OUR PRIVACY PLEDGE TO YOU

Introduction

At First Southern Bank the basis of each customer relationship, many of which span generations, is trust. You have chosen to do business with First Southern Bank, and we are obligated to honor that relationship with great care, beginning with the 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.

You should refer back to this document from time to time to make sure that you are aware of any changes or modifications that may be made to this policy. If any such changes are made, they will be posted at this website.

Overview

Technology and new marketing practices have increased the amount of customer information collected and shared in today's marketplace. Consumers are concerned about the impact this development has or might have on their privacy and reputation. At First Southern Bank we are sensitive to the importance of these concerns. We want to serve consumers as effectively and conveniently as possible, and such service involves making use of technology and customer information. But we also want our customers to be confident that their relationship with First Southern Bank is treated with appropriate confidentiality. We therefore commit to customers that we will take reasonable steps to protect the privacy of the information shared with us. Our customers are protected not only by state and federal laws but - even more importantly - by First Southern Bank's commitment to them.

Recognition of a Customer's Expectation of Privacy

We recognize your right to privacy at First Southern Bank, thus we recognize that you have a right to expect your personal financial information to remain private and secure. We will maintain standards to ensure that any information that is requested by us is held private and secure at all times. The same standards apply regardless of whether you are a current or former customer of First Southern Bank. All information collected from you will be maintained in the strictest confidence and will be shredded when it is no longer required according to federal and state retention requirements.

Types of Customer Information

Information about you may be accumulated from a variety of sources. For example, we may collect nonpublic personal information about you from:

First Southern Bank applications or other forms that you may fill out;
Your transactional history with us, our affiliates, or others; and
Consumer reporting agencies.

All of these pieces of information will be referred to collectively throughout this policy as "Customer Information."

We will limit the use and collection of Customer Information to the extent which is necessary to administer our business, provide superior service to you, and to offer opportunities that we think will be of interest to you. This also means that we will use the Customer Information to help us identify and mitigate potential risks or loss to First Southern Bank, which ultimately benefits you. Of course, we will use this information only in accordance with the principles set out in this Privacy Policy.

Disclosure of Customer Information

There are times when we are required to disclose your Customer Information, while at other times we may voluntarily provide your Customer Information to carefully screened third parties in order to provide you with the high quality services that you have come to expect from First Southern Bank. In any event, we will always carefully control the way in which any Customer Information is shared.

For example, we must disclose your Customer Information:

If ordered to do so by court order; or
If the Bank Secrecy Act, Internal Revenue Code, Right to Financial Privacy Act, the Welfare Reform Act or various other laws and regulations require us to do so.

On the other hand, we may disclose such information:

To certain financial service providers with which First Southern Bank has an ongoing fiduciary relationship, or to other financial institutions with whom we have joint marketing agreements; or
To companies that participate with First Southern Bank in supplying products and services to customers; or
To companies that promote products and services on our behalf. (Except in unusual situations where, for example, such companies might be governed by federal or state laws to the contrary, these companies are not permitted to use our customer information for purposes other than the provision of the service intended).

Whenever we disclose any Customer Information to such companies, we require that they honor and adhere to our commitment to customer privacy.

Occasionally, First Southern Bank makes a decision to sell a particular line of business (for example, mortgage servicing rights). Usually, an integral part of that business is its customer database, which may contain Customer Information. First Southern Bank reserves the right, in these unusual circumstances, to transfer ownership of such customer databases to the purchaser.

First Southern Bank Employees

Keeping your financial information secure is one of our most important responsibilities. To that end, First Southern Bank employees are informed of their responsibility to protect confidential customer information through bank-sponsored training sessions, and are bound by this Privacy Policy. They are governed by a code of conduct that includes the responsibility to protect the confidentiality of Customer Information.

We also restrict access to your Customer Information to only those employees who need to know such information in order to maintain your account(s), or to provide products or services to you.

Keeping Your Information Secure

We safeguard information according to established security standards and procedures, and we continually assess new technology for protecting information. Our employees are trained to understand and comply with these information safeguard principles.

Accuracy

Equally important, we strive to ensure that the information concerning our customers is accurate. Customers are protected by the Fair Credit Reporting Act, which requires us to notify consumers whenever consumer reports from third parties have been used to solicit business from them. We may use such reports only for the purpose of screening business prospects when a customer or potential customer has authorized a consumer reporting agency to furnish us a report, or when making a customer or potential customer a firm offer of credit, or insurance.

We must also notify an applicant if we decline any application made by him or her, when we have used a consumer report during the processing of the application. If this occurs, even if the report was not the basis for the decision to decline the application, we will:

Provide the applicant with the name and address of the reporting agency;
Tell the applicant why his or her application was declined; and/or
Give the applicant an opportunity to request the reasons for the denial.

Sometimes, as in the case of insurance, we are merely an agent for the carrier that actually provides the product. In such cases, any decision to decline an application for insurance will be made by the carrier, not by First Southern Bank, and the applicant's right to know whether a consumer report was used or why the application might have been declined will apply directly to the carrier, not First Southern Bank. In that situation, First Southern Bank will tell the applicant whom to contact in order to obtain more information.

First Southern Bank employs reasonable measures to ensure the accuracy, timeliness and completeness of our customer information. If we become aware of inaccuracies in our records, we will take prompt steps to make appropriate corrections.

Privacy on the Internet

Customers may have special privacy concerns regarding First Southern Bank's services on the Internet. In particular, customers might be anxious to ensure that their information is secure, that such information is also covered by our Privacy Policy, and that they are aware of and can control First Southern Bank's use of their personal information in the Internet environment.

First Southern Bank is equally concerned about customer privacy in the Internet world and is committed to its protection. For the security measures First Southern Bank applies, please refer to First Southern Bank’s Internet Policy.

Protecting Your Privacy Online

Whenever we ask for personal information on our website, we use Secure Socket Layer ("SSL") technology for transferring data. This technology encrypts - or scrambles - your account information so it's virtually impossible for anyone other than First Southern Bank to read it.

Further, we use state-of-the-art Internet technology, supported by the outside companies we work with, to make online banking secure and to protect your personal information.

You can also help maintain the security of your banking information by not sharing your I.D. or password with anyone, by changing your password regularly, and by remembering to sign off.

Linking From Our Site

On occasion First Southern Bank may provide links on its website to other websites operated by third parties. If you use these links, you will leave First Southern Bank's website, and your browser will be redirected to websites over which First Southern Bank has no control. You should acquaint yourself with these other websites, as they may have privacy policies that differ significantly from First Southern Bank.

Protecting our Children

We do not knowingly solicit data from children, and we do not knowingly market to children. We recognize that protecting children's identities and privacy online is important and that the responsibility to do so rests with both the online industry and with parents.

Count on our Commitment to your Privacy

You can count on us to keep you informed about how we protect your privacy and limit the sharing of information you provide to us - whether it's at a banking center, over the telephone or through the Internet.

If you have any questions regarding this Privacy Policy, or if you would like to obtain a printed version of this policy, please contact our Compliance Officer at (954)633-1643.