Primary Financial Company LLC ("Primary Financial") is one of the nation's
largest providers of certificate of deposit services and it is committed to providing
competitive and innovative products and services for the success of credit unions.
In fulfilling its mission, Primary Financial has access to nonpublic personal information
about its customers. Primary Financial values the protection of personal information
and its use in a confidential manner, consistent with the requirements of its customers.
Primary Financial takes every reasonable precaution to protect the accuracy and
integrity of nonpublic information. Primary Financial restricts access to nonpublic
information to employees with a specific business purpose for use of the information.
Primary Financial has established security procedures and security levels controlling
employee access, as well as physical and electronic safeguards, which comply with
existing regulations and which conform with standard industry practices to safeguard
Information is the cornerstone of Primary Financials ability to provide superior
service and its most important asset is its customers' trust. Keeping customer information
secure, and using it only as the law will permit, is a top priority for Primary
Primary Financial's policy is to satisfy all laws and regulations concerning the
use and disclosure of nonpublic personal information about its corporate customers
and their customers, and its corporate co-agents and their customer credit unions
and their members, including the Securities and Exchange Commission Privacy Regulation,
17 C.F.R. Part 248 (the "SEC Privacy Regulation"). Under the SEC Privacy
Regulation and other similar regulations, Primary Financial is limited in the manner
it may use or disclose the nonpublic personal information it receives about the
customers of its corporate customers and members of its customer credit unions.
Primary Financial pledges to abide by these limitations.
Primary Financial collects nonpublic personal information about its natural person
customers from the following sources: information received on application forms
or other forms; and information about the customers transactions with Primary
Financial, its affiliates, or others.
Primary Financial does not disclose any nonpublic personal information about customers
and former customers to anyone, except as permitted by law. Primary Financial may
disclose all of the information it collects as described above to companies that
perform marketing services on its behalf or to other financial institutions with
whom it has joint marketing agreements.
Primary Financial restricts access to nonpublic personal information about its natural
person customers to those employees who need to know that information to provide
products or services. Primary Financial maintains physical, electronic, and procedural
safeguards that comply with federal regulations to guard the nonpublic personal
information of its natural person customers.