Privacy Policy

AARP Financial Inc. (AARP Financial) is pleased to make available to AARP members access to on-line banking through the AARP Financial Savings Center website www.aarpsavings.com operated and maintained by Waterfield Financial Services Inc. Banking services and products, including checking, high yield money market savings and secure money market accounts are provided by The Huntington National Bank. The Certificate of Deposit accounts and services are provided by Reliance Trust Company. Deposits are FDIC insured to the maximum provided by law. This privacy policy describes how Waterfield Financial Services Inc., The Huntington National Bank and Reliance Trust Company (collectively, "we") collect, use, share and protect your personal information.

Waterfield Financial Services Inc., The Huntington National Bank and Reliance Trust Company, respect the privacy and security of your personal information as our top priority. We recognize that our most important asset is our customers' trust and that is why we work diligently to safeguard the confidentiality of your personal information.

Please read this notice carefully. It will provide you with information on how we manage the information you entrust to us and an overview of the policies we use to protect your privacy.

COLLECTION OF INFORMATION

Our main concern when collecting and maintaining customer information is to provide you with the best possible customer service. We obtain nonpublic personal information (NPI) about you from the following sources:

• From you, on forms, via the Internet, by telephone or other means. Examples of this type of information include your name, address, social security number, employment, credit history and other financial information.
• From transactions with us, our affiliates or with others. For example, we may collect account balances, transaction records, and your payment histories.
• From consumer reporting agencies, we may collect information through a credit bureau report relating to your credit worthiness.
• From outside sources, we may collect information regarding your employment, credit or other relationship with you or may verify information you provided, such as employment history and loan or credit card balances.
• From the AARP Financial Savings Center website, we may collect information on the number of web pages you visit, how long you visit the website and how often you visit the website.

USE AND SHARING OF INFORMATION

NPI we collect, as described above, is used to provide account services, to comply with applicable laws and regulations and to provide for the security of your accounts with The Huntington National Bank and Reliance Trust Company. We use NPI to provide you with excellent customer service - Your customer information allows us to respond quickly and efficiently to your inquiries. We also use NPI to protect the security of your accounts with us - We utilize your personal identification number and password to prevent unauthorized persons from gaining access to your accounts or account information. Our commitment to you is to limit who receives the NPI and the type of information shared in accordance with this Privacy Policy.

INFORMATION SHARING WITHIN THE BANK AND AFFILIATES

Your NPI may be shared between Waterfield Financial Services Inc., The Huntington National Bank, and Reliance Trust Company in accordance with agreements relating to the deposit products and services offered through the AARP Financial Savings Center. Within Waterfield Financial Services Inc., The Huntington National Bank and Reliance Trust Company, we may share your NPI with each of our affiliated companies. We may also share your NPI with AARP and its affiliates, including AARP Financial. Your NPI may be shared with our affiliated companies in order to provide support for the savings center products and services currently offered to our customers. We collect and analyze customer information, such as account activity and history, in order to find ways to improve our current products and services, or to develop new ways to meet your needs.

• As part of our efforts to offer you the best and most current banking opportunities, we may contact you with information about new products, services and special promotions regarding AARP endorsed products. If you would like to be taken off our mailing list or e-mail list, please submit your request to the Bank by email to customercare@aarpsavings.com or by telephone (866) 421-5806.

INFORMATION SHARING WITH NONAFFILIATED THIRD PARTIES

For those customers who open accounts with The Huntington National Bank or Reliance Trust Company through the AARP Financial Savings Center, neither The Huntington National Bank nor Reliance Trust Company will sell or provide your personal information to any third party for their independent use. We do not share information we collect about you or former customers with third parties except as permitted by law.

Waterfield Financial Services, Inc., The Huntington National Bank and Reliance Trust Company may share all NPI we collect, as described above, with third parties for a variety of purposes, including:

• To companies that provide services for us in the processing or servicing of your transactions. These companies may include check printers, bill payment providers, customer service call centers, operations support, and data processing and ATM providers. For example, the company may provide assistance in processing your transactions or in the production and mailing of your account statements. Our contractual agreements with these companies require them to maintain the confidentiality of your information and to use the information only for the specific purpose we have requested.
• To comply with federal, state or local law or regulations or to respond to properly authorized judicial process or requests from government officials or agencies, including our regulators and law enforcement.
• To companies that perform marketing services on our behalf. These companies may include data base management, mail distribution and design or print productions. Our contractual agreements with these companies require them to maintain the confidentiality of your information and to use the information only for the specific purpose we have requested.
• To report when required by law to information reporting agencies and credit bureaus to whom we report information about your transactions with us.
• To protect the confidentiality or security of our records pertaining to you or your accounts or transactions. This may include sharing with government, regulatory and other legal authorities, as required by law, or in response to a subpoena or a similar legal process, a fraud investigation, or to auditors conducting an examination of our bank. In all cases, we only provide the specific information required.
• At your request and with your written consent to third parties. An example of this would be when you give someone a power of attorney or other authorization to act on your behalf.

PROTECTING THE SECURITY OF THE INFORMATION WE COLLECT ABOUT YOU

Waterfield Financial Services Inc., The Huntington National Bank and Reliance Trust Company maintain physical, electronic, and procedural safeguards to help prevent unauthorized access to personal information. We require password and PIN authentication in order to obtain access to your account. We restrict access to your NPI to those properly authorized employees and agents who need to know that information. Our employees are trained to fulfill their responsibilities of maintaining customer confidentiality and privacy at all times. If necessary, disciplinary action will be taken to enforce our policies on protecting your personal information. Companies we use to provide support services are not permitted to use information about our customers for their own purposes and are required by contract to maintain strict confidentiality.

Transactions conducted on the AARP Financial Savings Center website are secure; you can confirm this by the padlock on your browser window. Please be aware that emails sent to and from us are not secure and should not contain any NPI or account information. When communicating with the Bank, use Secure Bank Mail which is available to you once you have logged into your account online. See Security Policy for more information on the security measures utilized to protect your information.

ACCURACY OF YOUR CUSTOMER INFORMATION

We do our best to maintain accurate and complete information about you and your accounts. If you ever identify information you think is inaccurate or incomplete, please contact your Customer Care Team. We will investigate your concerns and correct any inaccuracies.

FORMER CUSTOMERS

If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices as described above regarding the collection and sharing of NPI.

LINKS TO OTHER SITES

This web site contains links to other sites. If you use a link to visit the site of another company, we cannot be responsible for the privacy practices of that company or its site. We invite you to review the privacy policy of any linked site before providing information.

ABOUT COOKIES

"Cookies" are small text files we place on your computer when you access our web site. We only use cookies to determine how you have navigated to our site, for example, in the case that you are responding to a specific promotional offer. We do not currently record any personal identifiable information in any cookies produced by our site.

CHILDREN'S INFORMATION PRIVACY

Neither Waterfield Financial Services Inc., The Huntington National Bank nor Reliance Trust Company will seek to obtain information from children or minors under the aged of 18 except to identify beneficiaries. The Bank's application process is designed to identify applications submitted by minors and to prevent their opening an account. We may offer a Uniform Gift to Minor Account that would include the name of the minor, but may only be opened with an adult signatory on the account.

UPDATES TO OUR PRIVACY POLICY

Waterfield Financial Services Inc., The Huntington National Bank and Reliance Trust Company will continue to review and monitor our privacy practices and we will modify our privacy policy as necessary. You can always review our current privacy policy by accessing the web site or calling us toll free for a copy. In the event that a material change is made to this privacy policy, we will make every attempt to notify our customers at the time of the change, or sooner if required by law.

PRIVACY ISSUES CONTACT INFORMATION

If you have any questions or comments about our privacy policy, you may contact us at:

Deposit Operations
P.O. Box 1245
Indianapolis, IN 46206-1245

Toll Free Phone: (866) 421-5806
Email: customercare@aarpsavings.com

Huntington Privacy Policy

This Customer Information Privacy Notice ("Customer Notice"):

• Explains how we collect and disclose customer information when you apply for or obtain financial products and services for personal, family, or household purposes from The Huntington National Bank ("Huntington") through a private label banking center brought to you by Affinity Financial Corporation or Waterfield Financial Services ("Banking Center Channel").
• Does not apply to financial products and services that you apply for or obtain from Huntington outside of the Banking Center Channel.

We may supplement this Customer Notice to address special state law requirements not otherwise described in the State Disclosures section below. In the event of any conflict between the provisions of this Customer Notice and any supplement, the provisions of such supplement will apply to the extent applicable.

Confidentiality and Security

Protecting customer information has always been important to us. Access to customer information is limited to those persons who need to know that information. For example, access to customer information is needed to resolve questions or inquiries, for internal security or fraud control, to provide products or services, or to protect or enforce our rights.

We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard customer information.

Customer Information We Collect

We collect customer information about you from the following sources:

• Information we receive from you on applications or other forms, such as your name, address, Social Security number, assets, and income.
• Information about your transactions or relationships with us, with other Huntington companies or with third parties, such as information about your balances and payment history.
• Information we receive from consumer reporting agencies, such as your creditworthiness and credit history.

Our Policy About Disclosing Customer Information Outside of Huntington

We do not disclose customer information we collect about our customers or former customers to third parties outside of Huntington, except as permitted or required by law. These exceptions are described below. Since this is our policy, there is nothing you need to do to request us not to share customer information with such third parties.

Exception for Joint Marketing and Service Providers

We may disclose customer information we collect on customers and former customers to companies that perform marketing services for us or to other financial institutions with whom we have joint marketing arrangements.

Examples of these companies or financial institutions are:

• Financial institutions with whom we have joint marketing agreements, such as insurance companies, mutual fund companies, credit card companies, and motor vehicle dealers.
• Companies that provide marketing services for us, such as bulk mailing companies, direct marketing companies, market research firms, and marketing consultants.

Other Exceptions

Other examples of when we disclose customer information outside of Huntington are as follows:

• To consumer reporting agencies.
• In connection with audits or any sale or transfer of your accounts or a Huntington company or division.
• For fraud, security or risk control.
• To help complete a transaction you initiate, including information requested to verify the existence or condition of an account
• To resolve disputes or inquiries you may have about your accounts.
• With your consent or at your direction.
• When disclosure is required by law, such as pursuant to court order, subpoena, legal process or government agency examination or investigation, or to protect or enforce our rights.
• To companies that perform services for us in connection with your accounts, such as data processing and software companies and collection agencies.
• As otherwise necessary to service your account, or as permitted or required by law.

Sharing Customer Information with Other Huntington Companies

Under the terms of our agreement with Affinity Financial Corporation and Waterfield Financial Services, we do not disclose customer information we collect on customers and former customers of the Banking Center Channel with other Huntington companies. As a result, there is nothing you need to do to request us not to share customer information with other Huntington companies.

Correcting Errors in Information We Share with Consumer Reporting Agencies

If you believe any of the information we share with a consumer reporting agency is in error, please let us know. Write to us at: The Huntington National Bank, Consumer Reporting Agencies, P.O. Box 1245, Indianapolis, Indiana 46206-1245. Please provide us with your complete name, current address, phone number, and Social Security number. You will also need to include your account number, type of account, and the specific item in dispute. You must tell us the reason you believe this information has been reported in error.

Identity Theft

The law provides certain rights to victims of identity theft. If you believe you are a victim of identity theft with respect to any of your accounts or transactions with us, you may notify us at: The Huntington National Bank, Identity Theft, P.O. Box 1245, Indianapolis, Indiana 46206-1245. Please provide as much detail as possible about the accounts or transactions in question, including any dates and account or transaction numbers that apply. We may contact you to discuss additional information necessary to resolve the matter.

For more information about how to protect yourself against identity theft or what to do if you believe you are a victim, please visit www.ftc.gov/idtheft.

Important Information About Procedures for Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

State Disclosures

In addition to your rights described in this Customer Notice, you may have other rights under state laws. We will comply with applicable state laws with respect to our information practices.

Effective Date

This Customer Notice is effective as of 9/22/07.