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FIRST BANK OF DELAWARE PRIVACY POLICIES FOR CUSTOMERS Effective April 10, 2009 PRIVACY POLICIES - YOUR TRUST IS THE CORNERSTONE OF OUR RELATIONSHIP, SO WE WORK DILIGENTLY TO SAFEGUARD YOUR PRIVACY When we refer to “we,” “our,” “us,” or “bank” in these policies, we mean First Bank of Delaware. These policies apply to First Bank of Delaware customer relationships established in the United States. Different policies and procedures may apply to customers outside the United States, depending on the laws of the country governing and your relationship with First Bank of Delaware. We are committed to providing you with the best services while respecting your privacy. Highlights of our commitment to you: We do sell your information to third parties We do share your information with outside parties who may wish to market their products to you We are committed to helping you protect your privacy Within the First Bank of Delaware we carefully safeguard your information. We carefully select the companies that provide services on our behalf or offer you services we do not provide. At every level of our organization we are committed to protecting your information in every on-line transaction. When we use the words “you” and “your,” we mean consumer customers who have a continuing or former relationship created by purchasing or holding financial products or services, such as: Deposit or Loan Accounts; Credit Card or Stored Value Card; Self-directed Individual Retirement Account; Financial investment, or economic advisory services This Privacy Policy describes how we use and protect your information. It is applicable to consumer relationships in the United States and is effective April 10, 2009. We believe that protecting your privacy is an important part of the service we provide to you. We may make changes to this policy at any time and will inform you of changes, as required by law. To receive the most up-to-date Privacy Policy, you can visit our Web site at: http://www.fbdel.com/pgsGen/privacyStatement.asp , or call us at 1-888-FBD-3511. HOW WE PROTECT AND USE CUSTOMER INFORMATION 1. We restrict access to your information through policies, procedures, contracts and technology designed for that purpose. Examples of how we protect your information include, but are not limited to, the following:
2. We collect and maintain information about you as part of your customer relationship with us and to permit us to service your account. In the course of providing services to you, we collect nonpublic personal information about you in connection with providing a financial product or service to you. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or governmental records. In this Privacy Policy we use the term “information” to mean nonpublic personal information we collect from the following sources: Information you provide to us on applications or forms, such as your assets, income and accounts with others. Information we receive from an outside company, such as a credit reporting agency, regarding your credit history or employment status. Information about your transactions or experiences with us, companies affiliated with us, or others. 3. We use the information we collect about you to service your accounts and meet your financial needs The information we collect may be used among First Bank of Delaware’s “affiliated companies” (described in paragraph 4), and authorized non-affiliated third parties (described in paragraph 5) for a number of purposes, including: To protect your accounts from unauthorized access or identity theft. To process your requests such as credit card and debit card applications, loan applications, purchases, and ATM withdrawals. To service your accounts by issuing checks, ATM cards, credit card and debit cards and account statements. To keep you informed about financial services of interest to you. 4. We share information with First Bank of Delaware’s affiliated companies so that we can work together to provide our services to you. We may disclose all of the information we collect, within our “affiliated companies,” a term that means companies we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control. Disclosures to affiliated companies may include: Customer information to our administrative and service units which, for example, service your accounts or prepare your account statements Information that helps us identify you or is derived from your transactions and experiences with us (a) for purposes other than direct marketing, and (b) unless you instruct us otherwise for direct marketing purposes. As discussed below the section entitled “Your Policy Rights and Choices,” you can instruct us not to share other personal financial information about you with First Bank of Delaware affiliates. Your name, address, and facts about your transactions with us (such as payment history and other transactions on your accounts with us) 5. We carefully select the companies that provide services on our behalf, or offer you services that we do not provide. In order to optimize your relationship with us, we may share your information we collect, as described above with nonaffiliated third parties that are acting on our behalf, or as permitted by law, including: Companies that perform support services for us, such as data processors, technical systems consultants and programmers or check printers. Companies including direct marketers that help us market our products and services to you or provide products and services of other companies Companies that, under joint marketing agreements, offer financial products that we do not directly provide, such as mortgage or insurance companies. Companies that conduct surveys or provide marketing research, retailers, membership organizations and publishers. Government entities, courts, or other entities (in response to subpoenas and other legal processes), or those with whom you have requested us to share information. Companies that offer financial products that we do not directly provide such as mortgage or insurance companies. Other non-financial organizations such as non-profit organizations. Important note about Credit Reporting: We may report information about your accounts(s) to credit reporting agencies and/or other consumer reporting agencies. Late payments, missed payments, or other defaults on your account(s) may be reflected in your credit report and/or consumer report As described below the section entitled “Your Privacy Rights and Choices,” you can instruct us not to share certain information about you with nonaffiliated third parties of First Bank of Delaware. YOUR PRIVACY RIGHTS AND CHOICES You may choose to limit (commonly known as “opt-out”) the way we share information about you or the solicitations we send you, except as described in Exceptions to Opt-Out below. You may limit our affiliated companies from marketing their products or services to you based on your information we collect and share with them. This information includes your income, your account history with us, and your credit score. Your choice to opt-out will not affect sharing your information we collect that is described above with: Companies performing marketing or other services for us; Other financial institutions under joint marketing agreements; Government entities in response to subpoenas or regulatory requirements; and Affiliates and unaffiliated persons who perform services for us and to respond to customer inquiries. In addition, we may disclose the information we collect about youto our affiliates and nonaffiliated third parties, to credit reporting agencies and similar organizations and in connection with fraud prevention or investigation and risk management and security. Disclosures may also be made when required or permitted by law. For example, required disclosures may be made to law enforcement and banking regulators while permitted disclosures may be made to vendors assisting us in opening, maintaining or servicing your account. Unless otherwise notified, applicants who do not become our customers may not make certain privacy elections. However, all privacy rights and choices with respect to how we use or disclose information apply to former customers. Attention: Privacy Choice Processing/Operations 50 South 16 th Street, Suite 2400 Or call us toll-free at 1-888-FBD-3511 ---------------------------CUT HERE & RETURN BOTTOM PORTION ONLY-------------- (PLEASE RETAIN PRIVACY NOTICE FOR YOUR RECORDS) YOUR CHOICES (Please State Your Choices Below): Restrict Information Sharing With Companies We Own or Control (Affiliates) Restrict Information Sharing With Other Companies We Do Business With NAME: _______________________________________________________________________
SIGNATURE: ______________________________________________________________________
ACCOUNT(s): ______________________________________________________________________ (Account Numbers to be Provided by Customer)
Special Notice to Vermont and California Customers The information-sharing practices described above are in accordance with federal law. Vermont and California law places additional limits on sharing information about Vermont and California residents, so long as they remain residents of those states. Vermont: In accordance with Vermont law, First Bank of Delaware will not share information we collect about Vermont residents with companies outside of First Bank of Delaware except as permitted by law, such as with the consent of the customer, to service the customer's accounts or to other financial institutions with which we have joint marketing agreements. First Bank of Delaware will not share Application Information, Consumer Report Information and Information from Outside Sources about Vermont residents among the First Bank of Delaware affiliated companies except with the authorization or consent of the Vermont resident. California: In accordance with California law, First Bank of Delaware will not share information we collect about California residents with companies outside of First Bank of Delaware except as permitted by law, such as with the consent of the customer, to service the customer's accounts, or to fulfill on rewards or benefits. We will limit sharing among our companies to the extent required by applicable California law. Special Notice to Nevada Customers: We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by providing us with a written request sent to the following address: First Bank of Delaware Attention: Do Not Call List Two Liberty Place 50 South 16 th Street, Suite 2400 Philadelphia, PA 19102 Or calling us toll-free at 1-888-FBD-3511 In addition to our address and contact information we provide above, Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number- 702.486.3132; e-mail: BCPINFO@ag.state.nv.us.
This policy is effective as of April 10, 2009. 1. Are you a visitor? If you do not bank online with First Bank of Delaware, we do not collect, capture, or retain personally identifiable information when you are just browsing. By offering you this level of privacy during your browsing experience, we believe you will be more likely to find the products and services that fulfill your financial needs and goals. 2. Are you a registered user? When you register for an online service, our website will request information, such as your email address or your account number. This information allows you to perform certain tasks (for example, correspond with us or review your accounts) and it allows us to provide the information you requested. In these cases, we collect only the information necessary to interact with you. We also gather data to track website usage, such as number of hits, pages visited, and the length of user sessions in order to evaluate the usefulness of our sites. 3. About cookies Cookies are pieces of data assigned by a web server to the browser on your computer. Cookies help websites to keep track of your preferences and to recognize return visitors. So, when you return to a website you've visited before, your browser gives this data back to the server. Contrary to reports about cookies, cookies do not contain viruses. We do not embed your Social Security number, account number(s) or password in our cookies.
4. We work to ensure privacy and security during your online sessions The information you provide to us online is protected by Secure Socket Layer (SSL) technology. SSL is the leading security protocol for data transfer on the internet. This technology scrambles your account information as it moves between your computer’s browser and First Bank of Delaware's computer systems. When information is scrambled, or encrypted in this way, it becomes nearly impossible for anyone other than First Bank of Delaware to read it. This secure session helps protect the safety and confidentiality of your information when you bank with us online. 5. Protecting children's privacy online From our websites, we do not knowingly collect or use personal information from children under 13 without obtaining verifiable consent from their parents. We are not responsible for the data collection and use practices of nonaffiliated third parties to which our websites may link. E-mail can be used for sending scams such as a false offer from a company or an alert to a false computer virus in an effort to move you to a false website. These e-mails are often forwarded with good intention by friends, adding an erroneous level of legitimacy. E-mails such as these are most likely from criminals who send thousands of emails at a time to random addresses. When you visit a phony website, identity criminals will try to steal your personal information such as online IDs and passwords, or Social Security numbers and account numbers. This practice is known as "spoofing" or “Phishing.” If you receive an e-mail that you think could be a scam, do not forward it and delete it immediately. If you receive an e-mail warning that a new computer virus is circulating, check the Web site of any one of the well-known anti-virus software companies for validation. We will never initiate a request for sensitive information from you via email (i.e., Social Security Number, Personal ID, Password, PIN or account number). If you receive an e-mail that requests this type of sensitive information, you should be suspicious of it. To report a suspicious email that uses First Bank of Delaware's name, you can contact us at the following address: First Bank of Delaware Two Liberty Place 50 South 16 th Street, Suite 2400 Philadelphia, PA 19102 Or calling us toll-free at 1-888-FBD-3511 7. Links to non-First Bank of Delaware sites We are not responsible for the information collection practices of the non-First Bank of Delaware links you click to from our web pages. We cannot guarantee how these third parties use cookies or whether they place on your computer cookies that may identify you personally. We urge you to review the privacy policies of each of the linked websites you visit — before you provide them with any personally identifiable information 8. Policy changes If we make changes to the Online Privacy Policy or make any material changes to our online services, we will revise the Online Privacy Policy to reflect such changes and revise the policy's effective date. PROTECTION OF SOCIAL SECURITY NUMBERS
Tips to Help You Protect Your Customer Information and Assistance to Victims of Identity Theft If you believe you may be a victim of identity theft, please follow the following procedures:
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