PRIVACY OF CONSUMER FINANCIAL INFORMATION POLICY

(PART 332 of the FDIC Rules and Regulations)

Customer Confidentiality

It is the policy of Kit Carson State Bank that both the financial records of our customers and the relationships between Kit Carson State Bank and our customers be confidential.  No employee shall disclose any nonpublic personal information about a customer to anyone outside the bank except as provided in the following customer Privacy Policy or as it is revised from time to time:

KIT CARSON STATE BANK

PRIVACY POLICY

About Privacy

At Kit Carson State Bank, the basis of each customer relationship is trust.  You have chosen to do business with us, and we are obligated to honor that relationship with great care, beginning with the information you have chosen to share with us.  We believe that your privacy should not be compromised and we are committed to treating customer information responsibly.

We recognize your right to privacy at Kit Carson State Bank.  We recognize that you have a right to expect your personal financial information to remain private and secure.  While information is critical to providing quality service, we recognize that one of our most important assets is our customers’ trust.  Thus, the safekeeping of customer information is a high priority for Kit Carson State Bank.

Use, Collection and Retention of Customer Information

We collect, retain, and use information about you only where we reasonably believe that it will help administer our business or provide products, services, and other opportunities to you.  We collect and retain information about you only for specific business purposes—and we will tell you why we are collecting and retaining it upon your request.  We collect nonpublic personal information about you from the following sources:

• Information we receive from your applications or other forms
• Information about your transactions with us, our affiliates, or others
• Information we receive from a consumer reporting agency

We use information to protect and administer your records, accounts, and funds; to comply with certain laws and regulations; to help us design or improve our products and services; and to understand your financial needs so that we can provide you with quality products and superior service.
 

Maintenance of Accurate Information

We continually strive to maintain complete and accurate information about you and your accounts.  Should you believe that our records contain inaccurate or incomplete information about you, please notify us.  We will investigate your concerns and correct any inaccuracies.

Limitations on Employee Access to Information

At Kit Carson State Bank, 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 these Privacy Principles.  Because of the importance of these issues, all Kit Carson State Bank employees are responsible for maintaining the confidentiality of customer information and employees who violate these Privacy Principles will be subject to disciplinary measures.

Protection of Information via Established Security Procedures

We safeguard information according to established security standards and procedures, and we continually assess new technology for protecting information.  Our employees are trained to understand and comply with these information principles.

Restrictions on the Disclosure of Account Information

It is the bank’s policy not to reveal specific information about your accounts or other personally identifiable data to unaffiliated third parties for their independent use, unless 1) you request or authorize it; 2) the information is provided to help complete a transaction initiated by you; 3) the information is provided to a reputable credit bureau or similar information reporting agency; or 4) the disclosure otherwise is lawfully permitted or required.  We may provide your name, address, or phone number from 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.  

Maintaining Customer Privacy in Business Relationships With Third Parties

If personally identifiable customer information is provided to a third party, Kit Carson State Bank will insist that the third party adhere to similar privacy principles that provide for keeping such information confidential.

Sharing of Former Customer Information

If you decide to close your account(s) with us, we will adhere to the privacy policies and practices as described above.

Providing Privacy Information to Customers and Responding to Inquiries

Kit Carson State Bank recognizes and respects the privacy expectations of our customers.  We want our customers to understand our commitment to privacy in our use of customer information.  As a result of our commitment, we have developed these Privacy Principles which are made readily available to our customers.  Customers who have a question about the privacy of their customer information, have questions about these Privacy Principles, or who would like to request a copy of this Privacy Policy should contact the main bank in Kit Carson at 719-962-3273, the branch in Cheyenne Wells at 719-767-5235 or the branch in Burlington at 719-346-5433. 

Privacy Notices

A Privacy Notice will be provided to all new Kit Carson State Bank customers at account opening that accurately describes this bank’s policies and practices and, thereafter, at least annually during the continuation of the customer relationship.  For the purposes of this policy, annually shall mean at least once in each 12-consecutive month calendar year following the calendar year in which the initial notice was provided.  In order to maintain safe harbor, the Kit Carson State Bank will generally use one of the model privacy forms approved by Federal financial regulatory agencies for compliance with the Gramm Leach Bliley Act when sending the initial, annual, and revised privacy notices.  Other types of notices may continue to be used only as long as they comply with the privacy rules.  To benefit from the safe harbor provisions, no additional information other than what is specifically permitted may be included in the form.  However, the model form may be incorporated into another document as long as it is done in a way that meets all the requirements of the privacy rule and model form instructions.   If a customer agrees to electronic receipt of the notice, the bank may send the form electronically in either PDF or HTML format and may send the notice by email either by attaching the notice or providing a link to the notice.

The bank’s Privacy Notice may be revised, provided Kit Carson State Bank customers are provided with a clear and conspicuous revised notice that accurately describes the bank’s policies and practices.  A revised notice must be provided before the bank may:

• Disclose a new category of nonpublic personal information to any nonaffiliated third party;
• Disclose nonpublic personal information to a new category of nonaffiliated third party; or
• Disclose nonpublic personal information about a former customer to a nonaffiliated third party, if that former customer has not had the opportunity to exercise an opt-out right regarding that disclosure.

A revised notice is not required if the bank discloses nonpublic personal information to a new nonaffiliated third party that was adequately described in the prior notice.

The initial, annual, and revised Privacy Notices must be provided in such a manner that the customer can reasonably be expected to receive the actual notice in writing or, if the customer agrees, electronically.  The annual notice shall no longer be required upon termination of the customer relationship. 

The Board of Directors shall review this policy at least annually, making any such revisions and amendments as it deems appropriate.

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