Protecting your privacy is important to Clarkston State Bank and its employees. We want you to understand what information we collect and how we use it. In order to provide our customers with a broad range of financial products and services as effectively and conveniently as possible, we use technology to manage and maintain customer information. The following policy serves as a standard for all Clarkston State Bank employees for collection, use, retention and security of non-public personal information.

Information We Collect
We may collect “nonpublic personal information” about you from the following sources:

• Information we receive from you on applications or other loan and account forms;
• Information about your transactions with us or others who communicate with us; and
• Information we receive from third parties such as credit bureaus.

Information We Disclose
We are permitted under law to disclose nonpublic personal information about you to other third parties under certain circumstances. For example, we may disclose nonpublic personal information about you to third parties who assist us in servicing your loan or deposit account with us, examples of those who assist us includes check printing companies, ATM and Debit Card production companies, Correspondent Banks for check clearing purposes, a check imaging company so we have a permanent record of all checks written or deposited to your account, our data processing service provider and our audit company, to government entities in response to regulatory requirements, subpoenas, and to credit bureaus. The foregoing list was not intended to be all-inclusive, but is merely a sample of the types of service companies with whom we share information to better serve your financial needs. We do not disclose nonpublic personal information about you to anyone, except as permitted by law.

If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice. With regard to closed accounts, we maintain our records on the account for seven years (except loans which are retained for two years), which provides for our compliance with all legal and regulatory reporting requirements.

Our Security Procedures
We also take steps to safeguard customer information. We restrict access to your personal and account information to those employees who need to know that information to provide products or services to you and your family. Employees who violate these standards are subject to disciplinary actions. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard all nonpublic personal information. You can assist in maintaining your privacy by taking steps to guard your private non-public financial information from those that call or ask you for such information at stores, over the Internet or by phone. As partners in the privacy process, we can assure that the safety and security of your private financial information is of the highest concern to us and we appreciate your assistance and confidence.

Children’s Privacy Online
We do not knowingly solicit, collect or use personal information from children under 13. For information concerning the Children’s Online Privacy Protection Act (COPPA), visit the Federal Trade Commission website at www.ftc.gov.