Privacy Disclosure

TruNorth™ Mortgage is a division of TruNorth Bank.

Download our privacy statement mobile app supplement.

FACTS	WHAT DOES TruNorth Bank DO WITH YOUR PERSONAL INFORMATION?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security Number and Income Account Balances and Transaction History Credit History and Payment History Overdraft History When you are no longer our customer, we continue to share your information as described in this notice.
How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons TruNorth Bank chooses to share; and whether you can limit this sharing.

Reasons we share your personal information	*Does TruNorth Bank* share?**	Can you limit this sharing?
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	No
For our marketing purposes – to offer our products and services to you	Yes	No
For joint marketing with other financial companies	Yes	No
For our affiliates’ everyday business purposes – information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes – information about your credit worthiness	No	We do not share
For our affiliates to market to you	No	We do not share
For nonaffiliates to market to you	No	We do not share

Questions?

Call 855.527.4111

What We Do
How does TruNorth Bank protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. Employees are educated and required to maintain strict confidentiality of your personal information. We contractually bind third party companies or vendors to strict confidentiality with respect to any information provided.
How does TruNorth Bank collect my personal information?	We collect your personal information, for example, when you: Open an account or make deposit or withdrawals from your account Pay your bills, apply for a loan or give us your income information Show your driver’s license Use your credit or debit card We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?	Federal law gives you the right to limit only Sharing for affiliates’ everyday business purposes-information about your creditworthiness Affiliates from using your information to market to you Sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include banks and/or financial companies that are controlled by or under common control of Hometown Financial Group, Inc.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. TruNorth Bank does not share with nonaffiliates so they can market you.
Joint Marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial institutions with whom we offer investment services and credit card services.

Other important information

We adhere to Massachusetts Data Protection Law, regulation 201 CMR 17.00: Standards For The Protection Of Personal Information Of Residents Of The Commonwealth that mandates personal information be encrypted when stored on portable devices, or transmitted wirelessly or on public networks. Additionally, the regulations call on businesses to utilize up-to-date firewall protection that creates an electronic gatekeeper between the data and the outside world and only permits authorized users to access or transmit data, according to preset rules.
Children’s Online Privacy: The law requires parental consent to collect or use information from a child under 13. If you are a child under 13, please show this to your parents and do not use the online services of this institution without verifiable parental consent pursuant to the Children’s Online Privacy Protection Act.

Mobile App Supplement

TruNorth Bank’s mobile apps utilize features on your device to improve performance and help prevent fraud.
The type of information we may collect regarding your mobile device can include:

• Device settings
• Unique device identifiers
• Information about your location
• Analytical information that may assist with diagnostics and performance

Some information is collected automatically and does not require any action on your part. For your convenience, you may be asked to grant permission to access features on your mobile device, which may include but is not limited to, the following:

Permission:	Allow Access To:	Used For:
Access to external storage file	Files/media on the device	Secure message attachments
Audio	The device’s microphone	Chat
Camera	The device’s camera	Mobile remote deposit
Contacts	Contacts on the device	Person to Person Payment/Recipient List Sharing of App
Location*	Your location	Map

*Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect location data when you use the Services even when the app is closed or not in use; for example, to provide our fraud detection services. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

Opting Out of Location Tracking. If you initially consented to the collection of geo-location information through the Services, you may subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the App.

Relationship to Privacy Statement
This Mobile Privacy Policy supplements the bank’s Privacy Statement and in the event of any inconsistency between the two, the Privacy Statement shall govern.