Privacy Policy

Guaranty Bank (which does business in Michigan under the trade name "BestBank") and its subsidiaries, collectively "Guaranty", understands that we receive private, personal information about our customers that they expect will be treated confidentially ("Nonpublic Personal Information"). We believe that we have an affirmative and continuing obligation to respect and protect the privacy of all our customers by maintaining the confidentiality of this information. Guaranty has implemented this privacy policy (the "Policy") to govern the management of our customer's Nonpublic Personal Information, including information provided to us on our Internet websites.

Basic Principles

We respect our current and former customer's right to keep all personal information confidential and secure from fraud.

We collect and retain personal information only if allowed by law and do not sell Nonpublic Personal Information to any Nonaffiliated Third Parties (defined below) for any purpose.

We only disclose Nonpublic Personal Information about a customer to Nonaffiliated Third Parties in limited circumstances as permitted by law.

We do not disclose account numbers to any Nonaffiliated Third Parties for telemarketing, direct mail marketing or electronic mail marketing.

We have established standards and procedures to insure the security and confidentiality of customer records, to protect against any anticipated threats or hazards to the security or integrity of customer records, and to protect against unauthorized access to or use of customer records which could result in substantial harm or inconvenience to the customer.

We educate and train our employees on the importance of confidentiality and customer privacy.

Types of Information Collected

The following is a list of the types of Nonpublic Personal Information we may collect:

Any information a customer provides to us on an application to obtain a loan, an account, a credit card, or other financial product or service.

• Account numbers, account balance information, payment history, overdraft history, and credit or debit card purchase information.
  
• The fact that an individual is, or has been, a customer of ours or has obtained a financial product or service from us.
  
• Any information about a customer that indicates that the individual is, or has been, a customer of ours.
  
• Any information that a customer provides to us or that we or our agent obtain in connection with collecting on or servicing a loan.
  
• Any information we collect through an Internet "cookie" (an information-collecting device from a Web server).
  
• Information from a consumer credit report. 

Disclosure of Nonpublic Personal Information

We may share Nonpublic Personal Information among Affiliates subject to federal and state laws. Affiliate means any company that controls, is controlled by, or is under common control with Guaranty.

Affiliates include our subsidiaries: GN Mortgage LLC, Shelter Mortgage Company LLC, and GB Home Equity LLC and the various d/b/a's used by these companies. 

Nonpublic Personal Information may be shared with Nonaffiliated Third Parties as permitted by law. Nonaffiliated Third Party means any person except an Affiliate of ours and a person who is employed jointly by us and any company that is not our Affiliate. 

All contracts we enter into with Nonaffiliated Third Parties pursuant to a joint marketing agreement shall contain a confidentiality provision prohibiting the disclosure and reuse of Nonpublic Personal Information. 

The Nonpublic Personal Information of former customers is treated in the same manner as the Nonpublic Personal Information of current customers.

Why Information is Shared

We only share Nonpublic Personal Information when we believe such sharing will benefit our customers, within the limits set forth above. This includes sharing information in order to provide our customers with the best products and services possible, as well as in order to make our customers aware of new products and services that may be of interest to them.

Notice of Policy

A notice of this Policy will be provided to:

1. All Guaranty customers no later than when a customer relationship is established and at least annually throughout the duration of the customer relationship.
   
2. All consumers (an individual who seeks to obtain a financial product or service from the financial institution, but had not yet established a customer relationship) if Guaranty is going to disclose his or her Nonpublic Personal Information with a Nonaffiliated Third Party. A consumer includes an individual who may provide information when inquiring about a service or product from Guaranty or an individual who uses a Guaranty Bank ATM.
   
3. All employees of Guaranty.