First Newton National Bank's Privacy Principles

Updated November 2000

At First Newton National Bank, our mission is to meet the desires of our customers. As financial service professionals entrusted with sensitive financial information, we respect the privacy of our customers and are committed to treating customer information responsibly. Our Customer Information Privacy Principles serve as standards for all First Newton National Bank employees for collection, use, retention, and security of individual customer information.

1. Recognition of Your Expectation of Privacy. At First Newton National Bank, we believe the confidentiality and protection of customer information is one of our fundamental responsibilities. And while information is critical to providing quality service, we recognize that one of our most important assets is our customers' trust. Thus, the safekeeping of customer information is a priority of First Newton National Bank.
   
   
2. Our Collection, Retention, and Use of Information About You. Information about consumers is accumulated from a variety of sources. Some information is provided to First Newton National Bank directly by customers themselves. Other data is developed by First Newton National Bank as a function of providing a product or service to a customer. Still other information is obtained from outside sources. We will limit the use and collection of information about our customers to that, which is necessary to administer our business, provide superior service, and offer opportunities that we think will be of interest to customers. This means that we will use information to help us identify and mitigate potential risks or loss to First Newton National Bank. We will use information to help identify additional products or services that we believe customers might want to know about. We will use this information only in accordance with the principles set out in this Policy.
   
   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
   • Information about your transactions with nonaffiliated third parties
   • Information from a consumer reporting agency
   
   We do not disclose any nonpublic agency information about you to anyone, except as authorized by law.
   
   
3. Our Maintenance of Accurate Information. We continually strive to maintain complete and accurate information about you and your accounts. Should you ever believe that our records contain inaccurate or incomplete information about you, please notify us. We will investigate your concerns and correct any inaccuracies.
   
   
4. Limiting Employee Access to Information. Each First Newton National Bank employee is required to follow our Company's "Code of Conduct," which states that all customer information is considered private and privileged and is to be used solely for the purpose of providing you with the finest service available.
   
   We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
   
   
5. Security Procedures to Protect Information. First Newton National Bank is committed to the security of your financial and personal information. All of our operational and data processing systems are in a secure environment that protects your account information from being accessed by third parties. We maintain and grant access to customer information only in accordance with our internal security standards.
   
   
6. Restrictions on Disclosing Information to Parties Outside First Newton National Bank. We do not reveal specific information about your accounts or other personally identifiable data to parties outside our Bank for their independent use unless: 1) you request or authorize it; 2) the information is provided to help complete a transaction initiated by you; 3) the information is provided to a reputable credit bureau or similar information reporting agency; or 4) the disclosure otherwise is lawfully permitted or required. Since we value our customer relationship with you, we will not disclose your nonpublic personal information to nonaffiliated third parties, except as permitted by law. We do not provide account or personal information to non-First Newton National Bank companies for the purpose of independent telemarketing or direct mail marketing of any non-financial products or services of those companies.
   
   If you decide to close your account(s) or become an inactive customer, we will follow the privacy policies and practices as described in this notice.
   
   
7. Disclosing Our Privacy Commitment to You. First Newton National Bank recognizes and respects the privacy expectations of our customers. We want our customers to understand our commitment to privacy in our use of customer information. As a result of our commitment, we have developed these Privacy Principles, which are made readily available to our customers. Customers who have questions about these Privacy Principles or have a question about the privacy of their customer information should call First Newton National Bank at 614-792-3010, e-mail us at fnnb@netins.net or mail us at P.O. Box 489, Newton, Iowa 50208.