PRIVACY POLICY

The expectation of our customers that we hold their privacy and security in the highest regard is a matter of great importance to us. We are concerned about and respect the privacy of our customers’ personal financial information. Our customers furnish sensitive information to the bank in the ordinary course of doing business with us. We recognize the importance of protecting the privacy of personally identifiable information and we are committed to treating such information responsibly.

The following privacy policy and disclosures outline the Bank’s practices regarding personally identifiable financial information for customers.

Confidentiality and Security
Protecting customer information is a significant responsibility for us. Access to customer information is limited to those persons who need to know that information. As an example, we permit employee access to information to resolve questions or inquiries, for the purposes of providing fraud control and internal security, to enable us to provide products and services and to protect and to enforce our rights.

We maintain physical, electronic and procedural safeguards that enable us to comply with federal and state regulatory standards relative to safeguarding customer information.

All employees have a copy of this policy and are trained at least annually regarding the safeguarding of customer information. The Financial Privacy Officer, the Human Resources Director and the appropriate department manager will take disciplinary action against any employee who violates the bank’s privacy policy and procedures.

Customer Information We Collect
We collect nonpublic, personal information about you from several sources, including the following:

• Information we receive from you on applications, forms or other means such as your name, address, telephone number, taxpayer identification number, assets and income or other information.
   
• Information about your transactions with our affiliates, others, or us such as your account balance, payment history and parties to transactions.
   
• Information we receive from a consumer reporting agency, such as information relating to your creditworthiness and credit history.

Our Policy about Disclosing Customer Information
The Bank does not now, nor does it intend in the future to disclose any personal information to any nonaffiliated third party, except as permitted by law.

In order to improve service to our customers, we may share information about current or former customers within our family of affiliated businesses. By sharing this information we can promote efficiencies and reduce costs to our customers. The types of information that we may share among our affiliates include the following:

• Identification information, such as name, address and telephone number
• Transactional information
• Deposit or loan experience
• Information we receive from you on applications and other forms
• Information we receive from a consumer reporting agency

Examples of the types of businesses we are or may become affiliated with are listed below:

• Mortgage banking companies, including Ridgefield Bank Mortgage Corporation
• Insurance companies, including Carnall Insurance, Inc.
• Brokerage companies
• Finance companies

You can prevent the Bank from sharing information with its affiliates. In order to do so, you must mail a written request, with your name, address, taxpayer identification number and account number to the Financial Privacy Officer, Fairfield County Bank, P.O. Box 2050, 150 Danbury Road, Ridgefield, CT 06877 or call us at 203-431-7431 or toll-free at 1-877- 431-7431. We will honor your choice on restricting information.

Exception for Joint Marketing and Service Providers
In the normal course of business, we may disclose all of the customer information that we collect as previously described, on customers and former customers, to companies that perform marketing services for us or to other financial institutions with whom we have joint marketing arrangements. Examples of these companies are:

• Financial institutions with whom we have joint marketing arrangements, such as insurance companies, mutual fund companies, credit card companies and others.
   
• Companies that provide marketing services for us, such as bulk mailing companies, direct marketing companies, market research firms and marketing consultants.
   
• In these cases the Bank will enter into an agreement with the third party that will require the third party to maintain confidentiality of the information in the same manner the Bank would and to restrict its use.
   
• The Bank will not provide your personal information to non-financial companies for the purpose of their independent telemarketing or direct mail marketing of any non-financial products or services.
   
• We may provide information to companies that perform services for us in connection with your accounts, such as data processing and software companies and collection agencies.

Other Exceptions
Other examples of when we disclose customer information outside of our family of affiliated businesses:

• To consumer reporting agencies.
   
• For fraud, security or risk control.
   
• To help complete a transaction that you initiate, including information requested to verify the existence or condition of an account.
   
• To resolve disputes or inquiries you may have about your accounts.
   
• When you consent or direct us to provide information about your accounts. This may be oral, in writing, by telephone, electronic or other means as we recognize.
   
• When disclosure is required by law, such as pursuant to court order, subpoena, legal process or government agency examination or investigation, or to protect or enforce our rights.
   
• As otherwise necessary to service your account, or as permitted or required by law.

Policy and Practice Changes
If we change our policy or practice by, for example, adding a category of information that we will disclose to a third party, we will notify existing customers and give them an appropriate time period to opt out of the disclosure. We do not and will not share information about former customers, therefore, notification of policy or practice changes to former customers is not necessary.

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