Statement of Information to be Disclosed
Lyon County State Bank (Bank) will not disclose, and does not wish to reserve the right to disclose, nonpublic personal information about customers or former customers to affiliates or nonaffiliated third parties, except as permitted by law.

Scope of Policy
This policy is limited to only those customers who obtain a financial product or service from the bank that is to be used primarily for personal, family, or household purposes.

Definitions
Definitions used in this policy are consistent with terms used in the statutory definitions and regulatory issuances related to consumer privacy in the financial services industry.

Privacy Notice
A privacy notice will be delivered as required by law. The privacy notice accurately summarizes this bank’s privacy principles and practices.

The customer privacy notice parallels the internal operational policies, procedures, and controls of this bank. To the extent the bank develops and maintains a web site, and offers e-banking services, the customer privacy notice will also be available on the site with conspicuous directions on its availability.

Communicating the Initial Customer Privacy Notice
At the time a customer establishes a customer relationship with this bank, the initial customer privacy notice will be provided.

Method of Delivery
The establishment of a customer relationship occurs when this bank and the customer enter into a continuing relationship. We, at that time, will provide the required notice such that the customer can reasonably be expected to receive the actual notice in writing and be able to retain it. We may reasonably expect that a customer has received the privacy notice and can retain it if the privacy notice is:

• Handed in printed format to the customer.
• Mailed to the customer’s last known address.

Oral description of the notice is not deemed adequate. Accordingly, our bank staff may not provide the initial notice required by orally explaining the details of the notice, either in person or over the telephone.

Time Requirements
Initial notices, under certain circumstances, may be provided within a reasonable time frame after we established a customer relationship if:

• Establishing a customer relationship is not at the customer’s election.
• Providing the notice would substantially delay the customer’s transaction and the customer agrees to receive the notice at a later time.

Failure to acknowledge receipt of the notice may result in this bank’s refusal to provide the customer’s requested banking product or service.

Providing Annual Customer Privacy Notice
On an annual basis, no less than every 12 months, we will provide to those customers with a continuing customer relationship, a customer privacy notice. This notice will be provided in a clear, conspicuous manner to each customer. However, it is acceptable to provide a single notice for joint accountholders. Following the initial privacy notice given to each customer, this bank has chosen to provide the annual customer data privacy notice in May of each year.

Customer Privacy Notice Content
The privacy notice provided initially and in subsequent annual issuances will contain the following information to the extent required by law in a clear, conspicuous manner:

• Statement that this bank does not disclose any nonpublic personal information about its customers to anyone, except as permitted by law.
• Statement about what categories of nonpublic personal information this bank collects.
• Statement that if a customer decides to close any account(s) or become an inactive customer, this bank will adhere to the privacy policies and practices as described in this notice.
• Details regarding this bank’s policies and practices with respect to protecting the confidentiality, security, and integrity of nonpublic personal information.

Joint Accountholders
If one or more customers jointly obtain a financial product or service from this bank, the bank may satisfy the privacy notice requirements by providing one notice to those consumers jointly.

Changes in terms of the Privacy Policy and Practices
This bank will not be able to directly, or through any future affiliation, disclose any nonpublic personal information about a customer to an affiliate or a nonaffiliated third party unless:

• We have provided the customer with a revised notice that accurately summarizes this bank’s revised policies and practices.
• We have provided to the customer an opt-out notice with the revised privacy notice.
• We have given the customer a reasonable opportunity, deemed to be 30 days after the notice has been mailed or hand-delivered, to opt out of the disclosure before we disclose the information to any affiliate or nonaffiliated third party.
• The customer does not opt out.

Until such time that this bank has followed this procedure, it may not directly or through any affiliate disclose any nonpublic personal information about the customer to any affiliate or nonaffiliated third party other than as detailed in the initial notice provided by us to the customer.

Information we can Disclose to Affiliates and Nonaffiliated Third Parties
This bank is permitted by law to disclose certain information to affiliates and nonaffiliated third parties. We can disclose:

• Publicly available information, as defined by law.

We can also disclose the following “exempt” nonpublic personal information under the circumstances and reasons described below.

• As necessary to effect, administer or enforce a transaction requested or authorized by the customer, or in connection with:

  Servicing or processing a financial product or service requested or authorized by the customer

  Maintaining or servicing the customer’s account with us or with another entity as part of a private label credit card program or other extension of credit on behalf of the entity

A proposed or actual securitization, secondary market sale (including sale of servicing rights), or similar transactions related to a transaction of the customer

• With the consent or at the direction of the customer, provided that the customer has not revoked the consent or direction.
• To protect the confidentiality or security of our records pertaining to the customer, service, product, or transaction.
• To protect against or prevent actual or potential fraud unauthorized transactions, claims or other liability.
• For required information risk control or for resolving customer disputes or inquires.
• To persons holding a legal or beneficial interest relating to the customer.
• To persons acting in a fiduciary or representative capacity or behalf of the customer.
• To provide information to insurance rate advisory organizations, guaranty funds or agencies, agencies that are rating this bank, persons who are assessing the bank’s compliance with industry standards, and our attorneys, accountants, and auditors.
• To the extent specifically required or permitted under other provisions of law and in accordance with the Right to Financial Privacy Act to law enforcement agencies (as defined in the regulations), to self-regulatory organizations, or for an investigation on a matter related to public safety.
• To consumer reporting agencies as permitted under the Fair Credit Reporting Act, or from a consumer report reported by a consumer-reporting agency.
• In connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of a business or operating unit if the disclosure of nonpublic personal information concerns solely customers of such business unit.
• To comply with federal, state, or local laws, and other applicable legal requirements.
• To comply with a properly authorized civil, criminal, or regulatory investigation, or subpoena or summons by federal, state or local authorities.
• To respond to judicial process or government regulatory authorities having jurisdiction over a bank for examination, compliance, or other purposes as authorized by lay.

Limitations on Redisclosure and/or Reuse of Information
We may not directly disclose any nonpublic personal information which we may receive about a customer from a nonaffiliated financial institution to any other person not affiliated with either the other financial institution or ourselves unless the disclosure would be otherwise permitted by law.

We may use nonpublic personal information about a consumer that we receive from a nonaffiliated institution as permitted by law.

Vendors and Other Third Parties
Pursuant to our policy of not disclosing nonpublic personal information, we will not disclose this information to any vendor or joint marketers, except as otherwise permitted by law.

Record Retention Information/Security
This bank will restrict access to nonpublic information about its customers to those employees who need to know that information to provide products and services to the customer. We will maintain physical, electronic, and procedural safeguards that comply with federal standards to guard the customer’s nonpublic personal information.