Protecting your privacy and the confidentiality of your information is important to Winter Hill Bank. We recognize our obligation to keep the information you provide us secure and confidential.

Our commitment to protect your financial information will continue under the principles and guidelines described in this notice. What Information We Collect
We may collect "nonpublic personal information" about you from the following sources:

• Information we receive from you on applications or other loan and account forms;
• Information about your transactions with us, our affiliates or others; and
• Information we receive from third parties such as credit bureaus.

"Nonpublic personal information" is nonpublic information about you that we obtain in connection with providing a financial product or service to you. For example, nonpublic personal information includes information regarding your account balance, payment history, and overdraft history. What Information We Disclose
We may disclose the following kinds of nonpublic personal information to third party companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements:

• Information we receive from you on applications or other loan and account forms, such as your name, address, social security number, assets and income;
• Information about your transactions with us, our affiliates or others, such as your account balance, payment history, parties to transactions, and credit card usage; and
• Information we receive from a consumer reporting agency, such as your creditworthiness and your payment history

When we work with third parties such as insurance agencies, investment advisors and other similar companies, they are subject to the same confidentiality policies that the Bank maintains and are required to sign confidentiality agreements.

We do NOT disclose any personal information about you 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 notice. Our Security Procedures
We also take steps to safeguard customer information. We restrict access to your nonpublic personal and account information to those employees who need to work with 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. For more information please call us at 800-444-4300 or email us at info@winterhillbank.com. You may also find additional information at the Federal Trade Commission's website (www.ftc.gov/privacy).