Privacy Policy

Solvay Bank and our affiliate, Solvay Bank Insurance Agency, Inc. (SBIA), recognize and respect the privacy expectations of our customers. Ensuring the privacy of customer information is a matter that we take very seriously and attend to in our everyday function so that our customers can rest assured that their accounts are handled in a confidential and secure manner. To affirm our commitment to the confidentiality and protection of our customers, we have set forth the following privacy principles:

Types of Information the Bank Collects

We collect nonpublic personal information about you from the information we receive from you on applications or other forms; information about your transactions with us; and information we receive from a consumer-reporting agency.

Disclosing Information to Our Affiliates Within Our Corporate Family

We may disclose information such as your name and address or transaction experience to our affiliate within our corporate family. This gives us an opportunity to provide you with additional insurance products or services that help better serve you and meet your needs. Information obtained from third parties, such as credit bureaus, is not shared with our affiliate unless you direct us to, or unless permitted or required by law. Under the final rules on Affiliate Marketing, the Bank has implemented appropriate opt-out procedures to assure compliance. Please refer to Exhibit A of this policy.

Disclosing Information to Non-Affiliated External Companies

Solvay Bank and SBIA may disclose information we collect from you to non financial companies such as check printing companies, collection agents, credit bureaus and our credit card provider. We may also disclose non public information to financial service providers, with whom we have joint marketing agreements, such as investment brokers and managers, and insurance companies. These companies assist us in processing your transactions and fulfilling service requests. Companies that provide services for your accounts are contractually obligated to keep the information we provide them confidential. We may also disclose information to non-affiliated third parties, for their use, if; a) you request or authorize it; b) the information is provided to help complete a transaction initiated by you; or c) the information is necessary to respond to a subpoena, inquiries by regulatory agencies or investigations of suspected fraud.

If You End Your Relationship

If you end your customer relationship with Solvay Bank or SBIA, or become an inactive customer, we will not release information about you to any non-affiliated third party, except as required by law.

Security of Customer Information

We maintain physical, electronic and procedural safeguards that comply with the federal standards to guard your nonpublic personal information from unauthorized access, alteration, or destruction.

Employee Access to Customer Information

Employee access to personally identifiable information is limited to those with a business reason for knowing such information. Each employee is required to follow Solvay Bank's Code of Ethics and is held accountable for adhering to our privacy policy and procedures.

Accurate Information

We ensure that customer financial information is accurate, current and complete, in accordance with reasonable commercial standards. If you receive or believe that information received from us or from a credit bureau is inaccurate or incorrect, you should notify us immediately. We will investigate and take steps to correct information that we determine to be incorrect and we will respond to you in a timely manner.

Solvay Bank and its corporate family will maintain our dedication to assure that customer information is safeguarded and used in a secure manner. If you should have any questions or concerns regarding our privacy policy, please contact us at (315) 468-1661 or write us at Solvay Bank, 1537 Milton Avenue, Solvay, New York 13209.

EXHIBIT A

SOLVAY BANK INITIAL OPT-OUT NOTICE

(Your Choice to Limit Affiliate Marketing)

Solvay Bank is providing this notice.

Federal law gives you the right to limit some, but not all, marketing from our affiliate Solvay Bank Insurance Agency, Inc. (SBIA). Federal law also requires us to give you this notice to tell you about your choice to limit marketing from our affiliate.

You may limit SBIA from marketing their insurance and annuity products or services to you based on your personal information that we collect and share with them. This information includes your name, address, telephone number, and transaction experience with us.

Your choice to limit marketing offers from our affiliate will apply for five (5) years from when you tell us your choice. Once that period expires, you will receive a renewal notice that will allow you to continue to limit marketing offers from our affiliate for another five (5) years.

To limit marketing offers by SBIA, please respond within 30 days of receipt of this notice by contacting us:

By telephone: 315-468-1661

On the Web: www.solvaybank.com

By mail: Fill out the form below and send it to:

Solvay Bank

1537 Milton Avenue

Solvay, New York 13209

Attention: Compliance Department

Do not allow your affiliate, SBIA, to use my personal information to market to me.

NAME: ____________________________________________

ADDRESS: ____________________________________________

____________________________________________

Effective Date: 03/03/2009