Privacy Policy Keeping Your Information Safe and Secure For Vermont Customers

This brochure is applicable to consumers who reside in Vermont.
We value the trust you have placed in us, and we remain dedicated to those principles today. You can count on us to provide you with the responsive, professional service you deserve, and to protect your privacy and security along the way.

In this brochure you find details about how we use and protect your customer information. We believe that protecting your privacy is an integral part of the customer service we provide to you. This is the reason why we do not share customer information with outside parties who may wish to market their products to you. We value your relationship...and we work diligently every day to honor the trust you place in us.

Highlights Of Our Commitment To You

• We do not sell customer information to third parties.
• We do not share customer information with outside parties who may wish to market their products to you. You do not have to take any action or instruct us to keep your information confidential. We will protect your privacy automatically.
• We safeguard your customer information carefully. We disclose customer information about residents of Vermont only in accordance with the guidelines and exceptions provided by Vermont law. For this reason, there are no "opt-in" or "opt-out" provisions included in this policy.
• We are committed to protecting your customer information in every transaction, at every level of our organization. For this purpose, we have designed procedures, standards and technology, which are described in this brochure.
• We are committed to helping you protect your privacy every day. In this brochure, you'll find tips to help you protect yourself from identity theft, and limit direct marketing from outside companies. Please see inside for more information about our Privacy Policy, and the steps we take to protect your customer information.

• We limit employee access to customer information to those who have a business reason to know this information. Employees are required to honor our code of conduct, which includes standards to protect customer confidentiality. They are subject to disciplinary action if they fail to do so.
• We maintain policies and procedures covering the proper physical security of workplaces and records.
• Our physical, electronic, and procedural safeguards meet or exceed federal standards regarding the protection of customer information.
• We require independent contractors and outside companies who work with us to adhere to strict privacy standards through their contracts with us.
• We use technological means (such as backup files, virus detection and eradication software, firewalls, and other computer software and hardware) to protect against unauthorized access or alterations to customer data.

• Information you provide to us on applications or forms, such as your income and accounts with others;
• Information we receive from an outside company, such as a credit bureau, regarding your credit history or employment status; or
• Information about your transactions or experiences with companies affiliated with us.

• To protect your accounts from unauthorized access or identity theft.
• To process your requests such as loan applications, purchases, and ATM withdrawals.
• To service your accounts by issuing checks, ATM cards, and account statements.
• To keep you informed about financial services of interest to you.

• Companies that perform support services for us, such as data processors, technical systems consultants and programmers, check printers, or companies that help us market our products to you.
• There are other situations when we may disclose to third parties the customer information we collect as permitted or required by law. Third parties could include government entities, courts or other entities (in response to subpoenas and other legal processes), and those with whom you have requested us to share information.

• Our administrative and service units which, for example, service your accounts or prepare your account statements.
• Affiliated companies that provide financial and other services. These include consumer bankers, mortgage lenders, consumer lenders, securities broker-dealers, insurance agencies, and real estate brokerage companies. By law, information that help us identify you or is derived from your transactions and experiences with us may be shared among affiliated companies (a) for purposes other than direct marketing, and (b) unless you instruct us otherwise, for direct marketing purposes. You can instruct us not to share other personal financial information about you with affiliated companies. In addition, if you select that option, we will not share any information about you with our affiliates for direct marketing purposes. Indicate your preference on the "You Have Choices" response form and return it to us at any time. Please note that if you choose not to receive product information by mail or telephone, you may continue to receive marketing information by mail about your accounts. Marketing information may be included in regular account mailings and statements, when you visit us online or at an ATM.

Trust accounts, for which we or our affiliates are the trustee, are protected under special rules of confidentiality, and trust account information is not shared for marketing purposes without specific consent.

Some state laws may impose additional restrictions on disclosure of information about customers in those states for certain purposes.

You Have Choices

We do not sell customer information or share it with outside third parties that may wish to market their products to you. We will protect your privacy automatically.

Within our affiliated companies, we may share information about you as described in section 5. You may notify us of your preference at any time.
[  ] Do not share personal financial information about me other than my own transaction and experience information for any purpose and do not share any information about me for marketing purposes among affiliated companies.

If you are satisfied with the current level of information you receive from us, you do not need to change your solicitation preference at this time. If you choose not to hear from us, you may not be notified about new services with us that may benefit you. You may always change your instructions at any time in the future.

Please do not contact me for marketing purposes by:
[  ] telephone      [  ] mail      

If you have already recorded your privacy preferences with us, there is no need to do so again.

How To Communicate A Preference To Us

• Call us at 1-888-528-8460
• Mail this response form in a stamped envelope to the address listed below. Please do not include other correspondence with your response.

Operations Center
MAC #N9777-111
P.O. Box 5277
Sioux Falls, SD 57117-5277

If you are a online banking customer you may indicate your privacy preference online.

Your preference will apply to all accounts linked to your Social Security Number. For joint accounts, any account holder may express a privacy preference on behalf of the other joint account holders.

Please print.

Name ________________________________________________________________
Address ________________________________________________________________
City ___________ State __________________ Zip ___________
Social Security Number/ Tax Identification Number
________________________________(required to process).

Tips to Help You Protect Your Customer Information
Assistance to Victims of Identity Theft

If you suspect that someone has had unauthorized access to your account with us, or access to your personal identifying information such as your Social Security Number or credit card information, please call us immediately at 1-800-869-3557 so we can take action to protect you. In addition, you should also report the crime to your local law enforcement agency and to the Federal Trade Commission (FTC). To speak with a trained FTC telephone counselor, call toll-free at 1-877-IDTHEFT (1-877-438-4338). Or to enter information about your complaint into a secure FTC online database, sign onto www.ftc.gov/idtheft. The site also provides links to numerous consumer education materials.

Ways to Limit Direct Marketing You May Receive From Outside Sources

There are outside agencies and companies, including national consumer credit reporting agencies, which are in the business of compiling mailing lists for purchase by marketers. You may wish to have your name removed from many of these lists by following the procedures outlined below.

Direct Marketing Association Member Companies

To remove your name from direct mail or telemarketing lists members of the Direct Marketing Association (DMA), send a written request with your name, address, and Social Security Number (if it was included in the mailing you received) to the Direct Marketing Association. The DMA is responsible for notifying its members (i.e., the agencies and companies that compile mailing and telemarketing lists) that you want your name removed from the lists they sell. Your name and address remains in the DMA's consumer exclusion files for five years.
DMA Mail Preference Service P.O. Box 643 Carmel, NY 10512
DMA Telephone Preference Service P.O. Box 1559 Carmel, NY 10512
Or contact the Direct Marketing Association via email at www.dmaconsumers.org.

National Consumer Credit Reporting Agencies (Credit Bureaus)

If you want to reduce the number of credit offers you receive, contact the National Consumer Credit Reporting Agencies at 1-888-567-8688 (1-888-5-OPTOUT). Financial institutions and other companies provide information to the Credit Bureaus for credit verification, fraud control purposes, and prevention of identity theft. You may direct these agencies not to sell or share this information about you for marketing purposes. You must register your own name and address with these organizations because they cannot process any requests from us. Be sure to include any variations of your name, address and other information that have appeared in mailings or telephone calls that you have received. The policies and practices described in this disclosure are subject to change, but we will communicate any significant changes to you as required by applicable law. The policies and practices described in this disclosure replaces all previous notices or statements regarding this subject.