I.  BACKGROUND

BTC BANK has always valued its customer’s privacy highly.  We recognize that Banking is an industry that is built upon trust.  Our customers entrust us with personal, private, confidential information about themselves and their finances, and they expect that we will keep that information confidential and use it only for the purpose of serving their needs for quality financial products and services.  BTC BANK has a proud tradition of respecting and honoring our customer’s expectations in this area.  It has always been the policy of this bank to obtain only information that is necessary and appropriate to conduct the affairs of the customers and the bank, and to exercise extreme caution and prudence in the handling and release of customer information to third parties.

II.  COLLECTION, USE AND RETENTION OF CUSTOMER INFORMATION

BTC BANK will collect and retain only information about our customers that is needed to appropriately handle customer requests for quality financial products and services, and to carry on other legitimate business purposes of the bank.

III.  ACCURACY OF INFORMATION

BTC BANK strives to maintain complete, current, and accurate information about its customers.  Any inaccurate information that is brought to the attention of the bank will be corrected as quickly as possible after notification.  Procedures will be maintained to ensure that any reported inaccuracies are promptly and effectively handled and that customer information remains as accurate, current and complete as possible.

IV.  INFORMATION SECURITY

Access to personally identifiable customer information shall be limited to employees who have a business reason to obtain such information.  Employees will be trained and educated on the importance of confidentiality and privacy of customer information.  Appropriate disciplinary action will be taken against employees who violate policies or procedures relating to customer information privacy.  Physical, electronic, and procedural safeguards that comply with federal regulations to guard nonpublic personal information will be maintained at all times.

V.  RELEASE OF CUSTOMER INFORMATION TO THIRD PARTIES

BTC BANK will generally only release nonpublic personal customer information to third parties where such release is consented to by the customer, necessary to facilitate or conduct customer transactions to service customer accounts, or is required or permitted by law.  Where appropriate, release of information will be controlled and governed by a contractual agreement between the parties that will include appropriate language regarding the confidentiality and use of information shared between the parties.

Prior to release of nonpublic personal information to a non-affiliated third party other than under the exceptions permitted in 12 CFR 332, 13, 14 or 15, BTC BANK will mail updated disclosures to its customers.  The updated disclosures will describe the nature of the information to be shared, the circumstances and purposes for which it will be shared, and will provide the customer with a means to opt-out of the sharing of such information.  At least 30 days will be allowed to elapse after the delivery of updated Customer Privacy Disclosures to allow for customers to opt out of the sharing of such information.  Information will not be shared on customers who elect to opt out.

VI.  DISCLOSURE OF CUSTOMER PRIVACY POLICIES

Customer Privacy Disclosures will be sent to all BTC BANK customers at least once each calendar year, and prior to the implementation of any significant change in customer privacy policies and practices.  These disclosures will also be given to all new customers of the bank when they become customers, and to others upon request.  Copy of disclosure is attached. 

VII.  APPROVAL

This policy was approved at a meeting of the board of directors of BTC BANK on the 14th day of June, 2001.  All directors, officers and employees will comply with this policy.  This policy is reviewed annually by the board of directors.