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Recognition
of Customers' Expectations of Privacy
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Our
customers' trust is our most important asset. We
understand that a key to maintaining that trust is
meeting our customers' concerns about the privacy
of consumer personal financial information.
Nonpublic personal financial information is
non-publicly available information about customers
who apply for or receive a financial product or
service from us for personal, family or household
purposes. We recognize that our customers are
concerned about the confidentiality and security
of nonpublic personal financial information and
expect us to obtain, keep and use the information
in an appropriate and responsible fashion. Doing
so is a responsibility we take seriously.
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| Obtaining,
Keeping and Using Information |
Obtaining,
keeping and using information is the core of our
business because we must do those things to serve
our customers in their financial relationships
with us. We obtain, keep and use many types of
information, including nonpublic personal
financial information. But, we limit the
obtaining, keeping and use of nonpublic personal
financial information to lawful information we
believe useful in conducting our business,
complying with applicable law, providing quality
service to consumers and offering products,
services and opportunities to consumers.
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| Maintenance
of Accurate Information |
We
recognize that it is important to our customers
that we maintain the accuracy of information
concerning their financial relationships with us.
We have established procedures to maintain the
accuracy of the information in accordance with
reasonable commercial standards. The procedures
include responding in a timely manner to a request
from one of our customers to correct any
information concerning his or her financial
relationships with us that he or she believes
incomplete, not current or otherwise inaccurate
and taking steps to correct the information if we
determine it to be inaccurate.
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| Limiting
Employee Access to Information |
| We
educate our employees on the importance of
maintaining the confidentiality and security of
nonpublic personal financial information. We limit
access by our employees to nonpublic personal
financial information to employees who have a
business reason for knowing the information and
who have been trained in the proper handling of
the information. We have established procedures to
protect against unauthorized access to nonpublic
personal information by our employees.
Under the
procedures, any of our employees who obtain
unauthorized access to nonpublic personal
financial information is subject to appropriate
disciplinary procedures.
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| Protection
Against Unauthorized Access to Information |
We
recognize the importance of providing safeguards
on access to nonpublic personal financial
information. Consequently, we have established
security procedures and physical and electronic
measures to protect against unauthorized access to
nonpublic personal financial information.
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| Restrictions
on Disclosure of Information |
| We
do not disclose nonpublic personal financial
information to a nonaffiliated third party
(including a government agency) except as allowed
by and in accordance with applicable law. Examples
of circumstances in which we may disclose
nonpublic personal financial information of a
consumer to a nonaffiliated third party are: |
- For purposes of
credit reporting, credit verification, risk
management or dispute resolution;
- To complete a
transaction requested or authorized by the
consumer;
- As consented to
by the consumer;
- To protect the
confidentiality or security of records
relating to the consumer, an account of the
consumer or a transaction involving the
consumer;
- To prevent fraud
or an unauthorized transaction;
- To comply with
applicable law in connection with a legal
proceeding or governmental investigation or
examination; and
- As described
below in the section entitled
"Maintaining Customer Privacy in Business
Relationships with Nonaffiliated Third
Parties".
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| Maintaining
Consumer Privacy in Business Relationships with
Nonaffiliated Third Parties |
To
serve consumers in their financial relationships
with us, we occasionally contract with
nonaffiliated third parties (for example, check
printing and data processing companies) to perform
services for us. We disclose nonpublic personal
financial information to those nonaffiliated third
parties only to the extent necessary for them to
perform those services, and we instruct them to
keep and use the information only as we intend it
to be kept and used and to disclose it only as
allowed by and in accordance with applicable law.
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| No
Disclosure of Information for Marketing Purposes |
We
do not disclose any nonpublic personal financial
information with nonaffiliated third parties for
marketing purposes.
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| Disclosure
of Privacy Policy to Consumers |
| This
Privacy Policy is readily available to consumers.
Consumers can call us at 716-937-3381 with any
questions concerning this Privacy Policy.
This Privacy Policy
applies only to individuals as consumers and not
as operators of a business and does not apply to
corporations and other organizations. We reserve
the right to change this Privacy Policy, and any
procedure referred to in this Privacy Policy, at
any time without any notice. This Privacy Policy
is for general guidance and does not constitute a
contract, create any legal right or change any
agreement between us and any of our customers or
anyone else.
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