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 PRIVACY NOTICE OF TRUST COMPANY OF CONNECTICUT At Trust Company of Connecticut, we realize that your privacy is important and we want you to understand that we are committed to treating your information responsibly. This Privacy Notice will summarize some of the policies and procedures we have in place to protect the privacy and security of the nonpublic personal information that is maintained by the Trust Company of Connecticut. As you know, Trust Company of Connecticut is a segregated division within NewAlliance Bank (the "Bank"). If you have a separate customer relationship with other divisions within the Bank or with one of the Bank's corporate affiliates, you have received (and will continue to receive) separate and distinct Privacy Notices that summarize the policies and procedures that apply to that particular customer relationship. TYPES OF INFORMATION WE COLLECT In the course of our business relationship with you, we collect personal information in order to assist us in providing you with investment management and other trust services as well as to fulfill legal and regulatory requirements. The type of information that we collect may include information from the following sources:
INFORMATION WE SHARE WITH OTHER DIVISIONS OF THE BANK AND AMONG THE ENTITIES WITHIN OUR CORPORATE FAMILY In order to provide an attractive array of products and services, the Bank has assembled a family of affiliated financial service companies that provide different products and services. As you might expect, the Trust Company of Connecticut will sometimes share information within this corporate family to help with individual and collective operations. At present, the members of the Bank's corporate family include, among others, the following financial institutions:
The Trust Company of Connecticut may, from time to time, share some or all of the information we collect (as described above) with other divisions of the Bank and with the other members of the Bank's corporate family. Information might be shared, for example, to help identify products or services in which you might be interested. In the future, as the Bank continues to adapt to the changing needs of customers and the community, the Bank may add additional companies to the corporate family and information may be exchanged with those companies as well. In any case, we would only share information within our corporate family if that practice is permitted or required by law. In this regard, you should be aware that, at the present time, the Trust Company of Connecticut does not intend to share information with other members of the Bank's corporate family if that practice would give rise to an "Opt-Out" right under the Fair Credit Reporting Act. However, you may have an Opt-Out right if you have a separate customer relationship with other divisions of the Bank or with other members of the Bank's corporate family. We urge you to review the separate Privacy Notices that apply to those other relationships for more information on your Opt-Out rights. INFORMATION WE SHARE OUTSIDE OUR CORPORATE FAMILY The Trust Company of Connecticut may, from time to time, disclose some or all of the nonpublic personal information we collect (as described above under "Types of Information We Collect") to nonaffiliated third parties. Again, however, we will only share information if permitted or required by law. For example, we may disclose nonpublic personal information in the ordinary course of business to third parties who help us service manage or administer your accounts (such as tax preparers, data processing companies, and securities brokerage firms that are engaged to execute a trade on your behalf). We may also, for example, share information with our auditors, legal counsel and regulatory agencies. These types of disclosures are often necessary for us to conduct our business operations or to comply with applicable laws. We may also disclose some or all of the information we collect (as described above under "Types of Information We Collect") to companies that perform marketing services on our behalf. These third parties might include certain nonfinancial companies, such as a company that might be hired to help us market a product or service (such as helping us with a large mailing or analyzing customer data to better identify customer needs or interests). Please be assured, however, that we will not sell our customer lists or your nonpublic personal information to nonaffiliated third parties that might want to market products to you. For example, we would not sell your nonpublic personal information to an airline, department store or some other similar retailer for mass marketing purposes. SAFEGUARDING CUSTOMER INFORMATION We have policies and procedures in place that are designed to limit access to nonpublic personal information to those employees who need to have access to the information to conduct business operations or to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. CUSTOMERS AND FORMER CUSTOMERS This Privacy Notice applies to you if you are an individual and, in that capacity, you currently have a customer relationship with the Trust Company of Connecticut in connection with a financial product or service that is to be used primarily for personal, family or household purposes. This Privacy Notice is not applicable to commercial or business purpose accounts. If you decide to close your account(s) or become an inactive customer, except as otherwise provided below, we will continue to adhere to the privacy policies and practices as described in this Privacy Notice. ADDITIONAL INFORMATION We hope that this Privacy Notice provides you with a better understanding of our concerns for your privacy. Please understand that this Notice is merely a summary of select aspects of our policies and procedures and does not constitute a contract. We reserve the right to revise the policies and procedures described in this Notice and, to the extent permitted by law, those revisions may affect the nonpublic personal information of our current customers and former customers.
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