PRIVACY POLICY STATEMENT

AN IMPORTANT MESSAGE CONCERNING YOUR PERSONAL INFORMATION
The trust and confidence of customers is very important to Ponce De Leon Federal Bank. The Bank is committed to protecting the information provided to it. This includes information received from you online as you communicate with the Bank when visiting the website or conducting transactions through the Internet banking system as well as in person. Ponce De Leon Federal Bank has established specific procedures for collection, security use and retention of your non-public information.

Protecting your Privacy
A SERVICE YOU CAN COUNT ON
Ponce De Leon Federal Bank, since its founding, has been careful to maintain the highest level of privacy and confidentiality of our customers’ personal information. When you provide us with personal information we know you also give us your trust:

• Trust that we will safeguard your privacy rights.
• Trust that we know how to respect those rights while utilizing this information for your financial well being.
• Trust that is the cornerstone of our business.

We want to thank you for your trust and assure you it is well founded.

Our Privacy Commitment
We start with this promise:

1. We collect, retain and use information about individual customers only where we reasonably believe such practices will be useful and allowed by law. We believe such practices are useful if they assist in administering our business, serving your needs and protecting your assets.
 
2. We have established procedures to assure that information you provide is accurate, current and complete in accordance with reasonable commercial standards. Part of this process includes responding to your requests to correct inaccurate information in a timely manner.
 
3. We limit employee access to personally identifiable information to those with a business reason for knowing such information.
 
4. We educate our employees so that they will understand the importance of confidentiality and customer privacy. This includes taking appropriate disciplinary measures to enforce employee privacy responsibilities.
 
5. We maintain appropriate security standards and procedures regarding unauthorized access to customer information. This includes maintaining physical, electronic and procedural safeguards that comply with Federal standards to guard your nonpublic personal information.
 
6. If personably identifiable customer information is provided to a third party, we insist that the third party adhere to similar privacy principles that provide for keeping such information confidential.

7. We believe communication with you is important too. Therefore, we have put in place methods of providing you with an understanding of our privacy policies. For your own well-being, we encourage you to be concerned about financial privacy, how we help you achieve it, and how you can safeguard it. This is one of the reasons why we are providing you this information now. Please do read on and contact us with any questions or additional concerns you may have.

Implementing Our Privacy Commitment
In General

We do not reveal specific information about your accounts or other nonpublic personal information to nonaffiliated third parties for their independent use, with these major exceptions:

1. To exchange information with reputable consumer credit reporting agencies
2. To maintain our overall standards of performing in a prudent manner
3. To help complete a transaction initiated by you
4. When you request us to disclose such information to a third party
5. The information is required and allowed to be provided law, including judicial process

By nonpublic personal information we mean personally identifiable financial information; and any list, description, or other grouping of consumers (and publicly available information pertaining to them) that we derive using any personally identifiable financial information that is not publicly available. By personally identifiable financial information we mean any information that (a) a consumer provides to us to obtain a financial product or service from us; (b) about a consumer resulting from any transaction involving a financial product or service between us and a consumer; or (c) we otherwise obtains about a consumer in connection with providing a financial product or service to that consumer.

By publicly available information we mean any information that we have a reasonable basis to believe is lawfully made available to the general public from: (a) Federal, state, or local government records; (b) widely distributed media; or (c) disclosures to the general public that are required to be made by Federal, state, or local law.

Products and Services Covered

This notice applies to nonpublic personal information we obtain about you related to our deposit and loan products — for example, when you open an account or apply for a loan. It also covers nonpublic personal information we obtain through providing other services, such as safe deposit or the purchase of travelers checks.

Information We Obtain About You
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, our affiliates, or others;
and
• Information we receive from a consumer reporting agency.
 
If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

Information We Are Permitted to Share About You

We are always permitted by law to share specific information about your accounts or other nonpublic personal information about you under the following circumstances:

1. To exchange information with reputable consumer credit reporting agencies.
2. To maintain our overall standards of performing in a prudent manner.
3. To help complete a transaction initiated by you.
4. When you request us to disclose such information to a third party.

We also may share all of the information we collect to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.

A nonexhaustive listing of information we might share under the situations described above includes:

Information we receive from you:

Address
Phone number
Social security number

Information we receive from other parties:

Assets and/or income
Account balance
Payment history
Parties to transactions
Credit card usage

Information we receive from consumer reporting agencies

Credit record
Credit history

Who We Do Not Share Information With

As a matter of both policy and routine operating procedure, we do not share or disclose nonpublic personal information about our customers or former customers with any nonaffiliated third party (an organization not owned by our parent company), except as permitted by law. While we believe this is the best way is assure protection of your financial privacy, you should know that unless you specifically direct us to, or unless required by law, we will not provide any of the nonpublic information we collect about you to any non-affiliated third party (see Information We Are Permitted to Share About You above).

In Other Words…
Your Right to “Opt Out” Is Automatic With Us

Consumers always have the right to direct that a financial institution such as ours not disclose nonpublic personal information about you to nonaffiliated third parties (other than disclosures permitted or required by law). However, we take this opportunity in explaining our policy to emphasize that there is no need for you to make such an election. We will not share nonpublic personal information about you with any nonaffiliated third party, unless you specifically direct us to, or unless permitted or required by law.

Identity Theft

If you suspect identity theft or you’re concerned that someone has unauthorized access to your personal information, call the Bank, immediately at 1-718 931-9000. We will take steps to help protect you. You should also consider reporting your concerns to:

• Your local law enforcement officials
• The Federal Trade Commission identity theft hotline at (877) ID-THEFT
• The Social Security Administration fraud hotline at (800) 269-0271
• Your credit card companies. Remember, knowing where to find your credit card information and toll-free contact numbers will help in an emergency.
• National credit reporting organizations that can place a fraud alert on your name and Social Security Number: Equifax: (800) 525-6285
Experian: (888) 397-3742 Trans Union: (800) 680-7289

Internet Banking

Website Privacy

The non-public personal information you provided to the Bank through the Website is afforded the same level of confidentiality and restrictions as provided for your other non-public personal information. Ponce De Leon Federal Bank has engaged technology experts to protect your transactions and information, keeping them private and secure as you use the Website.

Electronic Transactions

Ponce De Leon Federal Bank complies with the federal requirement for secured electronic transactions and accordingly uses 128-bit encryption. In addition, your information is constantly protected though specially contracted data security companies.

Customer's Role

The Bank is sure that you value the confidentiality and security of your information. That is why it is suggested that you make a special effort to protect your user identification (ID) and password by: (i) Signing off from the Internet immediately after each use. (ii) Keeping your ID and password secured and confidential. (iii) Frequently changing your password.

Cookies

To provide better security, Ponce De Leon Federal Bank may use cookies as part of its Internet connection with you. “Cookies” are small text files placed on your hard drive by some web servers and can only be read by the server that sent the cookie. Cookies cannot be used to access information on the hard drive or activities on other web sessions. The Bank’s web server creates a cookie to facilitate Internet banking activity for each session. The cookie stores certain customer information while the session is in process; however, the Bank does not collect information through the use of cookies.

Website Caution

Ponce De Leon Federal Bank recommends that you use caution when using “consolidation sites.” Consolidation sites are Internet sites that offer you the ability to collect all of your personal information on one site. This information would include your personal financial information, web site password, electronic and online banking passwords, and other such information. Do not provide this information unless you are absolutely confident that the site is one you know, have researched, and trust completely. Any transaction initiated by a consolidated site using information you have provided is considered to be authorized by you, whether or not you are aware of the transaction or authorized it. If you have used a consolidation site, and wish to terminate this authority, you must contact the Bank to block your account and issue a new user ID and password.

Links to Other Sites

Ponce De Leon Federal Bank Website contains links that allow you to access other Websites while you are within the frame of our Website. The Bank cannot control these links and therefore cannot provide you with assurances regarding their security and privacy practices. Please check the websites of these links for their own security and privacy practices.

Accuracy of Your Information

Ponce De Leon Federal Bank is committed to maintain accuracy of customer information. If you are aware of any inaccurate information at Ponce De Leon Federal Bank call 1- 718-931-9000. The Bank will investigate and promptly make any required corrections. You are also entitled to request a copy of your credit report from credit reporting agencies and to have them investigate and correct any inaccuracies contained in their report.

The information contained in this notice is intended to be accurate, reliable and comply with appropriate law and regulation. It is not intended to be legal or financial advice. For such advice, please contact the appropriate professional.