Financial Privacy Rights

We , our , and us mean Security State Bank.

This is our privacy notice for our customers. When we use the words “you” and “your” we mean the following types of customers:

• All of our consumer customers who have a continuing relationship with us, such as:
• Deposit account
• Loan account
• Credit card
• Safe deposit box
• Retail installment contract we hold and service
• Self-directed Individual Retirement Account where we act as custodian or trustee
• Home mortgage brokerage

We will tell you the sources for nonpublic personal information we collect on our customers. We will tell you what measures we take to secure that information.

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 resources, such as telephone directories or government records. 

An affiliate is accompany 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 company that is not an affiliate of ours. 

The Information that we Collect

We collect nonpublic personal information about you from the following sources: 

• Information we receive from you on applications or other forms
• Information about your transactions with us
• Information about your transactions with nonaffiliated third parties
• Information from a consumer reporting agency

Information We Disclose About You

We do NOT disclose any nonpublic personal information about you to anyone, except as permitted by law.

The Confidentiality, Security and Integrity of Your Nonpublic Personal Information

We restrict access to nonpublic personal 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 that comply with federal standards to guard your nonpublic personal information.

Nonpublic Personal Information and Former Customers

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

Luxury Expenditures Policy 
 

Security State Bank has four branches and about 50 employees.  The Bank has historically been very conservative regarding luxury expenditures.  Going forward Senior Executive Officers and other bank officers and employees will be permitted the following kinds of expenditures:

1. Any meals that are for a business purpose where a bank or prospective bank client is entertained.  Meals away from home when attending bank directed business with or without a client.  Sporting or cultural events as entertainment are permitted when entertaining clients.  Attending sporting events as a participant with or without a bank client are permitted as long as there is a business purpose.  These kinds of expenditures should be reasonable in relationship to the client’s perceived benefit to the bank and the normal and usual costs associated with meals or events.  In other words no sky boxes at Bronco’s games, no $500 rounds of golf per individual, and no $500 lunches.  Memberships in service clubs are encouraged and the bank will pay the dues and reasonable related expenses.  Memberships in golf clubs, health clubs, and similar facilities must be approved by the CEO.
2. No facility or office renovations of any kind are permitted without board approval.  Maintenance and repairs up to $1,000 are permitted without CEO approval.  All equipment and bank furnishings in excess of $1,000 must be approved by the CEO.
3. Business travel will normally be in bank provided vehicles or employees will be reimbursed for use of their own vehicle at prevailing mileage rates permitted by the IRS.  The bank will pay for coach class plane tickets, rental cars, and reasonable hotel accommodations.  Also the bank will pay for reasonable convention attendance expenses and/or educational/training programs.  A good rule of thumb on all expenses is; if you had to pay for it yourself would you spend the money.
4. Some times staff may find it necessary to exceed the guidelines above, i.e., airplane private charter, hotel accommodations and/or meals and entertainment in a metropolitan area where costs are higher.  The CEO or the bank’s president can provide prior approval with nothing more than an email request and explanation of purpose followed after the fact by a written expense submittal.
5. As a general rule SEOs and other staff are authorized to include their spouses where appropriate, but not their children or their family members.
6. Staff who fail to follow the above procedures may be asked to reimburse the bank for the expenditure(s) or other wise disciplined.
7. SSB’s internal audit department checks officer credit card expenditures monthly and reports their findings to the audit committee.  All other expense reimbursement requests must be approved by the CEO or the Bank’s president.  Internal audit will quarterly or as necessary audit all public relations and entertainment expenses.
8. Any bank officer, director, or employee who suspects that another staff member is violating this policy is to report that suspicion to the Chairman of the Board either in writing (email is acceptable) or by telephone.  Any such reporting will be kept in confidence by the Chairman.
9. The luxury expenditure limitations portion of this policy will be posted on the bank’s website.