Notice of Privacy Rights

Your privacy is our priority.

Your relationship with us is built on trust. We want you to know that we guard your privacy closely and regard that as a primary responsibility of the Bank. The Bank does not rent or sell customer information.

Companies that do work on behalf of the Bank (such as those that do mailings for us) have access only to the information they need to complete the job. We maintain confidentiality agreements with these companies in order to protect your privacy. We want you to feel confident that your information is guarded with the same care with which we protect our own.

Steps You Can Take To Protect Yourself And Your Financial Information

• Never disclose personal information such as social security number, credit card number(s), account number(s) or personal identification number (PIN) to anyone who should not have access to your accounts, especially over the internet or telephone. "PHISHING" is a type of fraud done through the internet and involves a fraudulent email sent to obtain personal information. The email includes a WEB address and logo that appear to be legitimate from a company with which you may or may not have an account. The email often states that account information needs to be updated or your account will be frozen or closed, and provides a link to click on to update the information. That link takes you to a fraudulent web site - you should not click on it. Forward the email to the Federal Trade Commission (FTC) at uce@ftc.gov. This fraud may also be perpetrated over the telephone. Remember, legitimate companies with which you already do business have your information - they DO NOT call or email you asking for personal, non-public information.
• Report lost or stolen checks, credit cards or bank cards immediately.
• Never write your personal identification number (PIN) on a card or carry it in your wallet. Do not choose a PIN that is easily associated with you (such as the last four digits of your phone number or social security number).
• Review your monthly financial statements promptly and report any discrepancies.
• Retain all ATM, debit and credit card receipts. When disposing of them, it is best to shred all receipts.
• Use a cross-cut shredder to destroy documents containing personal information including credit card offers received by mail.
• Sign new bank cards immediately.
• Report unusual telephone inquiries or suspicious activity to your telephone company and local law enforcement.
• If you believe that you have been a victim of fraud involving your Bank accounts, notify us immediately. You should also report the crime to your local law enforcement authorities and to the Federal Trade Commission. You can reach the FTC at 1-877-438-4338 or at www.consumer.gov/idtheft.

The following privacy statement is in language required by law, and includes statements included in every bank’s privacy statement.

DEFINITIONS

We, our, and us refers to Willow Financial Bank.

You and your refers to you, our customer.

Customers are defined as all of our consumer customers who have a continuing relationship with us, such as:

• Deposit account
• Loan account
• Credit card
• Safe deposit box or self service storage box
• Retail installment contract we hold and service
• Self-directed Individual Retirement Account where we act as custodian or trustee
• Financial, investment, or economic advisory services (for a fee)

Non-public personal information means information about you that we collect in connection with providing a financial product or service to you.

Non-public personal information does not include information from a public source, such as a telephone directory or government records.

Affiliate is a company we own or control, or a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us.

Non-affiliated third party is a company that is not an affiliate of ours.

Joint agreement is a written contract pursuant to which we and one or more other financial institutions jointly offer, endorse, or sponsor a financial product or service.

THE INFORMATION THAT WE COLLECT

We collect information about you from the following sources:

• You provide most of it when you request information from us, when you open accounts or apply for loans, in person, through our website or over the phone
• Use of your Willow Financial Bank accounts generates information that we maintain, including account balances, transaction activity and payment histories
• Consumer reporting agencies provide information about your credit history, for example, when you apply for a loan with us
• Public sources of information may be used; for example, we utilize public land records when you apply for a home equity product

Here is how we use that information to benefit you:

To protect you. We use information to confirm your identity when you contact us, safeguarding you against unauthorized access to your account.

The types of financial service providers to which we may disclose non-public personal information are:

• Insurance companies
• Mortgage companies
• Credit card companies
• Investment companies

We may disclose non-public personal information about you to other financial institutions with which we have joint marketing agreements in order to:

• Provide our customers with information about additional products and services
• Provide our customers with financial products or services that they have requested or authorized
• Collect a check or debt

Federal law allows us to disclose the information listed above with companies that perform marketing services on our behalf or with other financial institutions with which we have joint marketing agreements. Your privacy is important to us and we maintain confidentiality agreements with these companies in order to protect your privacy.