Medallion Bank Privacy Policy


Your Private Information is not for sale at Medallion Bank.

Medallion Bank ("MB") is committed to providing you, our customers, with the highest quality products and services while protecting your personal information. Providing the highest quality products and services requires us to collect, maintain and use certain personal and financial customer information about you and your activities with us. Protecting this private information, however, remains our highest priority. For this reason, this Privacy Policy outlines our procedures and our pledge to constantly protect the private information you have entrusted us with.

We Do Not Sell Your Customer Information To Anyone
We do not sell your Customer Information (described below) to anyone. We also do not disclose your Customer Information to any nonaffiliated third parties, other than as allowed by law or as described in this Privacy Policy. This means that to protect your Customer Information you do not have to "opt out" or formally request that we not disclose your Customer Information to parties that are not affiliated with MB. We may, however, sometimes disclose your nonpublic personal information to our contracted service providers and affiliates as permitted by law in an effort to better serve your needs or to provide better products or services to you. For example, we may share certain relevant Customer Information with the mailing service we contract with to print and mail monthly customer account statements to you.

Please note that to protect your privacy we cannot accept or respond to communications from someone claiming to represent you, unless that person is your attorney, guardian, trustee or is otherwise authorized by law to represent you.

Collection and Use of Customer Information
We collect, retain and utilize information about you we believe is necessary to operate our business, to provide you with quality products and services, and to ensure the protection of your account. We obtain this nonpublic personal information (collectively, "Customer Information") about you from the following sources:

Also, when you visit any of our websites, we may collect information to measure the use of our website and to assist us in improving the content of our site. We may also collect information from you that will permit us to offer more personalized service, which may include the use of "cookies." When you interact with our websites, our web server may send a "cookie" to your computer to allow us to help make your experience easier and more meaningful. A cookie is an electronic file that holds small items of information, but not Customer Information as described above. When you connect with our website and request to look at certain pages on the website the cookie will allow our web server to recognize your computer. Unless you choose to contact us through our website, you will remain anonymous to us as a website user.

Maintaining Accurate Customer Information
We have established policies and procedures to ensure that your Customer Information is accurate, current and complete. We will work to correct inaccurate Customer Information in a timely manner. If you have any reason to believe that your Customer Information is incorrect, please contact your customer service or account representative at the toll free number listed on your account statement. We will promptly investigate the situation and, when appropriate, update our records accordingly.

Protection of Information
We maintain appropriate policies and procedures to protect the security of your Customer Information. All of our employees have agreed to comply with our Privacy Policy and receive training to better understand the importance of confidentiality and customer privacy. We restrict access to your Customer Information to those employees who have a business reason for using such information. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your Customer Information. Even if you decide to close your account(s) and/or repay your loan(s) or other obligation(s) or otherwise become an inactive customer, any Customer Information we have about you will remain subject to the practices described in this Privacy Policy.

Customer Information We May Disclose or Share
In the course of conducting our business and servicing your needs, we do not disclose any Customer Information to anyone except as permitted or required by law. To conduct our business we may disclose Customer Information to, (1) financial service providers and other financial institutions with which we may enter into joint marketing agreements from time to time, and (2) as otherwise permitted by law, under the following circumstances:


Application of Our Privacy Policy
This Privacy Policy applies both during and after your customer relationship with us. In the event we revise this Privacy Policy, we will send our customers a copy of the new policy. Our former customers will also receive a copy of the new policy to the extent required by law. Please read this Privacy Policy carefully and keep it for your records.

 

Luxury Expenditure Policy

It is the policy of Medallion Bank (the “Bank”) that its employees use corporate assets in a prudent manner.  Reasonable expenditures are defined as appropriate and effective use of resources to achieve the Bank’s business objectives to promote the long term success of the Bank for the benefit of its stockholders.

The Bank prohibits excessive or luxury expenditures on entertainment and events, office and facility renovations, aviation and other transportation services, or other similar items, activities or events.  All expenditures must be reasonable, appropriate and compliant with the Bank’s Conflict of Interest/Code of Ethics Policy (the “Code of Ethics”), and are subject to the Bank’s established policies and procedures.  The list of activities below is not exhaustive and employees should continuously evaluate whether additional items, activities or events are susceptible to excessive spending.

Entertainment and Events

The Bank pays for appropriate entertainment and event expenses incurred on behalf of the Bank.  These expenses must be reasonable and in accordance with customary, accepted and lawful business practices.  Unless previously approved in writing by the President or the Executive Vice President or as part of a formal pre-approved Bank-sponsored recognition event, event tickets and other expenses for leisure activities may be used only for customer or non-profit entertainment.  Expenses for sponsorships, non-profit events or client events should serve a fundamental business purpose, whether it is business development or supporting the Bank’s local communities, and must be approved in accordance with established policies and procedures.

Office and Facility Renovations

Renovations and improvements of Bank offices and facilities are done to ensure a reasonably comfortable and safe environment for our customers and a reasonably effective and productive work environment for our employees, while balancing the overall expense and benefit to the Bank.  Situations which create a safety/health hazard will be remedied as promptly as possible to prevent any accidents or harm to individuals.  Office and facility renovations are reported to and approved by the Bank’s President or Executive Vice President.

Aviation and Other Transportation Services

The Bank pays for reasonable and appropriate travel expenses incurred on behalf of the Bank.  Use of aviation and other transportation services should be prudent and responsible, and must comply with the Bank’s established policies and procedures.  Ensuring compliance with the Bank’s policies and procedures is the responsibility of employees and their managers.

Other Similar Items, Activities or Events

The Bank pays for reasonable and appropriate activities or events for staff development, conferences and performance incentives conducted in the normal course of business.  Similar to other expenditures incurred on behalf of the Bank, reimbursement of expenses incurred for such items, activities or events must be in accordance with established Bank policies and the Code of Ethics, and be part of customary, accepted and lawful business practices. 

Requests for Approval

If an expenditure requires pre-approval, the employee must submit the request and any related documentation as required by the established Bank policy.  For each request for approval submitted, the appropriate reviewer must indicate his or her approval or disapproval of the request and must retain a record of the decision (whether recorded in writing or electronically). 

Exceptions

Requests for exceptions to this policy must be submitted in writing and may only be approved by the President or the Executive Vice President and ratified by the Board of Directors or the Audit Committee.

Certification

The Bank’s President and Chief Financial Officer must certify annually that in any instance where the approval of an expense is required by any executive officer, the Board of Directors or a Board committee that such approval was properly obtained.

Accountability and Adherence

Any expenditure in the above categories that is unreasonably high under the circumstances shall be considered excessive.  Any employee who engages in excessive spending shall be subject to corrective action up to and including termination of employment.  Violations of this policy must be promptly reported and escalated through the appropriate channels to the President or the Executive Vice President and shall be reported to the Board of Directors as appropriate. 


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