Privacy Policy and Disclosure

The directors, management, and staff of First Sentry Bank are concerned about and respect the privacy of customers’ personal financial information. We understand that our customers furnish sensitive information to the bank in the course of 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 consumers and those consumers who become our customers.

TYPES OF INFORMATION THE BANK COLLECTS

At First Sentry Bank we collect nonpublic, personal information from many sources. The bank collects nonpublic personal information directly from consumers on various applications and forms, for example, loan applications, deposit account applications, and requests for information about accounts or products and services.

The bank also collects information as a result of transactions between the bank and our customers and as a result of providing a product or service to our customers. This includes transaction information from checks, debit cards, credit cards, automated teller machine (ATM) cards, and electronic transfers (e.g., home banking or automated clearinghouse (ACH) transactions).

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

TYPES OF INFORMATION THE BANK DISCLOSES

The bank does not now, nor does it intend in the future, to disclose any personal financial information to any nonaffiliated or affiliated third party. By law the bank may disclose certain personally identifiable information without allowing consumers the right to opt out of the bank’s sharing agreements in the following circumstances:

To companies who perform transaction processing for the bank in the following circumstances:

• If the transaction, service, or product is requested or authorized by the consumer
  • To maintain or service a consumer’s account as part of a private label credit card or other loan extension program
  • In connection with a securitization, secondary market sale (including servicing rights), or similar transaction related to a consumer
  • To disclose information necessary to enforce the bank’s legal or contractual rights or the rights of any other person who is engaged in the financial transaction
• To disclose information 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 Credit Reporting Act
• To comply with federal, state, or local laws, rules, and other applicable legal requirements.

SAFEGUARDING CUSTOMER INFORMATION

A First Sentry Bank we protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. The bank has appointed a financial privacy coordinator, Betty Wilcox, Compliance Officer, who is responsible for maintaining internal procedures to ensure that our customers’ information is protected. 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 financial privacy coordinator, 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.v
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.

This same policy will continue to apply to the customer’s information even after the customer relationship has been terminated.