Privacy Policy

This Policy explains what The Middlefield Banking Company does to keep information about you private and secure. We want you to know how we manage that information to serve you and that you have choices about how it is shared. This Policy covers our family of companies, a partial list of which is contained at the end of this Policy. Please read this Policy carefully.

Q. What information do you have about me?

A. To provide services and to help meet your needs, we collect information about you from various sources.

• We get information from your requests for our products or services. One example is income on loan applications.
• We get information about your transactions with us and with others. For example, we have your account balance information.
• We get information, such as your credit history, from credit bureaus.

Q. How do you safeguard information about me?

A. We take a number of steps to protect the privacy of information about you. Here are some examples:

• We keep information under physical, electronic or procedural controls that comply with or exceed governmental standards.
• We authorize our employees, agents and contractors to get information about you only when they need it to do their work for us.
• We require companies working for us to protect information. They agree to use it only to provide the services we ask them to perform for us.

Q. Is information about me shared within your family of companies?

A. Yes. We may share information about you within our family as required or permitted by law. This helps us to offer you financial products and services, such as loans, deposits, investments, credit cards and insurance.

Q. Is information about me shared with service providers and financial companies outside your family of companies?

A. Yes, as permitted by law. We may share information about you with outside companies that work for us. These may include firms that assist in marketing our products. We may also share information about you with outside financial companies that have joint marketing agreements with us. These arrangements give you the opportunity to receive additional products or services.

Q. Is information about me shared with non-financial companies outside your family of companies?

A. Yes. We may share information about you with companies outside of our family as permitted by law, including retailers, auto dealers, auto makers, direct marketers, membership clubs and publishers.

Q. Is information about me shared in any other ways?

A. Yes. We may also share information about you in other ways, as required or permitted by law. Here are some examples of ways that we share information.

• To protect against fraud.
• To respond to a subpoena.
• To service your account.
• To report to a credit bureau.
• With your consent.

Q. What choices do I have about information sharing?

A. We offer you the following two choices about sharing information that identifies you:

• Choice #1. You may tell us not to share information about you with non-financial companies outside of our family of companies. Even if you do tell us not to share, we may do so as required or permitted by law. Also if you have authorized us to share information in connection with a particular product or service, we will continue to share information about you in connection with that product or service. For example, you might have a credit card with one of our airline, retail or university partners that offers rewards programs.
• Choice #2. You may tell us not to share the following information about you within our family of companies:
  • Information from your applications to be used to determine your eligibility, such as your income.
  • Information from credit reports, such as your credit history.
  • Information from sources used to verify information you provide us, such as outstanding loans or employment history.

Even if you do tell us not to share, we may share other types of information within our family. For example, we may share name and address, information about transactions or balances with us, as well as survey results.

Q. How do I tell you about my privacy choices?

A. You may contact us by:

• Calling us toll-free at 888-801-1666, or
• Writing us at P.O. Box 35, Middlefield, OH 44062

You do not need to contact us unless you want to make one of the privacy choices listed above. If you are a current customer, you do not need to contact us unless you want to change a choice you previously indicated to us.

Q. What about joint accounts?

A. Each person may separately make privacy choices, and joint account holders may make privacy choices for each other. If only one joint account holder makes a privacy choice, information about the other joint account holder may be shared.

Q. How do you tell me about your Policy?

A. We send our Policy to you when you open a new account. We also send it to current customers yearly. We may change our Policy. We will send you a new policy if we broaden our information sharing practices about you. Our Policy is available at www.middlefieldbank.com/pdf/policy.pdf.

• Even if you do not make privacy choice #1 listed above, we will not share information that we have about you with non-financial companies outside our family of companies, unless otherwise permitted by law.
• We will not share information about you within, or with financial companies outside, our family of companies unless we first provide you with further privacy choices or unless otherwise permitted by law.

This Policy applies to current and former consumer customers. Separate policies may apply to customers of certain businesses, such as Private Banking or Private Client Services. In addition, customers in certain states may also receive policies that apply to them. The privacy policies posted on our websites apply when you use those sites. In addition, our online consumer information practices are at www.middlefieldbank.com/pdf/policy.pdf.

Please contact us if you see any personal information on our website that you believe is incorrect. This policy is effective as of September 15, 2007.