Privacy Policy

Approved by the Board of Directors on March 23, 2007

Privacy Philosophy

Our Privacy Notice is an important part of our commitment to provide you with the best financial and client service possible. We believe it is essential to clarify how Waterford Village Bank uses collected information, the benefits of such use and the way information is protected against unauthorized access and use. Your concern about the security of your personal information and your accounts is understandable and we want to assure you that we are continuously taking steps to safeguard your personal information. It is also essential that you know that we do not sell customer lists or individual customer information to any third parties.

Each customer relationship at Waterford Village Bank (WVB) is built on trust. We have implemented policies, procedures and controls to help safeguard and prevent unauthorized disclosure of non-public personal information, as well as detect any unauthorized disclosures. WVB employees are trained to handle customer matters and maintain confidence in a manner consistent with applicable laws and this notice. Only employees actively engaged in the discharge of assigned duties involving customer information are authorized to access specific information related to that purpose.

Information We Collect

Each of our affiliates collects and uses nonpublic personal information for different purposes, depending on the requirements of serving our customers. We may collect information such as your name, address, social security number, assets, liabilities, income and other nonpublic personal information through:

• Account or credit applications and forms you choose to complete, whether written, by telephone or electronic means
• Credit and consumer reports, such as your credit history and references, from consumer credit reporting agencies
• Our own transaction experiences with you, such as account balances, mortgage information or payment activity

Information We Share

We may share public and non-public personal information concerning your transactions and experience within WVB and related organizations. This sharing of information is intended to help us offer financial products and services we believe would benefit you and facilitate the servicing of your accounts. You have a choice as to whether or not you want this information shared with Waterford Village Bank-related organizations. If you prefer that we not share this information, you may opt out by writing to us at Waterford Village Bank, Attn: Compliance Officer, 8411 Main Street, Williamsville, New York 14221. Please provide your name, social security number, address and account number(s), and signature.

Other non-public personal information may be shared with service providers who assist us in servicing your accounts and preparing and/or delivering financial services and products to you on our behalf. Examples of such third-party service providers include check printers, data processors, deposit or loan account service providers, check verification services, and credit reporting agencies.

Information we collect, as described above, may also be shared with companies that perform marketing services on our behalf or with other financial institutions with whom we have joint marketing agreements. This allows us to offer a variety of financial products and services we endorse and believe you may find beneficial. These companies we do business with agree to keep such information confidential and are prohibited from disclosing such information to anyone for any other purpose. We do not, and will not, share your information with non-financial companies for the purpose of allowing them to market their products and services to you.

WVB does not disclose any non-public personal information about you to any other third parties except as permitted or required by law. We do not share medical or health insurance information, nor will we disclose medical information to unaffiliated third parties unless you have instructed us to do so in writing.

Information about WVB customer account transactions and experience may be reported to credit bureaus. Late payments, missed payments, or other defaults on your accounts may be reflected in your credit report.

Information Security Standards

Waterford Village Bank continually updates and improves our security standards and procedures to help protect against anyone gaining unauthorized access to your confidential information and to prevent fraud. We maintain physical, electronic and procedural safeguards that comply with federal standards. Our associates have an appropriate level of access to your personal information in order to perform their jobs and provide you with the best financial products and services possible. We do work with law enforcement officials to pursue any individuals who either fraudulently access or attempt to access or use information. We are continually looking for new technology to further enhance the security of this information. Through appropriate checks and balances built into procedures-such as asking you for information only you would know-we work to properly identify you when you contact us.

New Account Information

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

Fair Credit Reporting Act

We share information about you with our affiliates, as permitted by the Fair Credit Reporting Act. Examples of this information include information from credit reporting agencies and other outside sources. If you do not wish us to provide externally derived information to our affiliates, you may advise us in writing at Waterford Village Bank, Attn: Compliance Officer, 8411 Main Street, Williamsville, New York 14221. Please provide your name, address, social security number and account number(s), and signature. Your request to not share information does not include information we are permitted to share by law, such as data related solely to our experiences or transactions with you. Your account balance and payment history are examples of information we are always permitted to share with our affiliates.

Correcting Information Shared with Consumer Reporting Agencies

If you believe any of the information we have shared with a consumer reporting agency is in error, please let us know. Write to us at: Waterford Village Bank, Attn: Compliance Officer, 8411 Main Street, Williamsville, New York 14221. Please provide us with your complete name, current address, phone number, and Social Security number. You will also need to include your account number, type of account, and the specific item in dispute. You must tell us the reason you believe this information has been reported in error and provide documentation as available.

Identity Theft

Victims of identity theft have certain rights related to privacy under the law. If you believe you are a victim of identity theft with respect to any of your accounts or transactions with WVB, you may notify us at: Waterford Village Bank, Security Officer - Identity Theft, 8411 Main Street, Williamsville, New York 14221. Please provide as much detail as possible about the accounts or transactions in question, including any dates and account or transaction numbers that apply. We may contact you to discuss additional information necessary to resolve the matter.

For more information about identity theft protection and repair, visit the Federal Trade Commission at www.ftc.gov and click on the "Avoid ID Theft" box on the left margin. There you will find helpful information about how to protect yourself. You will also find information on what to do if you believe you are a victim of identity theft.

Internet Information Privacy

Waterford Village Bank Website

WVB has taken extensive measures to ensure that the information and data presented on this website is accurate, appropriate and up to date. While every effort is made to maintain the accuracy and utility of this information, WVB makes no express or implied warranty regarding such information or data, and hereby disclaims all legal liability and responsibility to persons or entities that use or access this site and its content, based on their reliance on any information or data obtained through this website.

Information on this website is not intended to constitute and should not be considered as legal or financial advice, nor is it intended to substitute for obtaining legal or financial advice from competent, appropriate and independent legal counsel or financial advisor. This website content is not designed or intended to provide authoritative financial, accounting, investment or other professional financial advice which may be reasonably relied on by its readers. If expert assistance in this area is required, the services of a qualified professional should be retained.

These privacy guidelines have been developed with the recognition that Internet technologies are rapidly evolving, and that underlying business models and procedures are constantly being challenged and modified. Accordingly, this notice is subject to change. Any such changes will be posted on this page as appropriate.

By your continuing use of our website you signify your acceptance of this Privacy Notice. If you do not accept the qualifications of this Privacy Notice, please do not use our website.

Use of Information Collected Online

When you visit our website to view any pages, read product information, or use our online calculators and other tools, you may do so without telling us who you are or revealing any personal information. While we do not collect identifying information about individual visitors to our site, we do use software to collect information for the strict purpose of tracking activity on our site. This allows us to better understand how many people visit us and which pages and features are most popular.

There may be instances where you elect to provide us with personal information. If you, for example, request forms or information, you are transmitting the information that applies to you in the form of a message. This will typically include information like your name, mailing address, email address, the kind of request you are making, and any other information necessary to fulfill your request. You only transmit personally identifying information that you enter yourself. This information cannot be collected unless you specifically elect to send it to us.

This information may be used internally only for the purpose of fulfilling the request or for contacting you directly and is not given or sold to any other business or organization. When you submit personally identifying information via one of our feedback or application forms, that information is encrypted, or scrambled, by your browser before it is transmitted back to our website. This effectively prevents anyone from intercepting and reading personal information about you. Note that this encryption does not take place if you send us e-mail, but only when you use your Web browser to respond to one of our online forms. Other than the automatic data collection activity described above, this site collects no personally identifiable information. When you knowingly and voluntarily provide personal, nonpublic information, such as when you complete data fields on a loan application, you have chosen to make an exception to the automatic data collection as described.

Use of "Cookies" on this Website

You will notice the term "cookies" used throughout the Internet to describe small text files used by our Web server to communicate with your Internet browser. We use cookies to improve the functionality of our Web site. We do not use cookies to store or transmit any personal, identifiable information about you.

Some parts of the WVB website may use a "cookie," which is a file placed on your computer hard drive that allows the WVB server to log the pages you use in the WVB website to determine if you have visited the site before. It also stores your preferences and other information on your computer to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content. No personal identifying information is captured by the cookie. This information is used by the WVB server to provide certain website features during your visit. You can set your browser to warn you when placement of a cookie is requested, and decide whether or not to accept it. By rejecting a cookie, some of the features available on the site may not function properly.

Email Communications

When you choose to identify yourself to WVB and provide an email address as an accepted communication channel, you are consenting to WVB using the information you provide, including personally identifying information, in accordance with this notice, unless you expressly state in the email your objection to any use(s). This may include the transmission of service communications such as welcome letters, billing reminders, technical service information and security announcements. Since general email is not secure and may be intercepted or viewed by others, you should refrain from sending confidential or private information via email.

Passwords and Identification

To access certain online services, you will need a User ID (Identification) and Password. This information may either be provided to you or you will be allowed to choose your own. The User ID and Password are designed to protect you by confirming your identity to our computer network systems, and are to be kept confidential. Our employees do not have access to your password. It is very important that you not share this information or allow a computer to "remember" your password, particularly if you are using a computer with public access such as one located in a library or a college computer lab. You may be required to change your password from time to time. For further safety, additional security questions may be incorporated into our security procedures to provide supplementary protection. If a password is used to help protect your accounts and personal information, it is your responsibility to keep your password confidential and protected. Do not share your password with anyone. If you are sharing or using a public-access computer, you should always log out of the site or service before leaving a terminal to prevent access to your information by a subsequent user.

Links to Other Websites

This WVB website provides links to other websites for convenience and informational purposes only. Users should be aware that when you select a link on the WVB website to an external website, you are leaving the WVB site. You will see a disclosure on our site that alerts you when you are leaving our website. Linked sites are not under the control of WVB, and WVB is not responsible for the contents of any linked site or any link contained in a linked site, or changes or updates to such sites. Inclusion of such links in the WVB website does not imply endorsement by WVB of the site, its content, advertisers or sponsors. For your protection, we recommend that you review the separate privacy notices provided on these linked websites. External sites may contain copyrighted materials with restrictions on use and reuse, whereby permission for use or reuse must be obtained from the original source, not from WVB.

Children's Information

Information on the WVB website is intended for general audiences and children. We respect the privacy of children and comply with the practices established under the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect or retain non-public personal information from anyone under the age of thirteen unless that information is provided to us by an adult authorized to do so.

We hope our Privacy Policy helps you understand how we collect and share information. If you have any questions regarding this policy, please contact our Compliance Officer at 716.639.2000 or 1.800.982.0075. We are required to provide our customers with a copy of our Privacy Notice each year.