ICBA FINANCIAL SERVICES CORPORATION and ICBA INSURANCE SERVICES,
Inc., (collectively “IBFS”), subsidiaries of the Independent Community Bankers of
America, is a service provider to your local community bank. We enable our member
banks to better serve their customers by offering access to investment opportunities
such as mutual funds, annuities, long-term health care, and other insurance products1. We offer this service through a joint agreement between our firm and your bank. That
agreement requires that the confidentiality of your information must be maintained. We
want you to know that, as an IBFS customer, we believe that protecting your privacy is
extremely important. Your bank and we want to be sure that we maintain your
confidence and trust. ICBA Insurance Services, Inc., is the supplier of certain insurance
products while ICBA Financial Services Corporation supplies the investment products.
We collect nonpublic information from you on investment product applications and
related account documentation as well as from your continuing transaction records. We
may share this information about you with the bank that sponsors this program to help
the bank monitor the success of the program or to help the bank provide better service
for all its customers. We do not otherwise disclose any nonpublic personal information
about our customers or former customers to anyone, except as permitted by law. For
example, we may share information on your transactions if we are required to disclose it
by law, regulation, or court order. We restrict access to nonpublic information about you
to those employees who need to know that information in order to provide products or
services to you. We maintain physical, electronic, and procedural safeguards that
comply with federal standards to guard your nonpublic personal information. If you
decide to close your account(s) or become an inactive customer, we will adhere to the
privacy policies and practices as described in this notice.