WE RECOGNIZE THE EXPECTATION OF PRIVACY
We understand that our customers expect us to maintain proper safeguards to protect confidential information that is provided to us. The privacy of customer information is protected not only by state and federal laws, but by our commitment to the protection of financial information. We have established policies and procedures to help prevent misuse of that information. This Policy has been prepared to explain what types of information we collect, how we use that information, and the circumstances under which we may share all or part of the information. Under no circumstances do we provide deposit or loan account personal information to third parties for the purpose of independent telemarketing or direct mail marketing of any non-financial products or services of those companies. We disclose information permitted or required by a variety of federal and state laws, as required to consummate customer transactions, and as directed by the customer. Our strict policies to protect information applies equally to current (active) accounts as well as inactive (closed) accounts both loans and deposits.
WE COLLECT, RETAIN, AND USE INFORMATION ABOUT THE CUSTOMER FOR LEGITIMATE BUSINESS PURPOSES, AS REQUIRED BY LAW OR DIRECTED BY THE CUSTOMER
We collect information about customers and consumers from many sources. Some information is provided to us by the customer such as social security number, income, employment, monthly expenses, and assets. All financial companies need to share customers’ personal information to run their everyday business. Reasons why MCB would share customer personal information:
it is necessary or useful as part of our relationship with the customer
it will help us provide you with products and services meeting your needs or
it is required by law or regulation and federal or state regulatory agencies.
Other information is created by MCB in the course of providing our customers with products and services. Some information comes from our experience of doing business with the customer, such as account usage or payment history. Additional information comes from outside third party sources such as consumer credit reporting agencies and other lenders that have a relationship with MCB customers. Some information is obtained at the customers’ request.
We use the information we collect about our customers to:
Identify new products or services that may help us meet a customer need or that may result in additional savings or convenience to consumers.
Positively identify our customers to protect their accounts and guard against unauthorized access to deposits or loan and deposit account information.
Help us identify and minimize potential risks for loss to Mountain Commerce Bank
We retain customer information as required by federal and state regulation. This includes retaining some information after a loan or deposit account no longer exists. We exercise extreme care in protecting the sharing of this information.
WE PROTECT THE DISCLOSURE AND USE OF ACCOUNT INFORMATION
Mountain Commerce Bank places internal restrictions on the disclosure of customer information. We limit the type of information shared and whom we share it with. We may share information concerning account history, experiences with us, and other data to outside parties, such as another bank or clearing house, to process transactions on your account or loan, verify information that you provide us, to obtain information concerning a particular transaction involving your account, loan or deposit, or to perform any of our obligations to you. However, Mountain Commerce Bank is not a Consumer Reporting Agency. We may disclose information as permitted by any of our agreements with the customer, or as provided in any permission given by the customer to share information. We may also share with third party providers of service or companies in which our bank is acting as a broker or agent certain information that our customer has given us in connection with an application for one of our products or services, or information we have received from a consumer reporting agency or other third party. We do not reveal specific information about your accounts, or other personally identifiable data, to third parties we are not affiliated with for their independent use, unless:
the information is provided to help complete a customer transaction,
you request or authorize it,
the disclosure is made to a financial institution, reputable information reporting agency, merchant or other person in accordance with standard banking industry practice,
the disclosure is required or allowed by law, or
you have been informed about the possibility of disclosure for marketing or similar purposes and been given the opportunity to decline.
We may disclose, as permitted by law, limited client information to companies that perform marketing services on our behalf or to other financial institutions/securities companies with whom we have joint marketing agreements. Although these entities are not owned by us, they work closely with us to help us meet consumer financial needs. We may disclose to these entities information we receive on application forms, such as name, address, phone number, social security number, assets, income and information about transactions with us, or others, such as account balance, payment history, and parties to transactions. We carefully select these business partners and they must agree to strictly safeguard the confidentiality of our client information. They are not allowed to disclose this information to anyone else without our permission.
In addition, sometimes it is necessary for us to disclose confidential customer information to third parties assisting us in the operation of our business, such as vendors and service companies we hire to provide services for us or to provide support for one of our products or services. We require those third parties to agree to safeguard confidential information about you and to observe all applicable laws and regulations about privacy, except to the extent required by federal or state law to the contrary. We may decide to sell a particular part of our business, including the customer loan or deposit data, to someone else; we reserve the right to transfer the customer data in those instances.
WE DISCLOSE INFORMATION WHEN REQUIRED BY LAW OR REGULATION
There are many state and federal laws that require us to disclose information to various government entities. Some examples of these laws are the Bank Secrecy Act, the Internal Revenue Code, Equal Credit Opportunity Act, Flood Disaster protection Act, and the Right to Financial Privacy Act. There are many other laws and regulations that require us, and our contractors and service providers, to disclose information. In addition, if our customer is involved in a legal proceeding, state and federal law provides the parties to the litigation with the right to subpoena and obtain records and information from us. In all these instances, we will disclose the information whenever required to do so by law, regulation, lawful judicial or administrative process, or court order.
As permitted by law, we routinely share customer information with reputable consumer reporting agencies (commonly known as credit bureaus) in accordance with standard banking industry practice and the Fair Credit Reporting Act. We disclose information that is otherwise permitted or required by a variety of federal and state laws, such as a court order or a subpoena for records. We do not disclose or share information about our customers or former customers to anyone, except as permitted or required by law or as directed by you.
We are also selective in determining who we will allow to provide support services for our bank and our customers (for example, the company that imprints checks for our customers).
WE STRIVE TO ENSURE THAT OUR RECORDS ARE UP-TO-DATE AND ACCURATE IN ACCORDANCE WITH COMMERCIAL STANDARDS
We’re proud of our quality service and if the customer finds a mistake, MCB expects the customer to notify us. This includes an error on statements, checks ordered from us, ATM or debit card, or other bank loan payoffs and teller errors. If an error is found we have provided an address or telephone number on the deposit or loan statement. We have procedures in place for maintaining and updating information about our customers. We also have procedures for timely correction of inaccurate information provided to us by the customer or third parties after we become aware of the inaccuracy. We’ll correct the error and credit the account for any charges imposed if the error is ours and they will not be reported to a credit reporting agency or reflected negatively in the customers ‘records.
In addition, various state and federal laws and federal and state regulatory agencies impose specific obligations and standards on us with respect to the collection of information and the accuracy of information we maintain, and the correction of erroneous information.
If we deny an application for a product or service and have used a consumer credit report during the application process, we will give the consumer the name and address of each credit reporting agency that gave us the consumer credit report, even if the report was not used in making our decision. If we deny a credit application for other reasons, we will tell you why or give you an opportunity to request the reasons.
If you are declined for an insurance policy such as credit life insurance and Mountain Commerce Bank is merely an agent for the carrier that actually provides the insurance, we will provide the information you need to contact the carrier that made that decision. The customer has the right to find out from the carrier whether a consumer report was used and/or why the application might have been declined.
WE HAVE POLICIES AND PROCEDURES ADDRESSING EMPLOYEE ACCESS TO INFORMATION ABOUT YOU
We have procedures in place intended to limit employee access to personally identifiable information about our customers. Employee access to this information is limited to our employees who, because of their position or responsibilities, have a business reason to know or have access to such information. We educate our employees about the importance of confidentiality and customer privacy through training. All of our employees are bound by our Code of Ethics, which addresses the importance of confidentiality and customer privacy. We also take appropriate disciplinary actions to enforce employee privacy responsibilities.
WE MAINTAIN STANDARDS AND PROCEDURES INTENDED TO HELP PREVENT UNAUTHORIZED ACCESS TO INFORMATION ABOUT YOU
We have established internal security procedures and safeguards intended to prevent access to your confidential information by unauthorized persons. We periodically upgrade and test our technology and these security procedures and safeguards to enhance protection of your information and to ensure their integrity.