PRIVACY POLICY 

Midstates Bank has established a reputation built on the foundation of integrity, trust and confidentiality.  We understand that the privacy and security of your account information and information that personally identifies you are important.  We respect your right to keep personal information confidential, to be secure from fraud and we are proud of our longstanding commitment to keep information accurate and safe.

This statement describes how we keep consumer information private. While our practices for commercial transactions, corporations, organizations, and their employees reflect the same concern for privacy, they are not necessarily the same as those outlined in this statement.

HOW WE RESPECT YOUR RIGHT TO KEEP INFORMATION PRIVATE AND CONFIDENTIAL. 

We collect and retain only information that is reasonably necessary or useful.

In general Midstates Bank will collect and retain information about you only if we are legally permitted to do so and if we reasonably believe it will be necessary for security purposes or useful in reviewing, handling, or collecting your account, completing transactions, or otherwise serving you. We collect nonpublic personal information about you from the following sources: 

• Information we receive from you on applications and others forms;

• Information about your transactions with us, our affiliates or others;

• Information we receive from a consumer-reporting agency. 

Nonpublic personal information is nonpublic information about you that we may obtain in connection with providing a financial product or service to you.  This could include information such as account balances, payment history, or overdraft history. 

Midstates Bank Website. When you browse Midstates Banks website we do not capture your e-mail address or other information about you unless you decide to transmit it to us in connection with correspondence or a transaction from our secure internet online banking. We recognize the importance of protecting children’s identities online.  Our website is not directed at children, and we do not knowingly collect or maintain personal information from children.  We do not use ‘cookies’ to collect and track information about you. 

Confidentiality and Security of Nonpublic Personal Information

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 standards to guard your nonpublic personal information.  Our employees are trained to understand the importance of customer financial privacy and to properly handle confidential information.  Breaches of customer privacy are considered serious employee misconduct and may result in termination of the employee. 

It is our policy that customer information is not to be provided to anyone over the telephone unless the previously issued Customer Access Code has been provided to the employee by the person requesting the information or we have otherwise determined that you are the person requesting information on your own account or have authorized us to release the requested information.  

We endeavor to maintain the most accurate and up-to-date customer records possible.  If you find that your account information is not correct, current, or complete, please call, e-mail or write to us at the telephone number or address on your account statement and appropriate corrections will be made as soon as possible.  Since some e-mail transmissions may be subject to interception, if your correspondence contains sensitive information (i.e. account number or social security number) you may want to send a letter or fax to us. 

We do not disclose any nonpublic personal information about our customers, or former customers, except as permitted by law. 

We do not share any nonpublic personal information or consumer reports with unrelated companies for any purpose other than verification, and we don't share, rent, or sell publicly available information with any unrelated companies for their independent use. However, Midstates Bank shares limited information in certain situations where we control or oversee its use as described below. 

Unrelated companies.  

We may disclose the following information to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreement:  

• Information we receive from you on an application or other forms, such as name, address and social security number;

• Information about your transactions with us, or others, such as your account balance or payment history;

• Information we receive from a consumer-reporting agency, such as your credit worthiness or credit history. 

We share your information with the companies we hire to provide operational, marketing, or advertising support, companies that help us distribute our products and services, or companies that provide products and services we want to offer. The companies we choose must satisfy our security and privacy requirements.  We share your information only if they agree to treat it confidentially and only if it is legally permissible to do so. We limit the information we provide these companies to what we reasonably believe they "need to know" in connection with their agreement with Midstates, and we don't permit them to use our customer information for any purposes outside our oversight or control. 

Credit bureaus and other companies. We exchange certain information about our customers with reputable consumer reporting agencies, and we may share transaction information with companies that request verification of the existence and condition of accounts. We follow standard banking industry practice and applicable laws, and limit the information we provide to what is necessary to accurately depict your relationship with us. 

Use of Electronic Mail to Transmit Information. We take every measure to ensure your personal financial information remains confidential.  Since email may not be a confidential form of sending confidential information, we discourage the transmission of non-public information through email. Changes of address, questions regarding specific account transactions, or any other information requests or transmissions should not be sent via email. Confidential information should be conveyed to Midstates Bank via regular mail, telephone or in-person with your business or personal banker.  

We are proud of our commitment to privacy. 

Midstates Bank respects your right to privacy and takes every precaution to provide you with the same level of privacy within our virtual branch that you receive through more traditional bank delivery channels. If you feel we have not met our obligations in the protection or use of your personal information, you may submit a complaint to us. Any complaint will be handled in compliance with the Institution’s Consumer Complaints Policy. Breaches of customer privacy are considered serious employee misconduct and may result in termination of the employee.   If you have additional questions regarding the privacy of your personal information, please contact your personal or business banker at any of our locations or call 712-755-7738. 

This Consumer Privacy Statement reflects the principles and practices of Midstates Bank and its subsidiaries as of November 2006 and is subject to change.