NOTICE OF YOUR FINANCIAL PRIVACY RIGHTS

We, our, and us, when used in this notice, mean Heritage First Bank.  This is our privacy notice for our customers. When we use the words "you" and "your" we mean the following types of customers:

• Deposit account
• Loan account
• Safe deposit box
• Automobile lease we service
• Retail installment contract we hold and service
• Insurance policies issued by or through us
• Self-directed Individual Retirement Account
• Financial, investment, or economic advisory services
• Mortgage brokerage services
• Brokerage account

We will tell you the sources of the information we collect about you. We will tell you what measures we take to secure that information. We will tell you what information we share about you with other entities. We will explain what your rights are, and how you can exercise them. If you share an account relationship with someone else, such as a joint account holder or co-borrower, we suggest that you share this information with such persons to ensure that each of you is aware of our policy and your options.

We first define some terms.

Nonpublic personal information means information about you that we collect in connection with providing a financial product or service to you. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records. Hereafter, we will use the term "information" to mean nonpublic personal information as defined in this section.

An affiliate is a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control.

A nonaffiliated third party is a person we do not employ or a company that is not an affiliate of ours. This is also known as nonaffiliated third party, or simply, an "other party."

Opt out means a choice you can make to prevent certain sharing of information. We will explain how you can exercise this choice.

THE INFORMATION WE COLLECT

We collect information about you from the following sources:

• Information you give us on applications or other forms
• Information about your transactions with us
• Information about your transactions with our affiliates
• Information about your transactions with other parties
• Information from a consumer reporting agency
• Information we receive through our Customer Identification Program

        THE CONFIDENTIALITY, SECURITY, AND INTEGRITY OF YOUR INFORMATION

We restrict access to information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to protect this information.

 YOUR INFORMATION AND OTHER PARTIES

We will not disclose information about you to anyone except as disclosed in this policy or as permitted by law. Examples of this might include disclosures necessary to service your account or prevent unauthorized transactions.

 INFORMATION ABOUT FORMER CUSTOMERS

We do not disclose information about former customers, except as permitted by law. 

YOUR INFORMATION AND AFFILIATES – FUTURE CHANGES 

In the future, we may disclose information about you to affiliates, even though we are not doing so now. Here are the kinds of information we may disclose to our affiliates:

Transaction and experience information from our account records:
     
Information about your transactions and experience with us, such as:

• Name
• Address
• Account balances
• Account activity
• Types of accounts
• Parties to the transaction
• Credit card usage
• Payment history
• Deposit history

Federal law allows us to disclose the information listed above with our affiliates. However, we will allow you to opt out of the disclosure of this information to our affiliates.

Other information not taken from transactions and experience:

• Information you give us on an application or other forms, such as:
  • Social Security Number
  • Assets
  • Income

• Information we receive from a credit reporting agency, such as:
  • Creditworthiness
  • Credit history

You may opt out of the disclosure of the information listed above.

 Types of Affiliates

We may disclose information about you in the future to the following types of affiliates:

• Financial service providers, such as:
  • Bankers
  • Mortgage bankers
  • Securities broker-dealers
  • Life insurers
  • Private label credit card issuers

Reasons for Disclosure

We may disclose information about you to our affiliates in the future to provide you with information about additional products and services.

YOUR INFORMATION AND OUTSIDE MARKETING SERVICES - FUTURE CHANGES 

In the future, we may disclose information about you to outside marketing services, even though we are not doing so now. Here are the kinds of information we may disclose to these services:

• Information you give us on an application or other forms, such as:
  • Name
  • Address

You may not opt out of the disclosure of this information. 

Types of Outside Marketers

We may disclose information about you in the future to the following types of outside marketers:

• Service providers that perform marketing services for us, such as:
  • Direct mail companies

Reasons for Disclosure

In the future we may disclose information about you to companies that perform marketing services on our behalf to provide you with information about additional products and services. 

YOUR RIGHT TO BLOCK THE DISCLOSURE OF YOUR INFORMATION

 Affiliates. We may disclose your information with our affiliates in the future. If you do not want us to disclose your information with our affiliates, you can block the disclosure of this information. This is known as your right to "opt out."

Your decision to block the disclosure of your information will apply to information collected from all products and services you receive from us.

If you have obtained one or more products or services jointly, each owner or purchaser has a separate right to opt out. If one of you chooses to opt out of the disclosure of your information and any other does not, only information regarding the other parties who do not opt out will be disclosed. However, each joint owner or purchaser may opt out of the sharing of information collected in conjunction with the product or service on behalf of all other joint parties.

If you wish to opt out of the disclosure of your information, please contact us at this address:

Heritage First Bank
Attn: Compliance Officer
1700 Turner McCall Blvd
P.O. Box 5184
Rome, Georgia 30162-5184

(Portions of this notice were prepared by Banker's Systems, Inc.)