Tower Financial Corporation Privacy Policy
Overview
This Privacy Policy sets forth the policies of Tower Financial Corporation with respect to the use, safeguarding and disclosure of nonpublic personal information collected by Tower Financial Corporation, in order to assure compliance by Tower Financial Corporation with federal and applicable state laws and regulations concerning privacy of consumer financial information. The terms used in this Policy but not defined in this Policy will have the meaning ascribed to them in the regulations of the Federal Reserve System at 12 CFR Part 216. We respect the financial privacy of our customers and consumers (customers and consumers hereafter collectively called “customers”). We will comply with laws and regulations designed to secure that privacy, including all federal and applicable state privacy laws and regulations, as well as the Federal Fair Credit Reporting Act to the extent it may apply to our business practices. Each customer’s relationship with us is important, and we want the customer to understand our policies and practices about handling nonpublic personal information. We recognize the customer’s right to privacy and that each customer has the right to expect his or her nonpublic personal information to remain private and secure. We will maintain standards to ensure that each customer’s nonpublic personal information is private and secure at all times.
We want each customer to be aware of this Privacy Policy, which outlines how Tower Financial Corporation safeguards nonpublic personal information.
Scope of Policy
This Policy applies to our relationships with customers who inquire about or obtain products or services from us for personal, family and household purposes.
While this Policy does not apply to business accounts, our commercial customers’ information is also very important to us. We also respect the privacy of our commercial customers, and will also take steps necessary to protect their information.
Strict Security Measures
We will establish procedures to limit employee and director access to information to only those employees and directors with a business reason for accessing such information. We will educate our employees and directors about the importance of confidentiality and customer privacy. We will take appropriate disciplinary measures to enforce employee and director responsibilities regarding customer information.
Collection Information
We collect information about customers to:
- Accurately identify them;
- Protect and administer their records, accounts and funds;
- Help us design or improve our products and services;
- Understand our customers’ financial needs;
- Save our customers time when they apply for new products and services;
- Offer quality products and services; and
- Comply with certain laws and regulations.
Sources of Information
- Applications and other forms that customers provide to us (information such as their name, address, social security number, assets, income and investment objectives);
- Our affiliates on transactions conducted (information and such as account balance, payment history and parties to transaction);
- Outside sources that assist in the origination of products and services like brokers, dealers, educational institutions (such as application information and transaction information);
- Credit reporting agencies and demographic data companies (information such as creditworthiness, credit history and demographic information); and
- Public sources such as federal, state or local records (information such as mortgage and other lien information).
We will establish procedures so that the financial information we collect is accurate, current and complete. We will be committed to promptly correct any inaccurate information.
The Selective Sharing of Information
Tower Financial Corporation may share information with our affiliates as well as with unaffiliated third parties external to us in the limited circumstances that this Policy describes.
We may disclose information to complete transactions initiated by a customer when a customer requests or authorizes the disclosure, or if the disclosure is required by law. At times it may become necessary to disclose information to enforce or apply the terms and conditions of an agreement we have with a customer and to protect the rights, property, or safety of the Bank, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
We may disclose information to our affiliates to evaluate our relationship with our customers to provide the best price and to provide our customers with information about additional products and services. Federal law allows us to disclose information about our customers’ transactions and experience with us to our affiliates. Our customers will be provided the opportunity to opt-out of the disclosure to our affiliates of other information not taken from transactions or experience with us.
Sharing with Carefully Selected Companies
We will disclose information to nonaffiliated third parties with respect to marketing our own products and services, as well as those products or services we offer jointly with other financial institutions. These “marketing partners” include:
- Marketing service providers who market our products and services and products and services of other financial institutions with whom we have joint marketing agreements; and
- Other financial institutions with which we have entered into an agreement to jointly market financial products or services.
We will also disclose information to nonaffiliated third parties as permitted by law. For example, we will provide information to outside companies to perform services on our behalf, such as loan servicing, data analytics, bill payment, account aggregation services, e-mail services, mail house services, printing of account statements; to government entities to respond to subpoenas; and to credit reporting agencies.
Whatever the reason for sharing information, we will require strict confidentiality by the receiving parties and limit the use of the information to the purpose for which it was disclosed.
Former Customers
If a customer ends his or her relationship with Tower Financial Corporation, we will adhere to the information policies and practices described in this Policy.
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