PRIVACY POLICY DISCLOSURE

At East River Bank, we recognize the sensitive nature of your personal financial information, and take every precaution to protect your privacy.  Because we value your business and continued trust, we firmly believe that it is our obligation to keep your information secure and confidential.  When you entrust us with your financial information, you can be certain that it will be used only within our strict guidelines.

We prepared this brochure to explain what types of information we collect, how we protect and use it, and under what circumstances we may share it.  We hope that you will read through all the details of East River Bank’s official position on privacy. 
At the very least, we want you to know that East River Bank responsibility uses information that we know about you to:

        Provide you with the products and services your have requested.
        Offer you additional bank products and services
       
Under no circumstances do we provide account or personal information to outside companies for the purpose of independent telemarketing or direct mail marketing for nonfinancial service products from those companies. 

CATEGORIES OF NONPUBLIC PERSONAL INFORMATION COLLECTED.

“Nonpublic personal information” is information about you that we obtain in connection with providing a financial product or service to you.  Some examples of nonpublic personal information are information regarding loan balances, payment history, account balances and overdraft history.

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications for our products and services and on other forms you provide to us.
• Information we receive from processing accounts with us and the transaction in those accounts, such as, deposit accounts and loans, as well as, information that we receive from providing services to you, such as funds transfer services.
• Information we receive from a consumer reporting agency (commonly known as a credit bureau) such as your creditworthiness and credit history.
• Information we receive in response to requests we make about you to third parties, like real estate appraisers and employers, or to confirm information that you have provided to us, particularly in the process of evaluation applications for loans.

CONFIDENTIALITY AND SECUTITY OF YOUR NONPUBLIC INFORMATION
We restrict access to your nonpublic personal information to employees who need to know that information to provide products and services to you.  WE maintain physical, electronic and procedural safeguards that comply with federal standards to protect your nonpublic personal information.

CATEGORIES OF NONPUBLIC PERSONAL INFORMATION THE BANK DISCLOSES

We may disclose the following kinds of nonpublic personal information about your, including:

• We may disclose information we receive from you on an application such as your assets, liabilities, income and employment history, for example, in order to verify the accuracy of the information that you have provided us or to determine whether a loan you have applied for it saleable in the secondary market.
• We may disclose information we receive from you on an application, such as, existing loan balances to be paid from our loan proceeds, for example, to persons who are to be involved in the closing of the loan such as attorneys and title companies.
• We may disclose information we receive from processing transactions and services on your accounts with us, such as balance information, to the operator of the interchange that processes our ATM and debit card transactions or in response to a merchant to whom you are giving a check in payment of articles you have purchased.
• We may disclose information about you to governmental entities, in response to subpoenas, or for required annual income statements
   OTHER IMPORTANT INFORMATION

Closing your account with us.  If you decide to close your account(s) of become and inactive customer, we will follow the privacy policies and practices described in this Notice until your nonpublic personal information has been purged from our files.

Contracting with third parties.  We may contract with other entities to perform specific support services, such as, but not limited to, data processing that may require us to provided them access to our customer information,  When doing so, we require such third party service providers to contractually agree to adhere to our security and privacy guidelines.

Notice not a Contract.  These Privacy Disclosures do not create a contract.  From time to time, we may amend or change the terms of this Notice.  In that event, we will provide you with a revised privacy notice and opportunity to exercise your opt out rights.

East River Bank has taken additional steps to ensure the privacy of your nonpublic personal information:

• We maintain security controls to ensure that your personal information contained in our files and computers is protected. Where appropriate, we use technology-based techniques to protect against unauthorized access to personal records, to ensure the accuracy and integrity of communications and transactions, and to keep information we have about you confidential whenever possible.
• We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.