Privacy Policy

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DANVERSBANK CONSUMER PRIVACY POLICY

Overview
On November 13, 2000, Privacy of Consumer Financial Information, Regulation P, went into effect with full compliance mandatory by July 1, 2001. Unlike other prior banking regulations, this regulation applies to all types of financial institutions, including banks, thrifts, credit unions, insurance companies, etc. The regulation governs the treatment of nonpublic personal information in the following manner:
     • it requires a financial institution to provide notice to customers about its privacy 
       policies;
     • it describes the conditions under which a financial institution may disclose
       nonpublic personal information about consumers to nonaffiliated third parties;
     • and it provides a method for consumers to prevent a financial institution from 
       disclosing that information to most nonaffiliated third parties by opting out of that
       disclosure, subject to the exceptions in sections 216.13, 216.14, and 216.15.

A major impact is the requirement for all financial institutions to develop initial and annual privacy notices that must be mailed to all existing customers. Regardless of whether or not a financial institution shares nonpublic personal information with third parties, it must provide notice to all its individual customers of the manner in which their information is handled.

In order to comply with this regulation, Danversbank amended its Consumer Privacy Policy to expand on the procedures that were put in place to ensure the integrity of its customers' information. The policy addresses the collection, use and safeguarding of nonpublic personal information and the manner in which customers are notified of our policy. It also addresses the procedures that have been developed to implement the regulation. These would include, training of employees, new account opening procedures, initial and annual mailings of privacy notices, tracking of customers who "opt-out" of information sharing, and a due diligence review of third party vendors and service providers.

The bank has appointed Kevin B. Noyes as the Privacy Coordinator. His duties include the implementation of the bank's Privacy Program, the development of the privacy notice, and the revision of the Consumer Privacy Policy.

Who the Policy Covers. This policy covers individuals who have an ongoing personal (rather than commercial) relationship with the bank. The types of covered relationships are as follows:
     • Deposit account
     • Loan account
     • Safe deposit box
     • Self-directed Individual Retirement Account where we act as custodian or trustee
     • Financial, investment, or economic advisory services (for a fee)

Who the Bank Shares Information With. Under Regulation P, the bank is allowed to share nonpublic personal information with nonaffiliated third party vendors to process and service transactions. These third parties would be used to:
     — Market the bank's own financial products or services
     — Process and service transactions the customer requests or authorizes
     — Protect against potential fraud or unauthorized transactions
     — Respond to judicial process
     — Comply with federal, state, or local legal laws

Information Sharing with Affiliates. The bank may disclose information to Affiliates or other non-affiliated third parties when it believes it is necessary to conduct business, or where disclosure is permitted or required by law. Danversbank currently does not have any Affiliates, but anticipates that it may in the future. The types of Affiliated Companies we may associate with would include financial service providers, such as:
     • Mortgage bankers
     • Securities brokers/dealers
     • Insurance companies
     • Banks

In the event that we do have Affiliates, we may disclose the following information to them:
— Information we receive from customers on applications or other forms, such as 
    their name, address, account balances, types of accounts, deposit history and 
    payment history.
— Information we receive from a consumer reporting agency, such as a customer's 
    credit history or creditworthiness.

Our customers may direct us not to disclose to our affiliates any information listed above that we receive from credit reporting agencies. In order to exercise this right, they would have to complete and sign an "opt out" form provided to them annually and return it to us.

Information Sharing with Joint Marketers. The bank may disclose nonpublic personal information to other financial institutions with which it has joint marketing agreements. Danversbank currently does not have any joint marketing agreements with third parties, but anticipates that it may in the future.

The types of companies we could enter into joint marketing agreements include the following: financial service provider, such as:
     • Mortgage bankers
     • Securities brokers/dealers
     • Insurance companies
     • Banks

In the event that we do enter into joint marketing agreements with third parties, we may disclose the following types of information:
— Information we receive from customers on an application or other form, such as,
    their name, address or social security number.
— Information about customer's transactions with us, or our affiliates, such as,
    account balances, types of accounts, account activity, deposit history or payment
    history.

As stated previously, Federal law allows us to disclose information to companies with whom we have joint marketing agreements. However, we will allow you to opt-out of the disclosure of this information if they so choose. In order to exercise this right, they would have to complete and sign an "opt out" form provided to them annually and return it to us.

Information Sharing with Nonaffiliated Third Parties. Because the bank values its customer relationship, it will not disclose customers' nonpublic personal information to nonaffiliated third parties, except as described in this policy or as otherwise permitted by law.

Safeguarding Customer Information. One of the bank's most important assets is its customer base. In order to preserve and protect that asset, it is necessary for the bank to follow certain procedures. The bank has in place physical, electronic and procedural safeguards that comply with federal standards to guard its customers' nonpublic personal information.

Employee Training. All bank employees have received initial training on the privacy regulation. There will be periodic training sessions incorporated into the Compliance program to ensure that all employees are familiar with the regulation. Danversbank's employee manual includes a section on confidentiality regarding customer information. The section states that any disclosure of the affairs of customers is a serious breach of trust and subject to immediate termination. All employees are aware of this policy.

Account Opening Procedures. All individual customers opening new accounts with the bank will be provided with a copy of the bank's Consumer Privacy Policy at the time the account is opened. This would include all deposit and loan products, safe deposits, and IRA accounts.

Tracking of Customers who Opt-out. If a customer chooses to opt-out of information sharing with affiliates, or joint marketers, they must complete an opt-out form and return it to the bank. This is the only acceptable method for them to instruct the bank of their desire to opt-out. Instructions sent via a written letter, phone call or e-mail are not allowed. Once received, the forms will be kept on file and the customer's account record information on the system will be adjusted to reflect the opt-out option.

Due Diligence of Third Party Vendors. In order to comply with Regulation P, the bank will review all contracts that it has with third party vendors and service providers to ensure that the contracts stipulate that information shared must be protected. In the event that the third party cannot comply with our policy, the bank will seek an alternative provider.

Website and Online-Banking Customers. The bank's privacy policy applies to all individual customers of the bank, including those who do their banking using the on-line banking option. These customers will also be provided with a copy of the bank's privacy policy and the opportunity to opt-out if they so choose. The bank's standard privacy brochure will be posted on the bank's website to allow the online customers to opt out of information sharing.

Joint Marketing. We have explained the kinds of nonpublic personal information we may disclose to other financial institutions with which we may have joint marketing agreements. Federal law allows us to disclose information for that purpose. If you prefer that we do not disclose nonpublic personal information to those with which we have a joint marketing agreement, we will allow you to opt out of those disclosures.

If you have a joint account, an opt out instruction given by one participant of this account will affect all participants of the account.

If you wish to opt out of disclosures, you may do so by checking the applicable box(es) below and returning this form to us at this address:

Danversbank
Attn: Privacy Coordinator
P.O. Box 150
Danvers, MA 01923

 Do not share my nonpublic personal information, other than nonpublic personal information relating to your transactions and experiences with me, with your affiliates in the future.

 Do not share my nonpublic personal information with other financial institutions with whom you have a joint marketing agreement.




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