Our policy on confidentiality for:

• TowneBank
• TowneBank Mortgage
• Towne Mortgage, LLC
• Towne Investment Group
• TowneBank Commercial Mortgage
• Towne Insurance Agency, Inc.
• Lawyers Escrow and Title Insurance Company
• Benefit Design Group, Inc.
• The Frieden Agency, Inc. T/A TFA Benefits
• GSH Residential Real Estate Corporation
• Eastern Title Company, Inc.

Our Commitment to You

TowneBank and its family of companies value you as a member and recognize the importance of protecting your financial information. We are committed to protecting the privacy, confidentiality and security of your financial information.

This Consumer Privacy Notice applies only to consumers who use our services or products primarily for personal, family or household purposes. This Notice is to inform you of the types of nonpublic personal information we collect, the circumstance under which we may share the information with our subsidiaries and affiliates and nonaffiliated third parties, and how we use and protect that information.

The policies and procedures described in this Privacy Notice are subject to change, but we will notify you of any significant changes. This Notice replaces any previous Privacy Notice issued.

Our Privacy Disclosure Policy

Categories of Information That We May Collect

We collect nonpublic personal information about you to help serve your financial needs, offer new products or services, and most importantly to provide you with exquisite member service. We gather nonpublic personal information from a variety of sources, including:

• Information we receive from you on loan or insurance applications, personal financial statements, or other forms necessary to establish an account relationship. Nonpublic personal information would include your name, address, social security number, assets, liabilities and income information.
• Information about your transactions with us, our subsidiaries and affiliates, or others, such as: your account balance, payment history, parties to transactions, and credit card usage.
• Information we receive from a consumer-reporting agency, such as: your creditworthiness and credit history.
• Information we may obtain from motor vehicle reports or medical reports to underwrite your request for insurance products.
• Information collected from our Internet web sites, such as information you provide to us and information necessary to manage your online sessions with us.

Disclosure of Nonpublic Personal Information

We do not disclose any nonpublic, personal information about our members or former members to any nonaffiliated third parties other than to process our members' accounts, and as required or otherwise permitted by law. This means we have opted out on your behalf for this type of information sharing outside of the TowneBank family of companies. We only share the information we collect, as previously described, with:

• Service providers that perform business operations for us (such as check printing and online banking services);
• Companies that market our services, or companies with whom we have joint servicing or marketing agreements (such as investment and asset management services and personal insurance products); and
• Others only as permitted or required by law (such as in response to subpoenas and information reported to consumer reporting agencies).

Any medical or health information we collect about you will be disclosed to third parties only to underwrite insurance or administer your policy or claim, as permitted by law, or as authorized by you.

We very carefully select the companies that provide services on our behalf. These companies are required to safeguard your information and use it only for authorized purposes.

Information We Share With our Subsidiaries and Affiliates

As a valued TowneBank family member, we want to ensure that your financial needs are being met. We do share information with our subsidiaries and affiliates in order to provide you with the best in financial service, and to keep you updated on any new or expanded products and services. Such new opportunities may be communicated to you from our subsidiaries or affiliates in the form of marketing brochures or mailings.

Unless you tell us not to, we may share information we have about our experiences or transactions with you or your account (such account balances and payment history) and identification information (such as your name and address) with a subsidiary or affiliate who will use that information to market its products and services to you. Also, unless you tell us not to, we may share other information about you within the TowneBank family of companies such as:

• Information that may be obtained from account applications or other forms, such as your assets, liabilities and income information;
• Information we obtain from a credit bureau, such as your credit history; and
• Information we obtain from others to verify information provided by you, such as your credit or other relationships with third parties.

Your Right to Tell us Not to Share Certain Information
With our Subsidiaries and Affiliates

If you do not wish us to share (commonly known as "opting-out") any information about you within the TowneBank family of companies, please complete and mail to us the Consumer Privacy Preference Form¹ at the bottom of this page. Of course, you may also contact your hometown banker for assistance. We will process your request as soon as we reasonably can. If you have previously informed us of your preference, you do not need to do so again.

By selecting "Opt-Out" status, you will also restrict the use of your personal information in any marketing solicitation activities conducted by our subsidiaries and affiliates. This exclusion does not apply, however, to any subsidiaries or affiliates with which you currently do business or if you ask to receive information or offers from them.

For a joint account (account held by two or more consumers), a request from any one of them "not to share" will apply to all joint accountholders. This request will be in effect until such time we receive a written request from you changing your sharing status.

Confidentiality, Security and Integrity of Information

Our employees are also committed to safeguarding member information and preventing its unauthorized access, disclosure or use. We provide on-going privacy training, and restrict access to nonpublic personal information to those employees who need to know the information in order to provide a product or service to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We require anyone to whom we disclose your personal information to protect its confidentiality and to use it solely for the purpose for which it is disclosed.

It is important that the information we maintain about you is accurate and complete. If you see information in your monthly statement(s) or elsewhere, which suggests that our information is incomplete or inaccurate, please contact us.

Click here to print the Consumer Privacy Preference Form¹

¹Special Notice to Vermont Residents - In accordance with Vermont law, we will treat accounts with Vermont mailing addresses as if you have elected to opt-out.