Citizens Bank Family of Companies Privacy Disclosure

From this point forward, the following definitions apply:

We, us and our- Citizens Bank, Tri-Cities Finance Company, Citizens Investment Services, Inc.*, and/or Small Business Resources, Inc.
You, your and yours- any consumer with whom we have a customer relationship
Customer relationship- a continuing relationship between us and the consumer
Consumer- an individual that obtains a product or service primarily for personal, family, or household use, or that person’s legal representative
Nonpublic personal information- personally identifiable financial information or a list of customers derived from using personally identifiable financial information that is not publicly available
Affiliate- any company that controls, is controlled by, or is under common control with another company
Nonaffiliated third party- any person or company that is not an affiliate or employed jointly by us and another company
Opt out- the option of instructing us not to share additional information

OUR COMMITMENT TO PROTECT YOUR PRIVACY

The Directors, management and staff of Citizens Bank and its affiliate companies are concerned about and respect the privacy of our customers’ personal financial information. Since our customers furnish sensitive information to us daily, they expect privacy and security for their personal and financial affairs and we are committed to the responsible handling of customer information. As we explore new technological innovations that will allow us to better serve our customers, we will continue to ensure that privacy and information security standards are upheld.

We believe that by understanding our customers, we are able to create more effective relationships by providing superior service, creating special offers, and designing relevant products based on our customer’s needs. In the process of understanding our customers, we will take the necessary steps to safeguard sensitive information entrusted to us. The following Privacy Disclosure for the Citizens Bank Family of Companies outlines our practice regarding personally identifiable financial information for consumers and customers.

INFORMATION WE COLLECT

We collect and use “nonpublic personal information” from many sources. The term “nonpublic personal information” refers to any information that is not available publicly. Information we collect may include the following:

Information provided to us on applications or other forms such as your name, address, income, assets, debts and other information.
Information about your transactions and account experience with us and our family of companies. This includes information such as your account balance, payment history, and other information.
Information obtained in a consumer report, including information about your credit history or creditworthiness.
Information from other sources such as verifications of your employment, loan balances, insurance coverage or other such information.
Other general information including demographic information.

Accuracy of Information

We constantly strive to maintain complete and accurate information about you and your accounts. Should you ever believe that our records contain inaccurate or incomplete information, please notify us. We will investigate your concerns and correct any inaccuracies.

INFORMATION WE DISCLOSE

Limitations on Information Sharing

In order to protect the privacy of your personal information, we promise to carefully control the ways in which the information is shared. We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as stated in this policy or as allowable or required by law.

Within the Citizens Bank Family of Companies

One of the ways we provide excellent customer service is by keeping customers informed of special offers and services provided by other companies with which we are affiliated. The Citizens Bank Family of Companies includes brokerage and finance companies.

We are permitted by law, under the Fair Credit Reporting Act, to share information concerning our customer’s account history and experiences within the corporate family. You cannot limit the sharing of this information.

We may from time to time disclose other information about our customers or former customers within the Citizens Bank Family of Companies, in order to provide you with the full benefit of available services. This information may include any of the information we collect such as:

Identification information including name, address, and telephone number
Information provided on an application such as income or employment history
Information obtained in a consumer report, including information about your credit history or credit worthiness
In formation from other sources

FAIR CREDIT REPORTING ACT AFFILIATE INFORMATION SHARING OPT-OUT
YOU HAVE THE OPTION OF INSTRUCTING US NOT TO SHARE THE ADDITIONAL INFORMATION LISTED ABOVE WITHIN OUR ORGANIZATION. YOU MAY DO SO BY SENDING A WRITTEN REQUEST INCLUDING YOUR NAME, ADDRESS, AND ACCOUNT NUMBERS TO: CITIZENS BANK CUSTOMER SERVICE; PO BOX 1900; ELIZABETHTON, TN 37644-1900, OR BY CALLING TOLL-FREE AT (866) 882-2265. YOU MAY USE THESE METHODS TO OPT-OUT OF INFORMATION SHARING FOR ANY CITIZENS BANK AFFILIATED COMPANY. AN OPT-OUT REQUEST FROM ONE OWNER OF A JOINT ACCOUNT WILL BE TREATED AS AN OPT-OUT FOR ALL OWNERS OF THE ACCOUNT. YOU MAY EXERCISE YOUR OPT-OUT RIGHT AT ANY TIME. IF YOU HAVE ALREADY OPTED-OUT OF AFFILIATE INFORMATION SHARING, YOU DO NOT NEED TO TAKE FURTHER ACTION.

Additionally, Federal law gives you the right to limit some, but not all, marketing from our affiliates. Federal law also requires us to give you this notice to tell about your choice to limit marketing from our affiliates.

FAIR AND ACCURATE TRANSACTIONS (FACT) ACT AFFILIATE MARKETING OPT-OUT
YOU MAY LIMIT OUR AFFILIATES WITH WHICH YOU DO NOT HAVE A PRE-EXISTING CUSTOMER RELATIONSHIP FROM MARKETING THEIR PRODUCTS AND SERVICES TO YOU BASED ON YOUR PERSONAL INFORMATION THAT WE COLLECT AND SHARE WITH THEM. THIS INFORMATION INCLUDES ALL OF THE INFORMATION LISTED ABOVE INCLUDING YOUR INCOME, ACCOUNT HISTORY WITH US, AND CREDIT SCORE. YOU MAY DO SO BY SENDING A WRITTEN REQUEST INCLUDING YOUR NAME, ADDRESS, AND ACCOUNT NUMBERS TO: CITIZENS BANK CUSTOMER SERVICE; PO BOX 1900; ELIZABETHTON, TN 37644-1900, OR BY CALLING TOLL-FREE AT (866) 882-2265. YOU MAY USE THESE METHODS TO OPT-OUT OF MARKETING FOR ANY CITIZENS BANK AFFILIATED COMPANY. AN OPT-OUT REQUEST FROM ONE OWNER OF A JOINT ACCOUNT WILL BE TREATED AS AN OPT-OUT FOR ALL OWNERS OF THE ACCOUNT. YOU MAY EXERCISE YOUR OPT-OUT RIGHT AT ANY TIME. YOUR DECISION TO OPT-OUT WILL NOT EXPIRE. IF YOU HAVE ALREADY OPTED-OUT OF AFFILIATE MARKETING, YOU DO NOT NEED TO TAKE FURTHER ACTION.

Any medical or health information we receive about a customer (for instance, if a customer applies for insurance as part of a loan or deposit account transaction) will not be disclosed among our family of companies, unless necessary to process transactions, to provide services requested by the customer, or to maintain the accounts.

Service Providers and Joint Marketers

We will not provide your personal information to anyone for the purpose of their independent telemarketing or direct mail marketing of any nonfinancial products or services.

We generally do not share information about our customers with nonaffiliated third parties, other than to conduct our business. However, we may disclose the following information to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements:

Information we receive from you on applications or other forms such as name, address, assets and income
Information about your transactions with us, our affiliates, or other such as account balances and payment history
Information we receive from a consumer reporting agency, such as your creditworthiness and credit history

Although, you will not have the option to opt out of this sharing agreement, anytime we disclose information to a third party marketing firm to tell you about our new products or services, or to a service provider, we will enter into a written agreement with the third party. The agreement will require the third party to maintain the confidentiality of the information in the same manner our bank would and restrict its use.

SAFEGUARDING CUSTOMER INFORMATION

Employee Information Access and Security Standards

We protect consumer privacy by authorizing employee access only to the information necessary to perform the employee’s job responsibilities. Employees are required to maintain the confidentiality of all customer information and are trained to understand that such information is to be used solely for the purpose of providing you with the finest service available. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to protect your nonpublic personal information from unauthorized access, including through the Internet.

POLICY CHANGES

If we change our policy or practice – for example, adding a category of information we will disclose to a third party – we will notify existing customers and give them an appropriate time period to opt out of the disclosure. In any case, we will provide our customers with an annual notice stating our privacy policies and giving them an opportunity to opt out of eligible sharing agreements.

PERMISSABLE INFORMATION SHARING

We are permitted to share your personal information in certain circumstances including:

With companies providing a service for us, such as imprinting checks or data processing
With companies who perform transaction processing for us:

If the transaction, service, or product is requested or authorized by you. For example, if you participate in an online bill payment service we offer and we have entered into an agreement to have another party provide the service.
To maintain or service your account as part of a private label credit card or other loan extension program.
In connection with the sale of a particular business function, such as mortgage servicing rights, or similar transaction related to a consumer

For disclosures that are necessary to enforce our legal or contractual rights or any other person’s rights who is engaged in the financial transaction.
For disclosures required in the ordinary course of business, such as settlement of claims or benefits, providing confirmation of information to the consumer or his agent, and to bill, process or clear items in the normal course of business.
To provide information to insurance rate advisory organizations, guaranty funds, or agencies, agencies that are rating us, persons that are assessing our compliance with industry standards, and our attorneys, accountants and auditors.
To the extent permissible under the Right to Financial Privacy Act.
To a consumer reporting agency under the Fair Credit Reporting Act and Fair and Accurate Credit Transactions Act.
To comply with federal, state, or local laws, rules and other applicable legal requirements.
In order to provide a service expressly requested or authorized by the customer.

The Citizens Bank Family of Companies

This notice is provided with respect to the following affiliated companies:

Citizens Bank
Tri-Cities Finance Company
Citizens Investment Services, Inc.*
Small Business Resources, Inc.

* SECURITIES ARE OFFERED EXCLUSIVELY THROUGH RAYMOND JAMES FINANCIAL SERVICES, INC., MEMBER NASD/SIPC, AN INDEPENDENT BROKER DEALER.

SECURITIES ARE:

NOT FDIC INSURED
NOT GUARANTEED BY THE BANK, AND
MAY LOSE VALUE.

If you have any questions regarding the confidentiality of your information, call one of the telephone numbers listed below and speak with a Customer Service Representative:

Elizabethton (423) 543-2265
Kingsport (423) 245-2265
Bristol (423) 989-4400
Johnson City (423) 952-2265
Toll Free (866) 882-226

ADDITIONAL INFORMATION ABOUT PROTECTING YOUR PERSONAL DATA

Fraudulent emails and websites may appear to be from legitimate companies and may contain their logos or images. Please be aware that Citizens Bank or its affiliated companies will NEVER contact you by email to verify or request personal information. If you receive such a communication, please do not respond. Contact Citizens Bank Customer Service at (866) 882-2265 and report the occurrence immediately.

You may also opt-out of prescreened lists maintained by the three major credit bureaus and limit the number of prescreened solicitations you receive. To do so, contact the National Opt-Out Center at 888-567-8688 or visit www.optoutprescreen.com.

You may opt-out of many telemarketing sales calls by registering your telephone number with the National Do Not Call Registry at www.donotcall.gov or by calling 888-382-1222. Registration is free.

OTHER INFORMATION YOU MAY FIND HELPFUL

Below is the text of a publication of the Federal Trade Commission regarding Deterring, Detecting, and Defending Against Identity Theft. This information may be useful to assist you with protecting your personal data:

Identity theft is a serious crime. It occurs when your personal information is stolen and used without your knowledge to commit fraud or other crimes. Identity theft can cost you time and money. It can destroy your credit and ruin your good name.

Deter identity thieves by safeguarding your information:

Shred financial documents and paperwork with personal information before you discard them.
Protect your Social Security number. Don’t carry your Social Security card in your wallet or write your Social Security number on a check. Give it out only if absolutely necessary or ask to use another identifier.
Don’t give out personal information on the phone, through the mail, or over the Internet unless you know who you are dealing with.
Never click on links sent in unsolicited emails; instead, type in a web address you know. Use firewalls, anti-spyware, and anti-virus software to protect your home computer; keep them up-to-date. Visit www.OnGuardOnline.Gov for more information.
Don’t use an obvious password like your birth date, your mother’s maiden name, or the last four digits of your Social Security number.
Keep your personal information in a secure place at home, especially if you have roommates, employ outside help, or are having work done in your house.

Detect identity theft by routinely monitoring your financial accounts and billing statements.

Be alert to signs that require immediate attention:

Bills that do not arrive as expected.
Unexpected credit cards or account statements.
Denials of credit for no apparent reason.
Calls or letters about purchases you did not make.
Inspect:
Your credit report. Credit reports contain information about you, including what accounts you have and your bill paying history.
- The law requires the major nationwide consumer reporting companies- Equifax, Experian, and TransUnion- to give you a free copy of your credit report each year if you ask for it.
- Visit www.annualcreditreport.com or call 1-877-322-8228, a service created by these three companies, to order your free credit reports each year. You also can write: Annual Credit Report Request Service, PO Box 105281, Atlanta, GA 30348-5281.
- Your financial statements. Review financial accounts and billing statements regularly, looking for changes you did not make.

Defend against ID theft as soon as you suspect it.

Place a “Fraud Alert” on your credit reports, and review the reports carefully. The alert tells creditors to follow certain procedures before they open new accounts in your name or make changes to your existing accounts. The three nationwide consumer reporting companies have toll-free numbers for placing an initial 90-day fraud alert; a call to one company is sufficient:
- Equifax: 1-800-525-6285
- Experian: 1-888-EXPERIAN (397-3742)
- TransUnion: 1-800-680-7289
  Placing a fraud alert entitles you to free copies of your credit reports. Look for inquiries from companies you haven’t contacted, accounts you didn’t open, and debts on your accounts you can’t explain.
Close accounts. Close any accounts that have been tampered with or established fraudulently.
- Call the security or fraud departments of each company where an account was opened or changed without your okay. Follow up in writing, with copies of supporting documents.
- Use the ID Theft Affidavit at www.ftc.gov/idtheft to support your written statement.
- Ask for verification that the disputed account has been closed and the fraudulent debts discharged.
- Keep copies of documents and records of your conversations about the theft.
File a police report. File a report with law enforcement officials to help you with creditors who may want proof of the crime.
Report the theft to the Federal Trade Commission. Your report helps law enforcement officials across the country in their investigations.
- Online: www.ftc.gov/idtheft
- By phone: 1-877-ID-THEFT (438-4338) or TTY: 1-866-653-4261
- By mail: Identity Theft Clearinghouse, Federal Trade Commission, Washington, DC 20580

COMMON WAYS ID THEFT HAPPENS:

Skilled identity thieves use a variety of methods to steal your personal information, including:

Dumpster Diving. They rummage through trash looking for bills or other paper with your personal information on it.
Skimming. They steal credit/debit card numbers by using a special storage device when processing your card.
Phishing. They pretend to be financial institutions or companies and send spam or pop-up messages to get you to reveal your personal information.
Changing Your Address. They divert your billing statements to another location by using a fraudulent “change of address” form.
“Old Fashioned” Stealing. They steal wallets and purses; mail, including bank and credit card statements; pre-approved credit offers; and new checks or tax information. They steal personnel records from their employers, or bribe employees who have access.

To learn more about ID theft and how to deter, detect, and defend against it, visit www.ftc.gov/idtheft. Or request copies of ID theft resources by writing to:
Consumer Response Center
Federal Trade Commission
600 Pennsylvania Ave., NW, H-130
Washington, DC 20580