ONLINE BANKING CENTER

First National Bank Privacy Policy

At First National Bank, our mission is to meet the desires of our customers. As financial service professionals entrusted with sensitive financial information, we respect the privacy of our customers and are committed to treating customer information responsibly. This policy summaries our practices regarding the collection, use, retention and security of nonpublic personal information concerning those customers of ours who obtain a financial product or service from us that is to be used primarily for personal, family or household purposes.

Types of Information We Collect

The types of information we collect and share depend on the product or service you have with us. This information can include:

• Social Security number
• Account balances
• Transaction history
• Income
• Payment history
• Credit history

We do not disclose any nonpublic information about our customers to anyone, except as permitted by law. If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this policy.

Ways we Collect Your Information

We collect your personal information, for example, when you:

• Open an account
• Apply for a loan
• Use your debit card
• Give us your contact information
• Show your driver's license

How We Share Your Information

All financial companies need to share customers' personal information to run their everyday business. Below, we list the reasons why we share customers' personal information.

• For our everyday business purposes-such as to process your transactions, maintain your account (s), respond to court orders and legal investigations, or report to credit bureaus
• For our marketing purposes-to offer our products and services to you

Confidentiality and Security

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We also maintain other physical, electronic, and procedural safeguards to protect this information and we limit access to information to those employees for whom access is appropriate.

> Privacy Model Disclosure

Addendum to First National Bank Privacy Policy

This addendum is a supplement to the Privacy Policy of the First National Bank focusing on the protection of customer information, specifically against identity theft and pretext calling.

Identity theft is the fraudulent use of an individual's personal identifying information. Often identity thieves will use another individual's personal information to fraudulently open various types of new accounts with financial institutions. This information is often obtained from the theft of wallets or purses, stealing financial institution's statements, diverting mail with a fraudulent change of address or rummaging through trash.

Pretext calling is a fraudulent means of obtaining an individual's personal information. Pretext callers contact financial institution employees posing as a customer in order to access personal account information. Information obtained from pretext calling is then sold to various individuals for uses in court proceedings or when combined with pretext calling to obtain personal information to create fraudulent accounts.

It is the policy of First National Bank that all employees use a variety of methods to safeguard customer information and reduce the risk of loss from identity theft, including but not limited to

• Verifying personal information to establish the identity of
  individuals applying for account services with our bank
• Review new accounts for the possibility of fraud in the opening process
• Verify the legitimacy of address changes
• Maintain overall adequate security standards

To reduce the risk of fraudulent applications, the bank requests positive verification of all individuals opening the new account. We also rely on logical verification, which is accomplished by verifying the address provided in the new account.

Positive verification would include

• Requesting photo based identification at the opening
  of all new accounts unless the individual is known
• Cross-verification of the address provided with the telephone directory
• When appropriate, we may obtain an individual's consumer
  credit report to obtain a more detailed verification
• New accounts are followed up with a "thank you" letter mailed
  to the address listed on the account as a verification of a proper address

Logical verification entails assessing the consistency of the information presented such as zip code, area code provided covering the same geographical area as the street number and street address and that they have a logical basis which is more easily verified in a small town, such as ours.

Change of Address Requests

• Change of address requests on existing accounts has the potential for being a fraudulent activity
• We will verify the customer information before completing the address change to insure that we are talking to the proper individual to authorize such a change of address.
  

Overall Security Standards

• All paper reports and storage of paper information, when it is time for such information to be discarded shall be processed through the paper shredder to avoid the reconstruction of consumer data from "dumpster diving"

Pretext Calling

Limiting telephone disclosures

The preferred way for giving out information on our customer's accounts over the telephone is for individual's to be instructed to use the 24 hour, seven day a week FirstAdvantage program. This product the bank offers provides balance and item activity in all accounts with the First National Bank. The customer may select their own four digit code to provide authorization for the release of such information.

In other instances, we will request from the caller their social security number, date and amount of the last deposit, in order to provide some limited information about their account.

In conjunction with the implementation of this policy, staff training has been held discussing the importance of safeguarding customer information.

Reporting Suspected Identify Theft and Pretext Calling

Should anyone believe that there has been activity related to identity theft or pretext calling, it should be reported to their immediate supervisor. Then follow-up will be made with the proper authorities. It is the policy of the bank to notify the local law enforcement agency immediately and also to notify the OCC by means of the Suspicious Activity Report (SAR).

Shredding of credit reports

Credit reports which are used for loan decisions, are kept in the customers loan file at all times. Any credit reports that are used with applications that are withdrawn or denied are stored in folders in the loan vault. At the time the retention period expires, shredding the materials destroys all credit information.

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