This notice is provided by the following companies within the National Penn family.
NATIONAL PENN BANCSHARES, INC. AFFILIATES:
• National Penn Bank and Divisions
– HomeTowne Heritage Bank, KNBT, and Nittany Bank
• Christiana Bank & Trust Company and Subsidiaries
– Christiana Corporate Services, Inc. and Subsidiary
– Monarch Management Services, LL
– Christiana Trust Company, LLC
– CBTD, LLC
– Christiana OREO, LLC
• National Penn Life Insurance Co.
• National Penn Investment Company
NATIONAL PENN BANK AFFILIATES
• National Penn Investors Trust Company and marketing name
– National Penn Investment Services
• Institutional Advisors LLC
• National Penn Capital Advisors, Inc. and Division
– Resources for Retirement, Inc.
• National Penn Insurance Agency, Inc.*
• Caruso Benefits Group, Inc.
• Higgins Insurance Associates, Inc., d/b/a
– Higgins Insurance
• Vantage Investment Advisors, LLC
• National Penn Leasing Company
• KNBT Settlement Services, d/b/a
– KNBT Abstractors
– Traditions
• Link Financial Services, Inc. and its Subsidiary
– Link Abstract, LP
• Laurel Abstract Company
• DFM Realty, Inc.
• National Penn Management Services, LLC
• NPB Delaware, Inc.
*Your account may be with an insurance company that is serviced through National Penn Insurance Agency.
In order to ensure that everyone receives a copy of this customer privacy notice as required, you may receive more than one copy. Thank you for choosing National Penn. If you have questions or would like more information, please call our customer service center at 1.800.822.3321 or visit us online at www.natpennbank.com.
OUR COMMMITMENT TO YOU
National Penn Bancshares, Inc. (“National Penn”) is committed to providing you and your family with financial products and services to meet your needs and your family’s financial goals. We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interests. Because we respect that your personal and financial data is your private information, we hold ourselves to high standards in its safekeeping and use.
We want you to know that we do not sell customer information. Instead, your information is used by us primarily to complete transactions that you request or to make you aware of other financial products and services that we would like to offer you.
The purpose of this notice is to explain how we collect, use and safeguard your personal financial information.
You may have other privacy protections under state laws. We will comply with them with regard to our information practices.
INFORMATION WE COLLECT ABOUT YOU
We may collect "nonpublic personal information" about you from the following sources:
- Information we receive from you on applications or other loan and account forms, such as your name, address, social security number, assets and income;
- Information about your transactions with us, our affiliates or others, such as your account balance, payment history, parties to transactions and credit card usage;
- Information we receive from credit reporting agencies, such as your creditworthiness and credit history; and
- Information we receive from your internet usage when you visit our web sites.
“Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial product or service to you. For example, nonpublic personal information includes information regarding your account balance, payment history and overdraft history.
In this privacy notice, the words “you” and “customer” are used to mean any individual who obtains or has obtained a product or service from National Penn that is to be used primarily for personal, family or household purposes.
This notice also applies to former customers, and to consumers who have provided information to us but have not entered into a customer relationship, for as long as information is retained.
INFORMATION WE MAY DISCLOSE
To assist us in providing products/services you have requested, we may disclose information we collect about you, as described above, to our affiliates and third party financial service providers. Such information may be shared for purposes including mortgage and account servicing, and payment and data processing services.
- To Provide Information About Products/Services
To provide you with information regarding financial, insurance, investment and other products/services that may be of interest to you, we may disclose information we collect about you, as described above, to our affiliates and third parties. These companies may be financial service providers (such as brokers and insurance agents) or non-financial companies (such as marketers) with whom we have joint marketing agreements. We do not provide account numbers for marketing purposes.
We may disclose certain information about you to selected credit reporting agencies and when we are otherwise legally required to do so (such as in response to a subpoena), to prevent fraud, or to comply with a legally permitted inquiry by a government agency or regulator.
RESTRICTIONS ON DISCLOSURE OF NON-PUBLIC, PERSONAL HEALTH INFORMATION
National Penn does not disclose your non-public, personal health information to non-affiliated third parties (including government agencies) or our affiliated companies, except as authorized by you or to perform insurance functions (for example, obtaining an insurance policy or administering an insurance claim) as allowed by and in accordance with applicable law.
SHARING WITHIN THE NATIONAL PENN FAMILY
National Penn is made up of a number of companies, called affiliates, that work together to bring you the financial products/services you want and expect. We are permitted under law to share information about our experiences or transactions with your or your account (such as balance and your payment history with us) with companies related to us by common control or ownership ("affiliates.")
We are also permitted under law to disclose nonpublic personal information about you to "nonaffiliated third parties" (i.e., third parties that are not members of our corporate family) in certain circumstances. For example, we may disclose nonpublic personal information about you to such third parties to assist us in servicing your loan or account with us; to government entities in response to subpoenas; and to credit bureaus. We do not disclose any nonpublic personal information about you to any other third parties, except as permitted by law.
We may disclose all of the information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements.
Otherwise, we do not share customer information with outside companies for purposes of selling their products and services to you. We do not sell "customer lists" to outside companies.
OPT-OUT CHOICES
You have two choices regarding affiliate credit sharing and affiliate marketing:
- Affiliate Credit Sharing Opt-Out:
The Fair Credit Reporting Act gives you the right to request us not to share certain credit information (such as specific information on your credit report), other than as permitted by law, with our affiliates.
- Affiliate Marketing Opt-Out:
Federal law gives you the right to limit some but not all marketing from our affiliates and requires us to give you this notice to tell you about your choices to limit Marketing from our affiliates. You may limit our affiliates in the National Penn family of companies, such as our insurance, securities, or trust affiliates, from marketing their products or services to you based on your personal information that we collect and share with them. This information is that which National Penn has on file such as details about your income or financial status, payment credit or account history.
You may opt out of one or both of the choices above. You may opt out at any time. If you previously opted out of one or both of the choices, you do not need to do so again, even if you have a closed account, as your choices will apply until you tell us to change your selection.
To out out, you may call us at 1.800.822.3321. You will need to provide your full name, address, social security number and telephone number and your opt-out selection choice. Note that opt-outs will take effect as soon as reasonably practicable, generally within a 30 day time period from the date your opt out is recorded.
JOINT ACCOUNTS
Each person may separately make privacy choices, and joint account holders may make privacy choices for each other. If only one joint account holder makes a privacy choice, that preference is applied to the entire account.
PROTECTING YOUR PRIVACY
We do not sell customer lists or individual customer information. We do not disclose any information about our customers, or former customers, to anyone, except as permitted by law. Any information we disclose comes from the sources described above and may include, among other things, your name, address and telephone number. We restrict access to your information to those employees who need to know that information in order to provide products/services to you, or to affiliates and other third parties for the purposes described previously. We require all companies with whom we share your information to keep it confidential and they may only use your information for the products/services requested or as permitted by law.
We have established a set of internal controls and procedures to maintain the confidentiality of your information in accordance with our policies, to maintain the accuracy of your information and to keep such information current and complete. We also provide you with various sources of account information, including account statements, telephone banking, on-line banking, and electronic banking. If at any time you discover that any of your information is inaccurate, outdated, or incomplete, please call or write us at the telephone number or address listed on your account statement, bank records, or other documentation. We investigate customer inquiries or notifications regarding inaccurate information fully and promptly.
INVESTMENT AND TRUST RELATIONSHIPS
We recognize and acknowledge that all our clients have high expectations of privacy regarding account relationships they maintain with any of our companies within the National Penn Family. Accordingly, other than non-financial information recorded on our internal records to recognize you as our client, your nonpublic information is not shared with any third party unless it is required in the course of properly servicing your relationship or as required by law. Please contact your relationship manager if you have any questions regarding the privacy of your information.
RESTRICTIONS ON DISCLOSURE OF NON-PUBLIC PERSONAL HEALTH INFORMATION
We do not disclose your non-public personal health information to non-affiliated third parties (including government agencies) or our affiliated companies, except as authorized by you or to perform insurance functions. (For example, obtaining an insurance policy, or administering an insurance claim), as allowed by and in accordance with applicable law.
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Thank you for choosing National Penn. If you have questions or would like more information, please call our customer service center at 1.800.822.3321.
Dated June 2009
