First Newton National Bank's Privacy Principles

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 Privacy Policy and Security Plan for Safeguarding of Customer Information serves as a standard for all First Newton National Bank employees for collection, use, retention and security of individual customer information.

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.

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.

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 non-public 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 non-public personal information.

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.

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 non-public 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.

Information we receive from a consumer reporting agency.

We do not disclose any non-public personal information about our customers or former customers to anyone, except as permitted by law.

Restrictions on Disclosing Information to Parties Outside First Newton National Bank

We do not reveal specific information about your accounts or other non-public personal information to parties outside our Bank for their independent use unless:

you request or authorize it

the information is provided to help complete a transaction initiated by you

the information is provided to a reputable credit bureau or similar information reporting agency

the disclosure otherwise is lawfully permitted or required

Since we value our customer relationship with you, we will not disclose your non-public personal information to nonaffiliated third parties, except as permitted by law. We do not provide account or non-public 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 principles and practices as described in this notice.

Notify Us of Inaccurate Information We Report to Consumer Reporting Agencies. Please notify us if we report any inaccurate information about your account(s) to a consumer reporting agency. Your written notice describing the specific inaccuracy(ies) should be sent to us at the following address: First Newton National Bank, Attn: Compliance Officer, P.O. Box 489, Newton, IA 50208.

FNNB Privacy Principles June 2008

These Privacy Principles apply to individuals and we reserve the right to change them, along with related provisions, at any time.