Bank of Bluffs Mobile Privacy Policy

· This Privacy Policy describes the types of "Personal Information" (information that is identifiable to a particular person) that is collected (directly or through service providers) in connection with the mobile downloadable application ("App") offered by Bank of Bluffs. This Privacy Policy is intended to supplement the disclosures in any Privacy Policy that you may have already been presented by us in connection with online banking or other services.

· We may collect Personal Information about you, which may include: name, postal address, zip code, e-mail address, telephone number, account numbers, payment card expiration date, payment card identification or verification numbers, social security number, mobile device location, and other information that we can use to contact you, verify your identity, provide the functionality available through use of the App. This information may be used to manage risks, such as information maintained about you by identity verification services and consumer reporting agencies, and any Personal Information that you may enter into information blocks present in the App interface.

· We may collect Personal Information about you from the following sources:

o We may collect information regarding your mobile device such as device settings, unique device identifiers, information about your location, and analytical information that may assist with diagnostics and performance. For your convenience, you may be asked to grant permission for access to your mobile device's geolocation data. This information may be collected when you use certain services that are dependent on your mobile device’s location (such as the location of an ATM or in store transactions).  Information that you input to the App or that the App collects automatically;

o Your use of the App, and your interactions with customer care, including information you enter or speak, and information transmitted by your computer or mobile device or other devices you use as part of your receipt of service; and

o We may also collect Personal Information about you from others, such as Affiliates, or other companies (such as for fraud detection).

· We share Personal Information about you only as permitted by law. For Personal Information that is nonpublic and that we collect in connection with a financial service, U. S. federal law permits us to share such information only for the purposes shown in the following table:

Reasons why we share certain data, what data we share, and if you can limit our sharing

Reasons we can share your Does Bank of Bluffs Share?

your personal information

For our everyday business purposes—such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes - You cannot limit this sharing.
For our marketing purposes— to offer our products and services to you	No –
For joint marketing with other financial companies	No
For our affiliates’ everyday business purposes—information about your transactions and experiences	No
For our affiliates’ everyday business purposes—information about your creditworthiness	No
For affiliates to market to you	No
For nonaffiliates to market to you	No

· We use Personal Information about you only as permitted by law, including but not limited to the following purposes:

o To complete transactions and render services authorized by you;

o Other everyday business purposes,

· If we are involved in a merger, acquisition, or sale of all or a portion of our assets that results in a change of the majority ownership of the App or the entity that owns it, you will be notified of this via email and/or a prominent notice on the App, as well as any material change in uses of your Personal Information, as well as any choices you may have regarding Personal Information about you.

· Definitions.

· "Affiliates" means companies related by common ownership or control. They can be financial or nonfinancial companies. The Bank of Bluffs affiliates include financial companies such as Scott Morgan Bancorp.

· "Nonaffiliates" means companies not related by common ownership or control. They can be financial or nonfinancial companies. The Bank of Bluffs does not share with nonaffiliates so they can market to you.

· "Joint Marketing" means a formal agreement between nonaffiliated financial companies that together market financial products or services to you. Bank of Bluffs does not jointly market.

· To protect Personal Information about you from unauthorized access and use, we maintain physical, electronic, and procedural safeguards, including but not limited to security measures that comply with applicable federal and state laws. We also require our service providers and business partners to whom we disclose the information to do the same. When you enter sensitive information (such as a debit or credit card number) into the App, we encrypt the transmission of that information using secure socket layer technology (SSL). We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

· We will retain, protect, use and share Personal Information about you as long as it is reasonably required for the purposes described in this Privacy Policy, and as required by law, including but not limited to for risk management, regulatory compliance, and audit purposes.