Privacy Statement

Emmet County State Bank recognizes and respects our responsibility to protect our current and former customers' private information. It is our policy that all personal information you supply to us will be considered confidential. The success of a financial institution, like ours, depends heavily on the level of trust and confidence it enjoys with its depositors, borrowers and shareholders. In continuing our commitment to provide quality service to our customers, Emmet County State Bank has adopted the following privacy statement for officers, directors and employees. This privacy statement applies to individuals (consumers) and Emmet County State Bank reserves the right to amend it at any time.

Our Collection, Use and Retention of Customer Information.

We collect, use and retain information about our customers only where we reasonably believe it would be useful in administering our business, and providing products, services and other opportunities to our customers. We collect and retain information available from public records, market research and credit reports, as well as information you provide to us, only for specific business purposes. We will tell you why we are collecting and retaining it upon your written request. We use information to protect and administer our customer's records, accounts and funds; to comply with certain laws and regulations, to help design or improve our products and services, and to understand your financial needs and provide you quality products and outstanding service. If you send us e-mail, we may retain the content of the e-mail and your e-mail address in order to respond to questions or concerns you may have expressed.

Our Maintenance of Accurate Information.

We have implemented procedures to help assure that our customers' financial information is accurate, current and complete in accordance with commercially reasonable standards. While some procedures are required by federal or state law, we also have procedures for responding to a request to correct inaccurate information in a timely manner and to update information and remove old information. Customers should notify us immediately at 712-362-2641 if they receive information regarding their relationship with us that they believe to be inaccurate.

Limited Employee Access to Information.

We maintain physical,electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We have procedures and security levels that limit employee access to personally identifiable information to those with a business reason to know such information. Appropriate disciplinary measure are taken to enforce employee privacy responsibilities.

Restrictions on the Disclosures of Account Information.

We do not reveal specific information about our current or former customers' accounts or other personally identifiable data unless (1) our customer has requested or given written authorization: (2) the information is provided to help complete a transaction initiated by our customer; (3) the information is provided to a reputable credit bureau or similar information reporting agency; or (4) disclosure is lawfully permitted or required. Any written authorization must include directives on whom the information is to be given to, what information can be revealed and the expiration date of the authorization. WE DO NOT SHARE CUSTOMER INFORMATION WITH AFFILIATES OR NON-AFFILIATED THIRD PARTIES UNLESS PERMITTED BY LAW.

Maintaining Customer Privacy in Business Relationships with Outside Third Parties.

At times it is necessary to provide personally identifiable information about our customers to a third party, such as a vendor or service company we hire to provide support or services to our bank operation. These vendors and service companies agree to safeguard our confidential customer information and must abide by applicable law.

If you believe Emmet County State Bank has misused information obtained through our relationships with you or if you have question or concerns regarding this privacy policy, please contact Doug Lago, President at 712-362-2641 to resolve any disputes.

The board of Directors approved this policy on the 13th day of June 2002.