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NORTHWOODS BANK OF MINNESOTA, NA

CUSTOMER INFORMATION

PRIVACY PRINCIPLES

At Northwoods Bank of Minnesota, NA ("the Bank") we strive to help our customers achieve financial success. As your personal financial 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 Northwoods Bank of Minnesota employees for collection, use, retention, and security of individual customer information.

Recognition of a Customer’s Expectation of Privacy

At the 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 for the Bank.

Customer Benefits of Institution’s Information Management Practices

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, information about your transactions with our affiliates, others, or us, market research and credit reporting agencies, as well as nonpublic personal information you provide to us, such as on applications and other forms only for specific business purposes. We will tell you why we are collecting and retaining it upon your request by sending you a written explanation. We use information to protect and administer our customers’ 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. 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.

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 federal or state law requires some procedures, we also have procedures for responding to requests to correct inaccurate information in a timely manner, and to update information and remove old information. If they receive information regarding their relationship with us that they believe to be inaccurate, customers should notify us immediately by writing to Northwoods Bank of Minnesota.

Limitations on Employee Access to Information

At the Bank, employee access to nonpublic personal information is limited to those with a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of customer information and on these Privacy Principles. Because of the importance of these issues, all the Bank’s employees are responsible for maintaining the confidentiality of customer information and employees who violate these Privacy Principles will be subject to disciplinary measures.

Protection of Information via Established Security Procedures

The Bank is committed to the security of your nonpublic personal information. All of our operational and data processing systems are in a secure environment that protects your account information from being accessed by unauthorized parties. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information and grant access to customer information only in accordance with our internal security standards.

Restrictions on Disclosure of Account Information

It is the Bank’s policy not to reveal specific information about customer accounts or other nonpublic personal information to unaffiliated third parties for their independent use, except for the exchange of information with reputable information reporting agencies to maximize the accuracy and security of such information or in the performance of bona fide corporate due diligence or business matter, unless (1) the information is provided to help complete a customer initiated transaction; (2) the customer requests or permits it; (3) the disclosure is required by or allowed by law (e.g., subpoena or investigation of fraudulent activity, request by regulator, etc.).

Maintaining Customer Privacy in Business Relationships with Third Parties

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

Information About Former Customers

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 also will not disclose nonpublic personal information about former customers.

Our Internet Web Site

Visitors to the Bank Web site remain anonymous. We do not collect personal identifying information about site users, unless you choose to provide such information to us. Visitors should, however, keep in mind that e-mail is not necessarily secure against interception. If you are not comfortable with the level of privacy, please use the reset button in on-line forms, or cancel an e-mail before it is sent. Visitors should call the Bank if requests or statements include sensitive or private information, such as your account numbers, credit card numbers or social security number. The Bank will NEVER ask you for your Personal Identification Number (PIN) for your Northwoods Bank of Minnesota ATM card or other Northwoods Bank of Minnesota card or your password for Online Banking or Telephone Banking. If you are asked for this information, please call 1-800-450-2265 or email us at: customerservice@northwoodsbank.com to report it to a customer service representative immediately.

Providing Privacy Information to Customers and Responding to Inquiries

At Northwoods Bank of Minnesota, we value our customer relationships. We want you to understand how we use the information you provide and our commitment to ensuring your personal privacy. If you have any questions about how Northwoods Bank of Minnesota protects your confidential information, please call your local Northwoods Bank of Minnesota office or contact us at our e-mail address.

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