VCCU PRIVACY POLICY

The public and non-public information of the members of this Credit Union shall be managed to maintain a meaningful balance between the needs of the members and sound financial management.  It is the purpose of this policy to establish guidelines and directions for the gathering, storage, protection, and dissemination of that information.

The main function of the Credit Union is to provide financial services to its members.  Loan demand and deposit servicing requires the gathering of both public and non public information from the members.  This information is gathered from various sources, the member (loan applications, membership cards, and other forms), information about the members transaction accounts with us or our affiliates, consumer reporting agencies, information obtained when verifying information from applications and other forms,  and outside agencies contacted for the purpose of obtaining information to establish and process the types of transactions requested by the members.  Access to the non public information gathered will be restricted to those employees that need to know the information to provide products and services to the members.

The following are examples of information collected about the membership: name, address, age, gender, telephone number, social security number, e-mail address, mothers maiden name, share numbers, share balances, loan numbers, loan balances, checking history, credit histories, etc.

The information may be disclosed to the following types of third parties: Financial service providers (insurance companies, mortgage service companies, and securities broker-dealers), Non-financial companies (consumer reporting agencies, data processors, check/share draft printers, financial statement publishers, plastic card processors, and government agencies).  Information may also be shared with our affiliate Vermillion Financial Services to offer products and services to meet member needs, as permitted by law.  In addition we may share information with companies that perform marketing or other services on our behalf or to other financial institutions with which we have joint marketing agreements (that agree to maintain strong confidentiality protections, can not sell the information and limit the use of the information provided) so that we may provide members competitive products and services.

We will disclose the information collected as described above and as permitted by law.

The Credit Union will maintain physical, electronic and procedural safeguards that comply with federal regulations to guard the non public personal information gathered about the members.

2-19-09