As a service provider for Franklin Templeton Bank & Trust, F.S.B., Franklin Capital Corporation is providing you a copy of their Privacy Statement.

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

We Take Our Commitment to Your Privacy Seriously

We all want to feel safe about the personal information we give to financial institutions. That’s why Franklin Templeton Bank & Trust, F.S.B. is committed to safeguarding information provided to us by our valued individual customers.

Please take a few minutes to read about how we protect the confidentiality of non-public personal information.

Who We Are and How Our Privacy Policy Serves to Protect You

Franklin Templeton Bank & Trust, F.S.B., is a federal thrift offering banking, trust, and custodial products and services. It is a part of Franklin Templeton Investments, a global investment management organization comprising the various subsidiaries of Franklin Resources, Inc.

It is the policy of Franklin Templeton Bank & Trust to not sell non-public personal information of individuals and it 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 that you may have.

Disclosure Inside of 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. We will not share your non-public personal information with these companies without first offering you the opportunity to prevent that sharing.

Disclosure 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 personal information:

• With companies that work on our behalf to service your accounts, or to provide services or process transactions you’ve requested or have consented to receive. 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, regulatory request, or other legal process.

Additionally, we may disclose non-public personal information from your application form or information about your account history/transactions to companies that perform marketing services on our behalf, or to other financial institutions with which 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 customers’ non-public personal information. These include performing ongoing evaluations of our systems containing customer information and making changes when appropriate.

We will notify you annually

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

If you are a customer living in Texas

Franklin Capital Corporation, one of our affiliates who may service your account on our behalf is licensed and examined under the laws of the State of Texas and by state law is subject to regulatory oversight by the Office of Consumer Credit Commissioner. Any consumer wishing to file a complaint against Franklin Capital Corporation should contact the Office of Consumer Credit Commissioner through one of the means indicated below:

In Person or U.S. Mail:
2601 North Lamar Boulevard
Austin, Texas 78705-4207.

Telephone No.: (800) 538- 1579.
Fax No.: (512) 936-7610.
E-mail: consumer.complaints@occc.state.tx.us
Website: Office Of Consumer Credit Commissioner