Franklin Templeton Bank & Trust does not sell non-public personal information of individuals and does not share it outside of Franklin Templeton Investments except as permitted by law. Our privacy statement, detailed below, describes the steps we take to protect each individual’s information and explains when non-public personal information about current or former customers may be shared with other parties.

What Type of Information Do We Collect?

When you, as an individual, become a customer of Franklin Templeton Bank & Trust, you provide us with your non-public personal information. We collect and use this information to service your accounts and respond to your requests. The non-public personal information we collect falls into the following four categories:

1. Information we receive from you on applications or other forms, whether we receive the form in writing or electronically. For example, this information will include your name, address, tax identification number, birth date, beneficiary designation and income.
2. Information about your transactions and account history with us, or with other companies that are part of Franklin Templeton Investments. This category also includes your communications to us concerning your accounts/loans.
3. Information regarding your creditworthiness and credit history received from a credit reporting agency.
4. Information from outside sources regarding their employment, credit or other relationships with you.

Disclosure Policy

Within Franklin Templeton Investments

To better service your accounts and process transactions or services you’ve requested, we may share non-public personal information with other companies within Franklin Templeton Investments. From time to time we may also need to send you information about products/services offered by other Franklin Templeton Investments’ companies although we will not share your non-public personal information with these companies without first offering you the opportunity to prevent that sharing.

Outside of Franklin Templeton Investments

We will only share non-public personal information with outside parties in the limited circumstances permitted by law. Below are some examples of third parties to whom we may disclose non-public personal information. While these examples do not cover every situation permitted under the law, we hope they help you understand how your information may be shared. We may share non-public customer information:

• With companies that work on our behalf to service your accounts, or to provide services or process transactions you’ve requested. For example, we may use companies to assist us with mailing statements, processing checks, or providing online transaction or account maintenance capabilities.
• With third parties whom you have authorized us to share information with.
• When permitted or required by law, such as in response to a subpoena or other legal process.

Additionally, we may disclose non-public personal information from your application form or information about your account history/transactions with us to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements. We will ensure that any outside companies working on our behalf, or with whom we have joint marketing agreements, are under contractual obligations to protect the confidentiality of your information, and to use it only to provide the services we’ve asked them to perform.

Confidentiality and Security

Our employees are required to follow procedures with respect to maintaining the confidentiality of customer information. Additionally, we maintain physical, electronic and procedural safeguards to protect our customer’s non-public information. These include performing ongoing evaluations of our systems containing customer information and making changes when appropriate.

We’ll Update You Annually

We will send you notice of our privacy policy annually for as long as you maintain an ongoing relationship with us. Periodically, we may revise our privacy policy, and will provide you with a revised policy if the changes materially alter the previous privacy policy. We will not, however, revise our privacy policy to permit the sharing of non-public information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. You may call us at 1-877/664-4286 if you have further questions or to request an additional copy of our privacy notice.

Franklin Templeton Bank & Trust, F.S.B.