Children's Online Privacy Protection Act

1. Introduction

The Children's Online Privacy Protection Act (COPPA) and the Federal Trade Commission's implementing regulations at 16 C.F.R. Part 312 establish a number of requirements applicable to operators of covered web sites and online services directed at children under thirteen.

2. Policy

The Morrill & Janes Bank and Trust Company will not operate a web site targeted to children under thirteen and makes that disclosure in it's Internet Privacy Policy.

Internet Privacy Policy

When you visit our website to view any pages, read product information, or use our online calculators and tools, you do so without telling us who you are and without revealing any personal information. While we do not collect identifying information about visitors to our site, we do use standard software to collect information for the strict purpose of tracking activity on our site. This allows us to better understand how many people use our site and which pages and features are most popular. The only information we normally collect and store is:

• The name of your Internet Service Provider,
• The website that referred you to us (if any),
• The date and time the pages were accessed,
• The page or pages you requested.

There are instances where you may elect to provide us with personal information. If you fill out one of our feedback or request forms or send us e-mail, you are transmitting the information that appears to you in the form or the message. This will typically include information like your name, mailing address, e-mail address, the kind of request you are making, and any other information necessary to fulfill your request. You never transfer personally identifying information that you do not enter yourself. This is always your option; this information cannot be collected unless you specifically elect to send it to us. This information is used internally only for the purpose of fulfilling the request or for contacting you directly and is not given or sold to any other organization.

When you submit personally identifying information via one of our feedback or application forms, that information is also encrypted, or scrambled, by your browser before it is transmitted back to our website. This effectively prevents anyone from intercepting and reading any personal information about you. Note that this encryption does not take place if you send us e-mail, but only when you use your web browser with one of our site's forms.

Our website is not targeted or marketed to children.

THE MORRILL & JANES BANK AND TRUST COMPANY

Notice of Your Financial Privacy Rights

We, our , and us , mean The Morrill & Janes Bank and Trust Company.

This is our privacy notice for our customers. When we use the words "you" and "your" we mean the following types of customers:

• All of our consumer customers who have a continuing relationship with us, such as:
• Deposit account
• Loan account
• Credit card
• Safe deposit box
• Home mortgage brokerage
• All persons who use our trust department
• All former customers

We will tell you the sources for nonpublic personal information we collect on our customers. We will tell you what measures we take to secure that information.

We first define some terms.

Nonpublic personal information means information about you that we collect in connection with providing a financial product or service to you. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records.

An affiliate is a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control.

A nonaffiliated third party is a company that is not an affiliate of ours.

THE INFORMATION THAT WE COLLECT

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms
• Information about your transactions with us
• Information about your transactions with nonaffiliated third parties
• Information from a consumer reporting agency
• Information we receive through our Customer Identification Program

INFORMATION WE DISCLOSE ABOUT YOU

We do NOT disclose any nonpublic personal information about you to anyone, except as permitted by law.

THE CONFIDENTIALITY, SECURITY, AND INTEGRITY OF YOUR 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.

NONPUBLIC PERSONAL INFORMATION

AND FORMER CUSTOMERS

If you decide to close your account(s) or become an inactive customer, we will follow the privacy policies and practices as described in this notice.