Privacy & Security
The following policy serves as a standard for all employees at Middleburg Trust Company (MTC) for collection, use, retention, and security of nonpublic personal information.
What Information We Collect
We may collect “nonpublic personal information” about you from the following sources:
- Information we receive from you on applications for loans or deposit accounts, securities forms, and other oral or written communications;
- Information about your transactions with us, or our affiliates, or others; and
- Information we receive from third parties, such as credit bureaus.
“Nonpublic personal information” includes 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 accounts with MTC’s subsidiaries, including loan balance, payment history, account balance, overdraft history, and portfolio or trust holdings values. We call this “Transactional Information.
Disclosure of Information to Third Parties
We do not disclose any nonpublic personal information about you to anyone, except as required or permitted by law or described below. For example, we may disclose information about you to third parties to assist us in servicing your loan(s) or account(s) with us, to government entities in response to subpoenas, and to credit bureaus. In addition, we may disclose the information we collect about you described above to companies that perform marketing services on our behalf and to financial institutions for the purpose of jointly offering financial products and services to you. These companies are contractually required to adhere to our strict standards of information security and confidentiality.
We have never in the past sold, nor do we plan to sell, any nonpublic personal information to third parties.
If you decide to close your account(s) or become an inactive client, we will continue to adhere to the privacy policies and practices described in this notice.
Information Shared within our MTC organization
As permitted by law, MTC and its affiliates share Transactional Information with each other. Unless you tell us not to do so, we may also share other information about you within our MTC corporate family for various purposes, such as offering you other products and services or opportunities made available by our subsidiaries or affiliates. This other information includes the following:
- Information we obtain from your applications, financial statements, brokerage statements or other forms, such as income, assets, liabilities, securities holdings, and employment history.
- Information we obtain from a credit bureau, such as credit history.
- Information we obtain from others to verify information provided by you, such as your credit or other relationships with third parties.
Subsidiaries or affiliates in the MFC corporate family that may receive this information are all financial services companies mentioned above, including without limitation, our bank, investment companies, trust company, insurance company, and mortgage company.
Such information sharing relieves our clients of the burden of providing duplicate information each time that they apply at any of our subsidiaries or affiliates for a new product or service. In addition, sharing information allows the members of the MFC corporate family to develop and enhance products and services to offer a competitive range of products and services to our clients. Members of MTC will only share information for legitimate business purposes with the goal of providing our clients with convenience and more choices.
How to Tell Us Not to Share this Information within our Corporate Family
If you ask us not to share such information within MTC, you might miss out on information about financial products and services offered by one of these companies that might be of benefit to you.
If you prefer that we not share such application information, financial statement information and credit-related information with companies within our MFC corporate family, you may direct us not to share (opt out) by calling us at 1-877-369-5200 between the hours of 8:00 a.m. and 5:00 p.m., ET, Monday through Friday. Please be prepared to provide your account numbers and your social security number so that we can process your request as soon as we reasonably can. Once you direct us not to share such information, the opt out will remain in effect until you notify us otherwise.
Your opt out only applies to such application, financial statement and credit-related information. As permitted by law, we can continue to share Transactional Information within our MTC corporate family.
For joint accounts, held by two or more consumers, one accountholder’s exercise of the right to opt out will be treated as an opt-out for all of the joint accountholders with respect to that joint account. For example, if Tom and Kate have a joint account, Tom’s direction will apply to Kate regarding their joint account, but not to Kate’s individual accounts or accounts that she may hold jointly with another consumer.
Our Security Procedures
We maintain physical, electronic, and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information. Our employees are bound by our Code of Conduct and policies to limit access to consumer information for business purposes only and keep your personal information confidential.