Securities and Exchange Commission
Form S-P
A. Model Privacy Form
F A C T S WHAT DOES [name of financial institution] DO WITH YOUR PERSONAL INFORMATION?
Why?
What?
How?
Financial companies choose how they share your personal information. Federal law gives
consumers the right to limit some but not all sharing. Federal law also requires us to tell
you how we collect, share, and protect your personal information. Please read this notice
carefully to understand what we do.
The types of personal information we collect and share depend on the product or service
you have with us. This information can include:
* Social Security number and income
* account balances and transaction history
* assets and investment experience, credit history, and credit scores
* bank account information if you sign up for certain account options we offer
When you close your account, we continue to share information about you according
to our policies.
All financial companies need to share customers' personal information to run their
everyday business - to process transactions and maintain customer accounts, and report
to credit bureaus. In the section below, we list the reasons financial companies can share
their customers' personal information; the reasons [name of financial institution]
chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information Does [name of financial institution] share? Can you limit this sharing?
For our everyday business purposes-
to process your transactions, maintain your account,
and report to credit bureaus, and protect against or
prevent fraud or unauthorized transactions, or comply
with federal, state, or local laws or other applicable legal
requirements. This sharing may be with non-affiliates.
For our marketing purposes-
to offer our products and services to you
For joint marketing with other financial companies
For our affiliates' everyday business purposes-
information about your transactions and experiences
For our affiliates' everyday business purposes-
information about your creditworthiness
For our affiliates to market to you
For nonaffiliates to market to you
Contact Us Call [toll-free telephone] or go to [web address]
p. 1 of 3
F A C T S WHAT DOES [name of financial institution] DO WITH YOUR PERSONAL INFORMATION?
Sharing practices
How often does [name of financial
institution] notify me about their practices?
We must notify you about our sharing practices when you open an account,
when we make a material change to our sharing practices, and each year while
you are a customer.
How does [name of financial institution]
protect my personal information?
To protect your personal information from unauthorized access and use, we
use security measures that comply with federal law. These measures may
include computer safeguards and secured files and buildings.
We collect your personal information, for example, when you
* open an account or deposit money
* buy or sell securities, pay your bills, or apply for a loan
* use your credit card or debit card
We may also collect your personal information from others, such as credit
bureaus, affiliates, or other companies.
How does [name of financial institution]
collect my personal information?
Why can't I limit all sharing? Federal law gives you the right to limit sharing only for
* affiliates' everyday business purposes - information about your
creditworthiness
* affiliates to market to you or nonaffiliates for marketing purposes
* nonaffiliates to market to you
* nonaffiliates unless the sharing is (1) related to processing and servicing your
transactions, (2) for specified purposes authorized by law; or (3) with our
service provider(s) for our joint marketing arrangements.
State laws and individual companies may give you additional rights to limit
sharing.
Definitions
Everyday business purposes The actions necessary by financial companies to run their business and
manage customer accounts, such as
* processing transactions, mailing and auditing services
* providing information to credit bureaus
* responding to court orders and legal investigations
* protecting against or preventing fraud or unauthorized transactions
* complying with federal, state, or local laws or other applicable legal
requirements including court orders and legal investigations
Affiliates Companies related by common ownership or control. They can be financial and
nonfinancial companies.
* [affiliate information]
Nonaffiliates Companies not related by common ownership or control. They can be financial
and nonfinancial companies.
* [nonaffiliate information]
Joint marketing A formal agreement between nonaffiliated financial companies that together
market financial products or services to you.
* [joint marketing]
p. 2 of 3
F A C T S
WHAT DOES [name of financial institution] DO WITH
YOUR PERSONAL INFORMATION?
If you want to limit our sharing
By telephone: [toll-free telephone] - our menu will prompt you through your choices
On the web: [web address]
By mail: mark your choices below, fill in and send form to:
[mailing address]
Contact us
Unless we hear from you, we can begin sharing your information 30 days from the date of
this letter. However, you can contact us at any time to limit our sharing and we will
implement your instructions as soon as reasonably practical.
Check your choices
Your choices will apply to
everyone on your account.
Check any/all you want to limit: (See page 1)
Do not share information about my creditworthiness with your affiliates for their
everyday business purposes.
Do not allow your affiliates to use my personal information to market to me.
(I will receive a renewal notice for this use for marketing in 5 years.)
Do not share my personal information with nonaffiliates to market their
products and services to me.
Your name Mail to:
[mailing address]
Your address
Account number
p. 3 of 3
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