Your Private Information is not for sale at Medallion Bank.
We Do Not Sell Your Customer Information To Anyone
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:
- Information we receive from you on applications and other forms, such as your name, address, phone number, social security number, employment, assets, income and debt;
- Information about your transactions with us, our affiliates or others, such as your account balances and payment history; and
- Information we receive from a consumer reporting agency, including your credit history and creditworthiness.
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
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:
- Third-Party Service Providers. We may disclose all Customer Information to third-party service providers that we have engaged to help deliver our services and products to you, and that have agreed to keep your Customer Information confidential.
- Among Our Affiliates. We may share certain Customer Information about transactions and experiences with you with our affiliates. This Customer Information may include identification information, account balances, and payment history.
- With Other Non-Affiliated Third Parties. In addition, we may share Customer Information about you with other non-affiliated third parties for our everyday business purposes, such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus or as permitted by law.
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).
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.
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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