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The basis of any relationship is trust, and we firmly believe your privacy should never be compromised. You have entrusted us with your business, and, for many generations, we have taken pride in honoring that pledge. We will continue to offer you the wide array of financial products and services necessary for you to achieve your financial goals, and we will do so in a highly confidential manner. Please review the following information as it pertains to your relationship with us.
“You” and “your” mean an individual (a person; not a business operator, corporation, partnership or trust, for example) who applies for, or receives a financial product or service with us for personal, family, or household purposes. “We,” “our,” “us” and “affiliate” mean the following companies that are in our corporate family: Five Star Bank and/or Five Star Investment Services, Inc. “Nonpublic personal information” means information about you that we collect because you apply for, or receive a financial product or service from us that is not publicly available.
We collect nonpublic personal information about you from the following sources:
- Information from you on account applications and other standard forms or in other ways such as your name, address, social security number, assets, type and amount of investments, expected transactions, account purpose, and income;
- Information about your transactions with us, our affiliate or others, such as your account balance; and
- Information from consumer reporting agencies, motor vehicle dealers, credit references, employers and insurance companies, such as your credit history, credit score, and information that we obtain to verify employment history or that insurance coverage is in place.
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.
We recognize and respect your expectation of financial privacy. In order to maintain the trust you have placed in us, we do not share any nonpublic personal information with nonaffiliated third parties unless you authorize or request it, or it is lawfully permitted or required.
In order to provide you with a high level of financial service, we may share all of the information we collect, as described above, to companies that perform marketing services on our behalf. Five Star Bank may share, and Five Star Investment Services, Inc. reserves the right to share, this same information with other financial institutions with whom they have joint marketing agreements.
Once you cease to have a financial product or service with us, our policy is to continue to honor the provisions contained in this Privacy Notice concerning your
nonpublic personal information.
As is consistent with our mission to provide you with superior financial products and services, we do share information with our affiliates, as permitted by law. Both affiliates are financial service providers, a bank, and a broker-dealer. Information about you that we may share with our affiliate — unless you request us not to:
- Your account history with us;
- Information we receive from you at application or on applications or other forms, such as marital status and income;
- Information from consumer reporting agencies, such as marital status, income, credit score, home ownership and home value;
- Information we obtain to verify representations made by you, such as representations concerning open lines of credit; and
- Information we obtain from a person regarding employment, credit or other relationship with you, such as your employment history. To limit marketing offers or otherwise direct us not to share this information, contact us by telephone at 877-226-5578 or in writing. Please include your name, address and social security number with your written request and mail it to the address below. If you have previously directed us not to share information, you need not notify us a second time.
Five Star Bank/Five Star Investment Services, Inc.
Attn: Opt Out Dept.
P.O. Box 227
Warsaw, New York 14569-0227
We value your relationship. We want you to know how we use the information you provide and our commitment to ensuring your personal privacy. If you have any questions about how we protect your confidential information, or about this notice, please contact your local branch office. In addition, if you believe we have compiled any incorrect information about you, including credit inaccuracies we may be reporting to consumer reporting agencies, please let us know immediately by writing to us at the following address: Five Star Bank, Attn.: Compliance Department, P.O. Box 227, Warsaw, New York 14569-0227.
Our website does not collect personal identifying information about you except when specifically and knowingly provided by you. Once you have provided personal identifying information, it will be used for the purpose as described at the point of data collection. All such information will then be subject to the provisions of our Privacy Notice.
For each visitor to our web pages, our web server automatically recognizes a user's software information, such as domain name (i.e. aol.com, msn.com), browser and operating system without identifying the user. We also aggregate information on these visits to our site that tells us such things as: how many visitors we had, what sites they came from, which of our pages they visited, how long they stayed at each site, and the total time of their visits.
The general information we collect is used to analyze and improve the content of our site. It is not shared with other organizations for commercial purposes.
If you send us e-mail, your return address will be displayed in the header we receive. We will use this information to respond to your inquiry and we will keep your message as a record of our contacts. We will not share that information with outside companies or agencies unless it is necessary for us to do so in order to respond to your e-mail or carry out a request therein, or unless we are required to so by law or court order.
A cookie is a piece of data given to a browser by a web server. We set a cookie each time you log onto NetExpress. This cookie is merely an anonymous number that identifies the user's session. It does not store any personally-identifiable information. We only use cookie technology to strengthen banking security in the following way:
While you are connected to the NetExpress site, the cookie is constantly monitored to ensure that we are communicating to the machine that logged in. If this cookie connection is interrupted (as may occur if an intruder intercepts your information), NetExpress will cancel the connection. This cookie will remain on your hard drive after you have completed your session. When you log onto NetExpress the next time, the old cookie will be replaced by a new cookie. At the end of any session, you can remove this cookie.
Because we have no way of distinguishing the age of individuals who access our website, we collect the same general information we collect from any website user as well as personally-identifiable information from individuals under the age of 14 if they provide it. If such information is received via e-mail, we will respond to the communication as warranted but only retain the information in accordance with our general information collection policy. If an individual under the age of 18 provides us with personally-identifiable information through an internet account application, the application will be declined and all related information would only be maintained as required or allowed by law.
We are not responsible for the content or the privacy policies of websites to which we may provide links.
We reserve the right to introduce new services or practices that may require a change to the provisions of this notice. We are committed to updating our Internet Privacy Notice promptly to keep you informed on how we use information you give us.
Five Star Investment Services, Inc. (FSIS) has corporate polices and procedures in place which seek to provide assurance and confidence that business continuity and contingency plans are adequate to support recovery from an unexpected disruption of our information systems and office facilities. Because Five Star Investment Services, Inc. is a wholly owned subsidiary of Financial Institutions, Inc. (NYSE: FISI) (“FII”, “the parent”) there exists considerable dependency on the parents systems and facilities and as such, FSIS’s Business Continuity Plan represents a portion of that of FII.
The following business continuity control practices are in place:
- A recovery plan designed to restore the Five Star Investment Services, Inc. environment, which includes alternative work spaces and back-up computer systems.
- The recovery plan is subject to annual review.
- Material identified as necessary to resume operations is stored at the off- site location(s) with security and environmental controls.
- A long-range plan has been developed which relates to strategic business plans.
- A regular review of capacity and resource needs is performed to update processing and storage requirements.
Our control policies, procedures, and practices have been reviewed, examined, and/or tested by internal and/or independent auditors.
This plan includes contingent facilities for trading, critical investment systems, and operating areas. In addition, alternative telecommunications are in place to provide continued communication between Five Star Investment Services, Inc. and its clients. The specific details of this plan are confidential for obvious security reasons.
We also have extensive back-up policies, procedures, and processes in place designed to direct recovery activities with minimal interruption in service if a critical system failure should occur. Precautionary measures include the back-up and storage of critical data files on a regular basis. Critical back-up media are then removed from the primary production site and stored at an off- site facility daily.
The recovery plan, policies, procedures, and practices address events ranging from small events to regional crises. Such events would include damage to or loss of single locations within our network, individual computer systems, entire facilities or data centers, and widescale disruptions which affect both our staff and facilities/systems. Five Star Investment Services, Inc. will make every effort to continue business on behalf of its clients on that same business day during any and all events, recognizing that service may be impacted for longer periods depending upon the seriousness of the event.
In the event of a disaster or business disruption, if you are unable to contact your
Financial Services Consultant, please contact the firm at 585-786-5555. The recovery and business continuity plans of Five Star Investment Services, Inc. are subject to modification without notice. Updates will be posted to Five Star Investment Services Inc. website www.five-starinvest.com and customers may request this information by contacting the number above.
Five Star Investment Services, Inc. does not guarantee that for every event or business disruption:(i) such plans will be successfully implemented; or (ii) such plans, if implemented will be sufficient and appropriate to avoid, deter, or mitigate the event or business disruption. In addition, in that Five Star Investment Services, Inc. is dependent upon various community infrastructures (e.g., transportation, telecommunications, exchanges, industry utilities, etc.), Five Star Investment Services, Inc.’s ability to implement its plans may be impacted by issues with these infrastructures.
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