Protecting your privacy is important to O’Bannon Banking Company and our employees. We want you to understand what information we collect and how we use it. In order to provide you with a broad range of financial products and services as effectively and conveniently as possible, we collect and retain information about you only when we reasonably believe that the information will assist us in managing your accounts and services and in providing products, services and other opportunities to you. One of the main reasons we collect certain information is to protect your account and to identify you when we conduct transactions with you. The information we collect will also be used to comply with certain laws and regulations that may apply to us and to help us understand your financial needs as we design or improve our products and services. We will also use your information to administer your account and transactions and to provide you with products and services that will best assist you. The following policy serves as a standard for all O’Bannon Banking Company employees for collection, use, retention, and security of nonpublic personal information.

What Information We Collect
We may collect “nonpublic personal information” about you from the following sources:

• Information we receive from you on applications or other loan and account forms;
• Information about your transactions with us or others; and
• Information we receive from third parties such as credit bureaus.

“Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial product or service to you. For example, nonpublic personal information includes information regarding your account balance, payment history, and overdraft history.

What Information We Disclose
We are also permitted by law to disclose nonpublic information about you in certain circumstances to third parties, which are not part of the O’Bannon Banking Company family of companies. We do not sell or share customer information to unrelated third parties for the third parties to use for their own purposes. We do share information with companies that work for us. For example, we may share information with companies that print checks for us, mail customer statements or letters or provide data processing services. These companies are acting on our behalf when they provide these services and are obligated by contract to maintain the information they receive in a confidential manner. They are not authorized to use the information for any other purposes. We also provide information:

When you authorize us to release information;

To credit reporting agencies;

To other parties when it is necessary or helpful in completing a transaction you initiate, including other financial institutions and networks involved in processing your transactions;

• To comply with a law, regulation, court order or subpoena;
• To verify the existence of your account and general information about the condition of your account for a merchant or other financial institution;
• In response to an inquiry about whether a check you have written on an account will clear;
• To local, state and federal authorities if we believe a crime may have been committed involving your account;
• To our independent auditors, consultants or attorneys and to agencies that regulate us.

We may disclose all of the information we collect as described above to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements. Those third parties contractually agree not to use the information for any other purpose.

If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.

Our Security Procedures
We also take steps to safeguard customer information. We restrict access to your personal and account information to those employees who need to know that information to provide products or services to you. Employees who violate these standards will be subject to disciplinary measures. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.