Section 1610

FINANCIAL RECORDS PRIVACY POLICY

General Policy Statement: Hamilton Horizons Federal Credit Union has a duty to protect the confidential nature of non-public personal information our members provide regarding their financial transactions with us. Except as provided in our agreement with our members, reporting to a credit reporting agency regarding a member's loans and accounts or as permitted or required by applicable state or federal law, the Credit Union will not release member non-public personal information to any person. To develop, implement and revise this policy, as needed, the board of directors appoints Cindy Rein Zima, CEO, as the Financial Privacy Coordinator.

The Financial Privacy Coordinator is responsible for the development and maintenance of procedures that insure the Credit Union's compliance with the obligations described in this policy. In this regard, the Financial Privacy Coordinator will insure that the Credit Union develops procedures that safeguard the security and confidentiality of member information: protect against any anticipated threats or hazards to the security or integrity of such records: and protect against unauthorized access to or use of such records or information that would result in substantial harm or inconvenience to any member.

The Financial Privacy Coordinator will access, control and manage any risk that may threaten the security, confidentiality or integrity of member information systems.

The Financial Privacy Coordinator is responsible to ensure that the Credit Union staff receives appropriate training to recognize and respond to any unauthorized attempts to obtain member information. Also a program will be developed that regularly tests all key controls, systems and procedures.

The Financial Privacy Coordinator will also insure the Credit Union's compliance with the following matters:

A. Telephone consumer Protection Act

The Credit Union will tell members how to remove their names from telemarketing and mailing lists when they open an account.

B. Fair Credit Reporting Act

Members should know that the Credit Union is permitted by the Fair Credit Reporting Act to share the following types of information with our affiliated companies:

• Identification information.

• Transactional information.

• Account experience (e.g., checking and loan accounts).

C. Right to Financial Privacy Act

The Right to Financial Privacy Act establishes specific procedures that federal government authorities must follow when seeking member records. The Credit Union's employees will follow those procedures when a federal agency requests member financial information. (See section 9330 of the Credit Union's Policy Manual).

D. Internet and Electronic Banking Privacy Policies

The Credit Union does not collect information about visitors to our website. The applications and transactions the Credit Union accepts electronically (online, by phone or fax) are all subject to the Credit Union's general privacy policy. The Credit Union will use encryption devices to insure that members' transactions over the internet are safe and secure.