PRIVACY POLICY

I. PRIVACY OF CONSUMER FINANCIAL INFORMATION

A. Central Keystone Federal Credit Union shall protect the confidentiality, security, and integrity of each member's nonpublic, personal information consistent with state and federal laws.

B. Central Keystone Federal Credit Union shall take careful and reasonable measures to protect the accuracy and privacy of all member information used in conducting business.

C. Central Keystone Federal Credit Union will not collect or maintain information about its members that is not essential for prudent business purposes.

II. RESPONSIBILITIES

A. Central Keystone Federal Credit Union officers, directors, committee members, and employees are required to hold in confidence all Credit Union transactions with members and all information in regards to members' personal business.

B. It is the responsibility of all officers, directors, committee members, and employees to protect confidential member information.

C. It is the responsibility of all officers, directors, committee members, and employees to identify any potential area of exposure and to take steps to report such discovery and to assist in correcting the condition that could permit any potential security breach.

D. It is, further, the responsibility of all officers, directors, committee members, and employees to report any actual or threatened release of confidential information and to take steps as may be immediately available to prevent or to halt such release.

III. SHARING INFORMATION

A. It is the policy to prohibit disclosure of member information to third parties (excluding Credit Union affiliates) concerning accounts with us, except:

1. When such disclosure is necessary to complete transactions.
2. To verify the existence and condition of your account for a third party (such as a credit bureau) as is permitted by law.
3. To comply with any court order or applicable laws or regulations.

4. When given written permission by the member. Federal law protects the information Central Keystone Federal Credit Union provides to credit reporting agencies and the Fair Credit Reporting Act strictly governs its use.

B. Central Keystone Federal Credit Union does not and will not sell or provide personal information to third parties for independent use. We may share personal information with our Credit Union affiliates, for example Members Financial Services, Inc., as allowed by federal law, if that information is required to provide a product or service that we believe members might want to know about.

C. If requested, members may be excluded from receiving marketing materials and solicitations from affiliated third party vendors of Central Keystone Federal Credit Union.

IV. INTERNET PRIVACY PROTECTION

A. Central Keystone Federal Credit Union uses multiple levels of security, beginning with the member's browser and ending with the Credit Union's operating system that acts as a virtual information vault inside the Credit Union. Information received via online applications is secured within the server and passwords are required for access.

B. Central Keystone Federal Credit Union uses firewalls that are designed to protect account information from unauthorized access outside the Credit Union.

V. ADMINISTRATION AND AMENDEMENTS

A. Protecting member privacy is an ongoing process and Central Keystone Federal Credit Union will continue to review the measures taken to safeguard member information.

B. If member information is shared with vendors, all contracts and agreements between the vendor and Central Keystone Federal Credit Union will include a guarantee that the vendor will safeguard such information.

C. Since no policy can address every possible contingency and circumstance, Central Keystone Federal Credit Union management shall use its good faith business judgment in administering this privacy policy, and expects that all employees and committee members will use good faith in their actions to protect the privacy of credit union members.

D. Central Keystone Federal Credit Union reserves the right to amend this policy in any respect.

Central Keystone Federal Credit Union Privacy Policy Statement

In today's world, there's a lot of talk about consumer privacy issues. Central Keystone Federal Credit Union wants you - our member/owners - to know that we appreciate the trust that you place in us. Protecting personal information and using it in a manner consistent with your expectations is a high priority for everyone associated with Central Keystone Federal Credit Union. Our credit union stands behind the following privacy statement:

• Central Keystone Federal Credit Union will collect only the personal information that is necessary to conduct our business. That means just what is necessary to provide competitive financial products and services - no more.
• Central Keystone Federal Credit Union will protect your personal information. Our credit union will maintain strong controls to ensure that member information in our computers and our files is protected. We pledge to do all that we can to protect against unauthorized access to personal records, ensure accuracy and integrity of communications and transactions, and protect member confidentiality.
• You will always have access to your information. As a member of Central Keystone Federal Credit Union, you will always have the opportunity to review your information and make necessary changes to ensure that our records are complete and accurate.
• Central Keystone Federal Credit Union will only share information when absolutely necessary. We will only share information to administer the products and services we provide, when required to do so by the government, or when we partner with other businesses to offer a broader array of products and services or other opportunities to better serve you, our member/owners.
• Central Keystone Federal Credit Union will only partner with businesses that follow strict confidentiality requirements. The business we select will offer products designed to enhance our members' economic well-being. Under no circumstances will we authorize these firms to charge your account without your express consent, and we will not sell member information to telemarketing firms.
• Central Keystone Federal Credit Union will offer you a choice in how your information is used. Any member of our credit union may elect to keep their information from being shared with our business partners. We will inform you on how to exercise your choice, and we will take all reasonable steps to make sure that your requests are followed. At least once a year, we will remind all members of their right to choose.

Approved by the Board of Directors December 20, 2000