BLUE DIAMOND’S COMMITMENT TO ITS CUSTOMERS

BLUE DIAMOND recognizes and respects the privacy expectation of each of its customers. BLUE DIAMOND believes that the confidentiality and protection of its customers’ non-public personal information is one of its fundamental responsibilities. This means, most importantly, that BLUE DIAMOND does not sell customers’ non-public personal information to any third parties. BLUE DIAMOND uses its customers’ non-public personal information primarily to complete financial transactions that its customers request or to make its customers aware of other financial products and services offered by a BLUE DIAMOND affiliated company.

INFORMATION BLUE DIAMOND COLLECTS ABOUT ITS CUSTOMERS

BLUE DIAMOND collects non-public personal information about its customers from the following sources:

• Account Applications and Other Forms, which may include a customer’s name and address, social security number or tax identification number, total assets, income, and accounts at other institutions;
• Account History, which may include information about the transactions and balances in accounts with BLUE DIAMOND; and
• Correspondence, which may include written, telephonic or electronic communications.

HOW BLUE DIAMOND HANDLES ITS CUSTOMERS’ FINANCIAL INFORMATION

As emphasized above, BLUE DIAMOND does not sell non-public personal information about current or former customers to third parties. Below are the details of circumstances in which BLUE DIAMOND may disclose non-public personal information to third parties:

• In order to complete certain transactions or account changes that a customer directs, it may be necessary to provide certain non-public personal information about that customer to companies, individuals, or groups that are not affiliated with BLUE DIAMOND. For example, if a customer asks BLUE DIAMOND to transfer assets from another financial institution, BLUE DIAMOND will need to provide certain non-public personal information about that customer to the company to complete the transaction.
• In order to alert a customer to other financial products and services that a BLUE DIAMOND affiliated company offers, BLUE DIAMOND may share non-public personal information it has about that customer with a BLUE DIAMOND affiliated company.
• In certain instances, BLUE DIAMOND may contract with non-affiliated companies to perform services for BLUE DIAMOND. Where necessary, BLUE DIAMOND will disclose non-public personal information it has about its customers to these third parties. For example, BLUE DIAMOND may provide non-public personal information about a customer’s separate account to a qualified brokerage firm in order to enter into futures transactions. In all such cases, BLUE DIAMOND will provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose. In addition, BLUE DIAMOND requires these third parties to treat BLUE DIAMOND customers’ non-public information with the same high degree of confidentiality that BLUE DIAMOND does.
• Finally, BLUE DIAMOND will release non-public information about customers if directed by that customer to do so or if BLUE DIAMOND is authorized by law to do so.

HOW BLUE DIAMOND SAFEGUARDS ITS CUSTOMERS’ PERSONAL INFORMATION

BLUE DIAMOND restricts access to information about customers only to those employees who require that information to provide financial products and services to that customer. BLUE DIAMOND maintains physical, electronic, and procedural safeguards that comply with federal standards to guard its customers’ non-public personal information.

KEEPING ITS CUSTOMERS INFORMED

BLUE DIAMOND reserves the right to modify this policy at any time, but in the event that there is a change, BLUE DIAMOND will promptly inform its customers of that change.