At Citizens Bank Minnesota, the basis of each customer relationship, many of which span generations, is trust. To honor that trust, it is dedicated to protecting the privacy of its customers, who share sensitive financial information with it in order to enable its staff to help them accomplish their financial goals. As such, Citizens Bank Minnesota has adopted the following privacy policy:

RECOGNITION OF A CUSTOMER'S EXPECTATION OF PRIVACY

The bank recognizes that customers have a right to expect their personal financial information to remain private and secure. It maintains standards and procedures designed to prevent misuse of this information.

COLLECTION, RETENTION AND USE OF INFORMATION

The bank collects, retains, and uses information about its customers only when it reasonably believes that it is necessary to provide products, services, and opportunities to the customer, as well as in the administration of its business. The bank collects information from applications that it receives from consumers for the bank’s products and services and from other information that the consumers provide to the bank during the application process; it collects information from processing transactions in customer accounts, such as checks and electronic transactions to a deposit account, purchases made on a credit card and loan payments; it collects information about consumers from third parties such as credit bureaus. The information is used for specific business purposes such as the protection and administration of records, accounts, and funds; compliance with laws and regulations; design and improvement of products and services; and understanding customers’ financial needs. CITIZENS BANK MINNESOTA DOES NOT SELL OR RENT CUSTOMER INFORMATION.

LIMITATIONS ON EMPLOYEE ACCESS TO INFORMATION

At Citizens Bank Minnesota, employee access to personally identifiable customer information is limited to those with a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of customer information and on this Privacy Policy. Because of the importance of these issues, all bank employees are responsible for maintaining the confidentiality of customer information, and employees who violate this Privacy Policy will be subject to disciplinary measures.

SECURITY PROCEDURES TO PROTECT CUSTOMER INFORMATION

The bank is committed to the security of customers’ financial and personal information. All of its operational and data processing systems are in a secure environment that protects account information from being accessed by third parties. The bank maintains and grants access to customer information only in accordance with its internal security standards.

RESTRICTIONS ON DISCLOSING INFORMATION TO OUTSIDE PARTIES

Citizens Bank Minnesota does not reveal specific information about your accounts or other information about you to unaffiliated third parties for their independent use, except for the exchange of information with reputable credit reporting agencies or in the performance of bonafide corporate due diligence, unless:

• the information provided is necessary or helpful in completing a transaction initiated by you;
• to verify the existence and condition of your account for a third party, such as a merchant, another financial institution or a credit reporting agency;
• to an account verification service, in addition to a credit reporting agency, if we close your account due to unsatisfactory handling, fraud, attempted fraud or criminal activity;
• to comply with a law, regulation or court order which applies to us or to an affiliate;
• in response to an inquiry about sufficient funds to cover a check you have written;
• when you authorize us to;
• to other companies, financial institutions and networks which may be involved in processing your transactions;
• to local, state and federal authorities, if we believe a crime may have been committed involving your account;
• to paying agencies after the death or incapacity of a recipient or beneficiary of recurring direct deposit payments;
• to our agents and affiliates and other companies to facilitate the delivery of information related to your accounts or other financial services;
• in response to requests by agents of the Bank, or its affiliated companies, such as independent auditors, consultants or attorneys.

Citizens Bank Minnesota may contract with outside vendors and other businesses to perform specific services in support of the Bank’s products.  When it is necessary to provide confidential customer information to a third party, the businesses and vendors selected are expected to adhere to the same privacy standards and applicable laws and regulations as that of the Bank.

DISCLOSING OUR PRIVACY COMMITMENT TO CUSTOMERS

Citizens Bank Minnesota wants its customers to understand its commitment to personal privacy in the use of customer information. Customers who have questions about the bank’s Privacy Policy may contact us at (507)354-3165, 800-549-0194 or Citizens Bank Minnesota, ATTN: Compliance Officer, PO Box 547, New Ulm, MN 56073, or e-mail us at citizensmn.com.

We will reaffirm this policy annually in writing, as long as you maintain an ongoing relationship with Citizens Bank Minnesota. While this policy may change from time to time, you can always review our current policy online at www.citizensmn.com.

The Bank’s Board of Directors has adopted this Policy as of March 6, 2008