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Privacy Policy

CLEAR LAKE BANK & TRUST COMPANY OF CLEAR LAKE (“CLB&T”) is committed to safeguarding customer privacy. As a customer-oriented financial institution, it is our policy to treat personal and financial information with the utmost respect, and in accordance with our customer’s wishes. For this reason, and because we want our customers to be confident and informed, we have adopted this Privacy Policy.

CLB&T recognizes the reasonable expectation of privacy of all customers as well as the importance of protecting customer privacy. CLB&T’s policy is to adhere to the following principles to protect customer privacy.

PRIVACY PRINCIPLES:

1. Recognition of a customer’s expectation of privacy

CLB&T recognizes and respects the privacy expectations of our customers and desires to communicate its principles of financial privacy to customers by making this policy available as well as answering questions from customers about financial privacy.

2. Use, collection, and retention of customer information

CLB&T collects, retains, and uses information about customers only where it reasonably believes that the information would be necessary for specific activities, useful to administer CLB&T’s business of providing products, services, and other opportunities to customers, and when permitted by law. 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, our affiliates, or others; and Information we receive from a consumer-reporting agency.

3. Maintenance of accurate information

CLB&T has established and maintains procedures to collect financial information that is accurate, current, and complete in accordance with reasonable commercial standards. CLB&T will also respond to correct any inaccurate information in a timely manner.

4. Limiting employee access to information

CLB&T restricts access to nonpublic personal information about you to those employees with a business reason for knowing such information in order to provide products and services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. CLB&T conducts training to educate employees on the importance of confidentiality and customer privacy and maintains appropriate disciplinary measures to enforce privacy responsibilities.

5. Disclosure of personal information to third parties

We may disclose all of the nonpublic personal information that we collect from current and former customers, as described in point #2 above, to the following type of third party:

Affiliated financial service providers – e.g. insurance agents.  This is done to more efficiently deliver a full range of financial products and services to our customers. Any such information sharing is in compliance with applicable laws and regulations. The affiliates keep the information provided to them confidential.

Nonaffiliated third parties that perform marketing, banking and financial services on our behalf or to other financial institutions with whom we have joint marketing agreements. In all cases we only work with approved vendors who meet our security and privacy concerns and who agree, in writing, to hold confidential all customer information and allow us to check their practice of strict standards. We do not, in any case, provide account numbers to such parties.

CLEAR LAKE BANK AND TRUST COMPANY DOES NOT SELL, TRADE, SUPPLY OR BARTER CUSTOMER INFORMATION TO NONAFFILIATED THIRD PARTIES, EXCEPT IN THE SPECIFIC INSTANCES DESCRIBED ABOVE.

6. Disclosure of privacy principles to customers

Information about CLB&T’s privacy policy is available to concerned individuals upon request.

PERSONAL INFORMATION USES:

CLB&T uses individual identifying information received from customers to provide financial services offered by the bank and its affiliates, to evaluate creditworthiness, and to prevent fraud. We also use the information to identify individuals and communicate with them. Information from credit reports is not shared except to the limited extent permitted for non-credit bureaus by the Fair Credit Reporting Act.

Using our Internet Banking Services:

When a customer registers for one of our Internet Banking services we compile a profile of that customer for that service (e.g., name, address, account number, logon i.d., etc.). Each time a customer uses our Internet Banking service, we collect their logon i.d., information about the transactions completed and the informational pages of our Web Site that were visited while using the service.

We use customer profiles in responding to customer inquires on the internet banking service. We aggregate the transaction information to assess and improve our internet banking services. We use transaction information for servicing purposes (e.g., billing). We use both, transaction information and the informational pages of our Web site visited, to help determine a customer’s financial needs so that we can offer other CLB&T products and services to them.

The bank may use a software “cookie” when accessing our Internet Banking products. No cookie will contain any information that would enable anyone to contact you via telephone, email, or U.S. mail. (A cookie is a small piece of information which a website stores in the web browser of your PC and can later retrieve. A cookie cannot be read by a website other than the one that set the cookie. You can set your web browser to inform you when cookies are set or to prevent cookies from being set.)

We do not knowingly solicit data from children, and we do not knowingly market to children, without parent or guardian consent. We recognize that protecting children’s identities and privacy online is important and that the responsibility to do so rests with both the online industry and with parents.