Online Privacy Information and Use Guide

This Privacy Information, in combination with other relevant privacy notices that we provide to you, informs you of the policies and practices regarding the collection, use and disclosure of any personal information that we and our service providers collect from or about users in connection with Mobile and Internet-Based Services.

Types of Information We Collect

When you visit a Martha's Vineyard Bank's website or use mobile or internet-based services, we may collect personal information from you in the following ways: (a) Personal Information you voluntarily provide; (b) Personal Information collected from Third Parties; and (c) Personal Information collected via Technology.

The information we collect may include your full name, address, email, telephone number, social security number, account numbers, payment card identification and expiration date, verification numbers, transaction and payment histories. From third parties, the information may be provided to us by identity verification services and credit reporting agencies, including credit bureaus as a matter of course to provide services. From technology, we may also collect information about you from your online browsing and transactions, including, but not limited to, your preferences, pages visited, technical information regarding your computer and operating systems, such as your Internet protocol address, domain name, device and system configuration, settings and location.

Cookies & Pixel Tags: Cookies, which are text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns. Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect location data when you use the Services even when the app is closed or not in use; for example, to provide our fraud detection services. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

How We Use the Information We Collect

In general, we use your personal information collected through our mobile and internet services to respond to your requests, to provide you the services you request, and to help serve you better. We use your personal information in the following ways:

• facilitate the creation of, and secure and maintain your account;
• identify you as a legitimate user in our system;
• provide improved administration of the Services;
• provide the Services you request;
• improve the quality of experience when you interact with the Services;
• send you administrative e-mail notifications, such as security or support and maintenance advisories; and send surveys, offers, and other promotional materials related to the Services.
• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others' rights, privacy, safety, or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate / deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft;
• to verify your identity and/or location (or the identity or location of your representative or agent) in order to allow access to your accounts and conduct online transactions.

Creation of Non-Identifiable Data. The App may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties at our discretion.

Do we disclose your personal information?

We disclose your personal information collected through your use of the web site and internet-based services in accordance with our other privacy notices. Other than as described in this privacy information in connection with internet and mobile services, this privacy information does not apply to the processing of your information by us or third parties with whom we share information.

Third Party Service Providers. We may share your personal information with third party or affiliated service providers that perform services for or on behalf of us in providing web and internet-based services, for the purposes described in this Privacy Policy, including: to provide you with the Services; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services to the App.

Authorities and Others. Regardless of any choices you make regarding your personal information, The App may disclose your personal information to law enforcement, government authorities, and private parties, for the compliance and protection services described above.

How Personal Information is Shared

Please see the Martha's Vineyard Bank Consumer Privacy Notice for information on how Personal Information may be shared and how you may be able to limit certain types of sharing.

Technology and Use Information

Links to Other Sites
Our internet and mobile services contain links to third party websites. When you click on a link to any other website or location, you will go to another site and another entity may collect personal and/or anonymous information from you. The provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites. We encourage you to read the privacy policy of every website you visit.

Your Choices

Do Not Track Signals. On pages where you have not logged in, you can browse anonymously by not providing us with any personal identifiable information, such as your name or email address, during your visits.

Some web browsers transmit "do not track" signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, sites should do when they receive these signals. We currently do not act in response to these signals. If, and when, a standard is established, we may revise our practices in this area.

For internet-based and mobile banking applications: Access, Update, or Correct Your Information. You can access, update, or correct your information by changing preferences in your account.

Opting Out of Location Tracking. If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the App.

For email or text communications: Opting Out of Email or SMS Communications. If you have signed-up to receive our email marketing communications, you can unsubscribe any time by clicking the "unsubscribe" link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information

Browsing mvbank.com domain sites: On pages where you have not logged in, you can browse anonymously by not providing us with any personal identifiable information, such as your name or email address, during your visits.

On pages where you have logged in, you cannot browse anonymously after you have identified yourself, unless you set your browser to disable cookies and similar files, or by deleting the cookies and similar files you have accepted from us. To do this, you will need to follow your browser's instructions for disabling or deleting cookies. Please note that the use of certain online products, such as Online Banking, requires the acceptance of cookies or similar files.

About Cookies, Similar Files and Other Technologies
Cookies are pieces of information stored directly on the computer you are using. Martha's Vineyard Bank or our third-party service providers may place cookies or similar files on your hard drive for security purposes to facilitate site navigation and to personalize your experience while visiting our site. Cookies allow us to collect technical and navigation information, such as browser type, time spent on our website, and pages visited. Cookies allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on Martha's Vineyard Bank's website. We may also use cookies in online advertisements to track consumer responses to Martha's Vineyard Bank advertisements and to identify third party sites which may refer you to us. Cookies and other technologies provide us the capability to monitor the use of our website so we can continually improve the design and functionality to better serve you. Cookies and similar files created or used by Martha's Vineyard Bank do not contain or capture unencrypted personally identifiable information.

Can You Refuse to Accept Cookies? You can refuse to accept these cookies and most devices and browsers offer their own privacy settings for cookies. You will need to manage your cookie settings for each device and browser you use. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products and services. For example, we will not be able to recognize your device and you will need to answer a challenge question each time you log on.

Martha's Vineyard Bank Uses Cookies in Two Ways:

• Web-browsing cookies to display information more effectively to you and to gather data about the usage of our website.
• Online banking cookies to identify you and differentiate you from other users.

Safeguards and Retention
We implement reasonable administrative, technical, and physical measures in an effort to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modification, and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

Protecting Children Online. The Martha's Vineyard Bank website is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Site. We do not knowingly collect information from children under 13 without parental consent.

The Internet is a public network. Children's access to the Internet can allow them to visit inappropriate websites and be exposed to unwanted risks. COPPA, the Children's Online Privacy Protection Act, protects children under the age of 13 from the online collection of personal information. For more information about the Children's Online Privacy Protection Act visit the FTC website at http://www.ftc.gov.

Email & phone calls. Martha's Vineyard Bank complies with the law and regulations and is committed to protecting and respecting consumer's rights to privacy. Martha's Vineyard Bank will use email to provide the most relevant information regarding Martha's Vineyard Bank products and services.

To protect your privacy, email or phone calls from Martha's Vineyard Bank will never ask you for any information through an email requesting that you provide personal information to us such as account number, social security number or driver license number. If you receive an email or phone call appearing to be from Martha's Vineyard Bank requesting personal information, please do not respond and contact us immediately at 508-627-4266.