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Privacy Policy

PRIVACY POLICY
Commercial Bank of Mott

Commercial Bank of Mott has implemented this privacy policy because a fundamental component of the bank/customer relationship is a customer’s trust in this institution and because we respect the expectations of our customers regarding privacy and confidentiality. Protecting our customers’ privacy, along with their financial assets, is at the core of our business. Our customers have chosen to do business with us, and we recognize our obligation to limit access to the information they provide us.

We recognize that our customers expect privacy and security for their personal and financial affairs. We understand the need to safeguard sensitive information about our customers that they have entrusted to us within our bank and affiliates. We maintain standards and procedures designed to prevent misuse of this information.

What Information We Collect
We collect, retain and use information about our customers only when we reasonably believe it will help administer our business or provide products, services and other opportunities to them. We collect and retain information only for specific business purposes and we will tell our customers why we are collecting and retaining it upon their request. We use information to protect and administer our customer’s records, accounts, and funds; to comply with certain laws and regulations; to help us design or improve our products and services; and to understand our customers’ financial needs so that we can provide them with quality products and exceptional customer service.

We may collect “nonpublic personal information” about our customers from the following sources:
  • Information we receive from them on applications or other forms;
  • Information about their transactions with us, our affiliates or others; and
  • Information we receive from a third party, such as a consumer reporting agency.
For the purpose of this policy, “nonpublic personal information” is nonpublic information about our customers that we obtain in connection with providing a financial product or service to them. For example, nonpublic personal information includes:
  • Information a consumer provides to us on an application to obtain a loan, credit card, or other financial product or service;
  • Account balance information, payment history, overdraft history, and credit or debt card purchase information;
  • The fact that an individual is or has been one of our customers or has obtained a financial product or service from us;
  • Any information about our consumer if it is disclosed in a manner that indicates that the individual is or has been our customer;
  • Any information that a consumer provides to us or that we or our agent otherwise obtains in connection with collecting on a loan or servicing a loan;
  • Any information we collect through an Internet “cookie” (an information collecting device from a web server); and
  • Information from a consumer report.
We collect this information to:
  • Establish and administer our customers accounts. (For example, we ask for personally identifying information to protect their accounts from fraud.)
  • To satisfy certain regulatory requirements. (For example, when they open an account, we are required by the Internal Revenue Service to obtain their social security number.)
  • To better understand them so that we may provide them with additional or improved products and services.
What Information We Disclose
We do not disclose nonpublic personal information about our customers to nonaffiliated third parties except as permitted by law. Accordingly, we do not reveal specific information about our customers’ accounts or other personally identifiable data to parties outside our bank. We will only disclose information to third parties about their credit, accounts, and transactions under any one of the following conditions:
  1. The customer requests or authorizes it;
  2. The information is provided to help complete a transaction initiated by the customer;
  3. The information is provided to a reputable credit bureau or similar information reporting agency; or
  4. The disclosure is otherwise lawfully permitted or required.
We may disclose the following information to our affiliated companies:
  1. Information we receive from our customers on applications or other forms such as their name, address, social security number, assets and income; and
  2. Information we receive from a consumer reporting agency, such as their credit worthiness and credit history.
For the purpose of this policy, an affiliated company is defined as any company that is related or affiliated by common ownership, or affiliated by corporate control or common corporate control, with another company. Accordingly, for the purpose of this policy, Commercial Bank of Mott and Commercial Insurance Agency are considered affiliated financial service providers.

If our customers prefer that we do not disclose such nonpublic personal information to our affiliated companies, they may opt out of those disclosures. This means they may direct us not to make those disclosures (other than disclosures permitted by law, which include account balance and transaction history). If our customers wish to opt out of disclosures to affiliated companies, they may call us collect.

Our Maintenance of Accurate Information
We have procedures to help assure that our customers’ financial information is accurate, current and complete in accordance with commercial standards. We also have procedures to respond to customers’ requests to correct inaccurate information in a timely manner. Customers should be informed that if they ever find that their account information is incomplete, inaccurate or not current, they can call us or write to us and we will correct any erroneous information in a timely manner.

Limiting Employee Access to Information
We also take steps to safeguard our customers’ information. Accordingly, employees’ access to personal and account information is restricted to their need to know such information for business reasons. All employees are trained to respect customer privacy, and those who violate our Privacy Pledge will be subject to discipline.

Security Procedures to Protect Information
We maintain security standards and procedures to help prevent unauthorized access to confidential information about our customers. We update and test our technology to improve protection of our information about them and to assure the integrity of our information.

Maintaining Our Customers Privacy in Business Relationships with Third Parties
We follow strict privacy procedures in regard to protection of customer information. Except as otherwise stated in this policy, we will not sell or share customer information with third parties. If we use a third party business partner, service company, or other business partner to prepare account documentation, service accounts, or for other purposes, we will make reasonable efforts to verify the business partners agree to safeguard our confidential information about our customers and their products and services with us and must abide by applicable law.

Disclosing Our Privacy Commitment to Our Customers
We want our customers to understand our commitment to personal privacy and our use of information. Accordingly, we will provide a clear and conspicuous notice that accurately reflects our privacy policy and practices to any individual who becomes our customer. This notice will be provided to the customer no later than when the relationship is established. In addition, we will provide an annual notice of our privacy policy and practices to our customers.

We will periodically review the methods available for communicating our privacy policy and determine whether current practices are meeting the needs of the Bank and our customers.

This Privacy Policy applies to individuals, and we reserve the right to change the policy, along with related provisions, at any time.