Banking Disclosure

RATIONALE FOR COLLECTION

Personal information is collected to enable us to provide products and services to you and to improve and conduct our business. For example, we collect personal information to:

• Help us better evaluate your financial needs

• Process your requests and transactions more efficiently

• Keep you informed about new and existing products and services that may be of interest to you

• Ensure that you are provided with effective and efficient customer service

• Assess the quality of our products and services

SOURCES OF INFORMATION

We collect information on you from a variety of sources, including:

• Account applications and other forms that you submit to us, which provide information such as your name, address, email address, telephone number, date of birth, occupation, financial goals, assets and income

• Your transactions

• Banks and other financial institutions to confirm information that you have provided to us, particularly in the process of evaluating applications for loans

• Other information submitted to us by you or a third party authorized by you to provide such to us on your behalf for the conduct of business with us.

TYPES OF INFORMATION COLLECTED

We will limit the collection, use and retention of your information to what we believe is necessary to provide you with exceptional quality service, comply with regulatory requirements, and make available to you other products, services, and opportunities that may be of interest to you. For example, your information may be used to evaluate your eligibility for a loan or other service, to improve our products and services or the way we deliver them to you, or to protect you from fraud. The information that we collect is limited to the following:

• Identification information such as names, address, telephone number, social security number etc.

• Application information such as assets, income, debt, etc.

• Transaction and experience information such as balance, payment history, account usage, etc.

• Historical Information from other sources such as employment history, credit history, etc.

• Compliance information – we collect information that may be required to ensure compliance with the laws of St. Kitts & Nevis such as the Anti-Money Laundering Regulations 2011.

DISCLOSURE OF INFORMATION

We will only disclose your personal information under the following circumstances:

• So that you may be informed of other products and services.

• In order to verify or complete a transaction.

• To verify the existence and condition of your account at another financial institution.

• To a third party performing a function on behalf of the NCCU.

• To comply with any law, regulation or an order of the Court.

• If you or any authorized person on the account gives us written permission to do so.

ACCESS TO PERSONAL INFORMATION

Only those employees who need to have access to your personal information to perform their jobs are given the access to your personal information. They may need access to your personal information to conduct business on your behalf, service your account, help you and your Financial Advisor pursue your financial objectives, and to conduct our business.

PROTECTION OF PERSONAL INFORMATION

The NCCU is committed to securing your personal information. We maintain your personal information and data according to strict standards of security and confidentiality.

We have ensured that employees who have access to your personal information maintain and protect the confidentiality of that information and must follow established procedures. Additionally, employees are required to acknowledge their responsibility to maintain the confidentiality of customer information through an oath of secrecy.

When we use other institutions and business to provide services for us, we require them to protect the confidentiality of personal information. They are required to sign a legally binding agreement which limits their use of the personal information of account holders.

We also maintain physical, electronic and procedural safeguards that meet required standards to protect your personal information from unauthorized use, inclusive of the installation of firewalls, monitoring of our systems and other security enhancements.

Notwithstanding the above, protection of your personal information is a shared responsibility. You have a critical role to play in this process. The following are some steps that you can take to assist our efforts to protect your information:

• Review your monthly account statements thoroughly and report any suspicious activity immediately.

• Report lost or stolen checks or your ATM card immediately.

• Do not pre-print your signature on checks.

• Safeguard your ATM card and check book.

• Memorize PINS (Personal Identification Numbers) and refrain from writing them down because you may lose them or leave them in a place that can be found by someone else.

• Do not share your PIN or passwords with anyone.

• Before you reveal any personally identifying information, find out how it will be used and whether it will be shared with others.

• If you believe that you have been a victim of identity theft or fraud, immediately contact the NCCU.

SHARING INFORMATION WITH NONAFFILIATED THIRD PARTIES

We are firm in our commitment that we will not rent or sell your personal information to any third party. However, we may share your personal information with institutions and businesses that we hire to perform services for us, such as vendors that provide data processing, computer software maintenance and development, transaction processing and marketing services. We assure you that any entity+ with whom we share your information agree to limit the use of such information to the purpose for which it was provided through the use of a duly signed legally binding confidentiality agreement.

Finally, we may disclose personal information to others, including non-affiliated businesses and regulatory authorities, as either required or permitted by applicable law. For example, we may disclose personal information to:

• Comply with investigations by regulatory authorities or law enforcement agencies

• Protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liabilities

HOW CAN YOU OPT OUT OR STOP DISCLOSURES ABOUT YOU

At this time, we do not intend to disclose the personal information of customers other than as noted above. If in the future, the NCCU is required to disclose the personal information of account holders other than the above, the NCCU will provide an additional notice, and provide an opportunity to affected account holders to opt out if applicable. The “opt out” option does not apply to disclosures that are legally permitted or required or to disclosures that the NCCU makes to companies that perform services on our behalf or to other financial institutions.

ACCESSIBILITY OF YOUR PERSONAL INFORMATION

We will give you access to the information we have about you. It is your right.

Most of this information is in the form of your transaction records. These are available to you through your account statements or passbook updates, by visiting the office, by the ATM machine or via the NCCU’s website.

If you require other information, simply contact or forward a written request to the office. We will ask you for specific details such as your account number. We will advise you in advance if a minimal charge will be required for conducting the search, and we will respond to your request within 5 working days.

Please note that we may not be able to provide information about you from those parts of our records which may contain references to other persons, are subject to legal privilege, contain confidential information proprietary to NCCU, relate to an investigation of a breach of agreement or contravention of laws, or cannot be disclosed for other legal reasons.

If you have any questions regarding decisions made about you, we will tell you the reasons for those decisions. Where relevant, we will provide you with the name and address of the third party from which a report was obtained.