Citizens State Bank
51066 Washington Street
New Baltimore, MI 48047

If you send a written request to the bank at a later time, please include the following information in your request:

Your name
Your address
All of your account numbers
The names of all persons authorized to use your accounts
Your social security number and all persons authorized on your accounts

______________________________ _____________________ _______________

Customer signature

Social Security number

Date

______________________________ _____________________ ________________

Customer signature

Social Security number

Date

Account number______________________ Type of account_______________________

Account number______________________ Type of account_______________________

Account number______________________ Type of account_______________________

Account number______________________ Type of account_______________________