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Scope of Policy
This Policy applies to our relationships with customers who inquire about or obtain products or services from us for personal, family and household purposes.
While this Policy does not apply to business accounts, our commercial customers’ information is also very important to us. We also respect the privacy of our commercial customers, and will also take steps necessary to protect their information.
Strict Security Measures
We will establish procedures to limit employee and director access to information to only those employees and directors with a business reason for accessing such information. We will educate our employees and directors about the importance of confidentiality and customer privacy. We will take appropriate disciplinary measures to enforce employee and director responsibilities regarding customer information.
We collect information about customers to:
- Accurately identify them;
- Protect and administer their records, accounts and funds;
- Help us design or improve our products and services;
- Understand our customers’ financial needs;
- Save our customers time when they apply for new products and services;
- Offer quality products and services; and
- Comply with certain laws and regulations.
Sources of Information
- Applications and other forms that customers provide to us (information such as their name, address, social security number, assets, income and investment objectives);
- Our affiliates on transactions conducted (information and such as account balance, payment history and parties to transaction);
- Outside sources that assist in the origination of products and services like brokers, dealers, educational institutions (such as application information and transaction information);
- Credit reporting agencies and demographic data companies (information such as creditworthiness, credit history and demographic information); and
- Public sources such as federal, state or local records. (Information such as mortgage and other lien information).
We will establish procedures so that the financial information we collect is accurate, current and complete. We will be committed to promptly correct any inaccurate information.
The Selective Sharing of Information
Tower Financial Corporation may share information with our affiliates as well as with unaffiliated third parties external to us in the limited circumstances that this Policy describes.
We may disclose information to complete transactions initiated by a customer when a customer requests or authorizes the disclosure, or if the disclosure is required by law. At times it may become necessary to disclose information to enforce or apply the terms and conditions of an agreement we have with a customer and to protect the rights, property, or safety of the Bank, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Federal law does not allow us to share information about a consumer’s creditworthiness with an affiliate without providing the consumer with the reasonable opportunity to opt-out of sharing that information. Tower has chosen not to share this type of information with any affiliate at this time. Consumers will be afforded the reasonable opportunity to opt-out of the sharing of this information if Tower elects to share this information in the future and this policy changes.
Federal law does not allow us to share information [including transaction or experience] with an affiliate for marketing purposes without providing the consumer with the reasonable opportunity to opt-out of sharing that information. It is Tower’s policy to share information for marketing purposes with an affiliated party only as authorized or requested by the consumer. The referring banker will maintain appropriate documentation of the request or authorization. Consumers will be afforded the reasonable opportunity to opt-out of the sharing of this information if in the future Tower elects to share information with its affiliates for marketing purposes and this policy changes.
Sharing with Carefully Selected Companies
We will disclose information to nonaffiliated third parties with respect to marketing our own products and services, as well as those products or services we offer jointly with other financial institutions. These “marketing partners” include:
- Marketing service providers who market our products and services and products and services of other financial institutions with whom we have joint marketing agreements; and
- Other financial institutions with which we have entered into an agreement to jointly market financial products or services.
We will also disclose information to nonaffiliated third parties as permitted by law. For example, we will provide information to outside companies to perform services on our behalf, such as loan servicing, data analytics, bill payment, account aggregation services, e-mail services, mail house services, printing of account statements; to government entities to respond to subpoenas; and to credit reporting agencies.
Whatever the reason for sharing information, we will require strict confidentiality by the receiving parties and limit the use of the information to the purpose for which it was disclosed.
We will not share information with nonaffiliated third parties to market to our customers.
If a customer ends his or her relationship with Tower Financial Corporation, we will adhere to the information policies and practices described in this Policy.