FINANCIAL PRIVACY
“We”, “our” and “us” all refer to Cumberland Bank & Trust. “You” and ‘your” refers to consumer customers who have an established relationship with us.
At Cumberland Bank & Trust, the basis of each customer relationship is trust. You have chosen to do business with Cumberland Bank & Trust, and we are obligated to honor that relationship with great care, beginning with information you have chosen to share with us. We believe that your privacy should not be compromised. At the same time, we want to offer you the array of financial products and services you need to accomplish your financial goals. We believe we can do both through the privacy policy outlined below.
CUSTOMERS
A customer is an individual who has established a continuing relationship with us under which we provide financial products or services to the consumer for personal, family or household purposes.
Customers include individuals who:
- Have a deposit with us
- Obtain a loan from us
- Have a loan for which we own the servicing rights; or
- Have a sale deposit box with us
A continuing relationship does not exist and you are not our customer if you obtain financial products or services only in isolated transactions, such as:
- Using our ATM to withdraw cash from an account at another financial institution:
- Purchasing a cashier check or traveler’s checks; or
- We sell your loan and do not retain the servicing rights.
NONPUBLIC PERSONAL INFORMATION
We collect nonpublic personal information about you from the following sources;
- Information we receive from you on applications or other forms;
- Information about your transactions with us, our affiliates, or others; and
- Information we receive from a consumer reporting agency.
Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records.
RECOGNITION OF YOUR EXPECTATION OF PRIVACY
We recognize your right to privacy of Cumberland Bank & Trust, and that you have a right to expect your personal financial information to remain private and secure. We believe the confidentiality and protection of customer information is one of our fundamental responsibilities. Thus, we will maintain standards to ensure your information is private and secure at all times.
RESTRICTIONS ON THE DISCLOSURE OF ACCOUNT INFORMATION
We do not reveal specific information about your accounts or other personally identifiable data to parties outside our organization unless it is under the following circumstances:
- You request or authorize disclosure;
- Information is provided to help complete a transaction initiated by you;
- Information is provided to a reputable credit bureau of similar information
reporting agency; or
- Disclosure is otherwise lawfully permitted or required.
LIMITATIONS ON ACCESS TO YOUR INFORMATION
We restrict access to nonpublic information about you except to those employees who have a specific business reason to know such information. Our employees are educated and trained on the importance of confidentiality and privacy of customer information. We take appropriate disciplinary action if employees fail to adhere to this policy or procedures relating to this policy. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.
SHARING OF INFORMATION WITH NON-AFFILIATED THIRD PARTIES
It is sometimes necessary to provide personally identifiable information about you to a party outside our organization. Some examples are when we hire a vendor or service company to prepare your account statements or to provide support for one or more of our products or services. When we work with outside businesses or companies, these vendors agree to safeguard your personal data and confidential information, and these vendors must abide by applicable law. We maintain procedures designed to protect your information. Other than under the limited exceptions explained in the paragraph above, it is our policy not to share confidential customer information outside our organization. You do not need to request this confidentiality, it is our standard practice.
MAINTENANCE OF ACCURATE INFORMATION
Maintaining the accuracy of your personal information is important. We have procedures to help assure that your personal information is accurate,
current and complete. We also have procedures to correct inaccurate information in a timely manner, including processes to update information or
remove outdated information. If you discover any information we have about you is incorrect, please let us know.
TIPS TO HELP YOU PROTECT YOUR CUSTOMER INFORMATION
If you suspect that someone has had unauthorized access to your account with us, or access to your personal identifying information such as your social security number or credit card information, please notify Cumberland Bank & Trust immediately so we can take action to protect you.
CONSUMER CREDIT REPORTING AGENCIES (CREDIT BUREAUS)
In accordance with the Fair Credit Reporting Act, we may share identifying information and information about your transaction and experiences within Cumberland Bank & Trust. You may direct these agencies not to sell or share this information about you for marketing purposes, but we cannot make that request on your behalf.
“We”, “our” and “us” all refer to Cumberland Bank & Trust. “You” and ‘your” refers to consumer customers who have an established relationship with us.
At Cumberland Bank & Trust, the basis of each customer relationship is trust. You have chosen to do business with Cumberland Bank & Trust, and we are obligated to honor that relationship with great care, beginning with information you have chosen to share with us. We believe that your privacy should not be compromised. At the same time, we want to offer you the array of financial products and services you need to accomplish your financial goals. We believe we can do both through the privacy policy outlined below.
CUSTOMERS
A customer is an individual who has established a continuing relationship with us under which we provide financial products or services to the consumer for personal, family or household purposes.
Customers include individuals who:
- Have a deposit with us
- Obtain a loan from us
- Have a loan for which we own the servicing rights; or
- Have a sale deposit box with us
A continuing relationship does not exist and you are not our customer if you obtain financial products or services only in isolated transactions, such as:
- Using our ATM to withdraw cash from an account at another financial institution:
- Purchasing a cashier check or traveler’s checks; or
- We sell your loan and do not retain the servicing rights.
NONPUBLIC PERSONAL INFORMATION
We collect nonpublic personal information about you from the following sources;
- Information we receive from you on applications or other forms;
- Information about your transactions with us, our affiliates, or others; and
- Information we receive from a consumer reporting agency.
Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records.
RECOGNITION OF YOUR EXPECTATION OF PRIVACY
We recognize your right to privacy of Cumberland Bank & Trust, and that you have a right to expect your personal financial information to remain private and secure. We believe the confidentiality and protection of customer information is one of our fundamental responsibilities. Thus, we will maintain standards to ensure your information is private and secure at all times.
RESTRICTIONS ON THE DISCLOSURE OF ACCOUNT INFORMATION
We do not reveal specific information about your accounts or other personally identifiable data to parties outside our organization unless it is under the following circumstances:
- You request or authorize disclosure;
- Information is provided to help complete a transaction initiated by you;
- Information is provided to a reputable credit bureau of similar information
reporting agency; or - Disclosure is otherwise lawfully permitted or required.
LIMITATIONS ON ACCESS TO YOUR INFORMATION
We restrict access to nonpublic information about you except to those employees who have a specific business reason to know such information. Our employees are educated and trained on the importance of confidentiality and privacy of customer information. We take appropriate disciplinary action if employees fail to adhere to this policy or procedures relating to this policy. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.
SHARING OF INFORMATION WITH NON-AFFILIATED THIRD PARTIES
It is sometimes necessary to provide personally identifiable information about you to a party outside our organization. Some examples are when we hire a vendor or service company to prepare your account statements or to provide support for one or more of our products or services. When we work with outside businesses or companies, these vendors agree to safeguard your personal data and confidential information, and these vendors must abide by applicable law. We maintain procedures designed to protect your information. Other than under the limited exceptions explained in the paragraph above, it is our policy not to share confidential customer information outside our organization. You do not need to request this confidentiality, it is our standard practice.
MAINTENANCE OF ACCURATE INFORMATION
Maintaining the accuracy of your personal information is important. We have procedures to help assure that your personal information is accurate,
current and complete. We also have procedures to correct inaccurate information in a timely manner, including processes to update information or
remove outdated information. If you discover any information we have about you is incorrect, please let us know.
TIPS TO HELP YOU PROTECT YOUR CUSTOMER INFORMATION
If you suspect that someone has had unauthorized access to your account with us, or access to your personal identifying information such as your social security number or credit card information, please notify Cumberland Bank & Trust immediately so we can take action to protect you.
CONSUMER CREDIT REPORTING AGENCIES (CREDIT BUREAUS)
In accordance with the Fair Credit Reporting Act, we may share identifying information and information about your transaction and experiences within Cumberland Bank & Trust. You may direct these agencies not to sell or share this information about you for marketing purposes, but we cannot make that request on your behalf.
