Nevada Trust Company
Privacy Policy and Notice

Client Trust and Data Privacy

At Nevada Trust Company we place an emphasis on protecting the privacy of our clients.  The Board of Directors and staff place a high priority on ensuring the security and privacy of data pertaining to each client.  Nevada Trust Company is aware that, as clients, you have entrusted us not only with your financial information and accounts, but also have shared personal information.

Managing Data Protection and Information Privacy

The Board of Directors and staff at Nevada Trust Company believe it is important that you be informed of the data protection and privacy practices we have instituted, which include:

1.   Specific security protection practices to ensure privacy of information;

2.   Control methods to limit access to client information;

3.   Formal procedures and processes to ensure the maintenance of accurate information;

4.   Procedures and restrictions on disclosure of client account information;

5.   Standards for client data collection, use, and method of storage;

6.   Client data privacy covenants in third-party service and/or business arrangements;

7.   Staff commitment to support and to protect a client’s right to data privacy; and

8.   Periodic disclosure to clients of privacy benchmarks and overview of institutional privacy practices.

This Privacy Notice is to serve as a reference and guide to clients, bank staff, and management with respect to protecting your client data and your privacy.  In providing this Privacy Notice we also want to underscore that despite our efforts to document or cover various situations in a written policy statement or notice, this notice is not designed to act as a substitute for sound risk analysis or good judgment by our staff.

We are required to provide you with this notice at the beginning of our relationship with you and annually thereafter.  If for any reason our policy changes in the interim with respect to privacy-related matters, you will be informed.

The Initial Privacy Notice

The initial Privacy Notice is provided by Nevada Trust Company when:

·         You become a client — You will be considered a client when you decide to enter into a continuing relationship with us.  That would occur, for example, when you, as a consumer, take the final step to open an account or obtain trust services from us. 

·         Prior to the time that we, as a financial institution, disclose any nonpublic personal information about you to a nonaffiliated third party —  Nonpublic personal information represents any personally identifiable financial information.  A nonaffiliated third party refers to any person, except a Nevada Trust Company affiliate or a person employed jointly by Nevada Trust Company or other company that is not Nevada Trust Company’s affiliate.  Before Nevada Trust Company discloses any nonpublic personal information about you to a nonaffiliated third party, you will be notified and have the option to opt out or decline sharing information.

You should be aware that we do not now, nor do we have any intention in the near future to, disclose any nonpublic personal information about you to an affiliated or nonaffiliated third party, except that which we are required and allowed to by law.  

·         Oral description of the initial Privacy Notice is not adequate — Nevada Trust Company will provide the initial Privacy Notice for you so that it can be retained or obtained at a later time, in written form, or if you agree, in electronic form.  Accordingly, Nevada Trust Company may reasonably expect that you, as a client, have received actual notice of Nevada Trust Company’s privacy policy and procedures as provided in this detailed notice.  The Privacy Notice describing Nevada Trust Company’s policies and practices may be:

¾     Handed to you in printed format;

¾     Mailed to your last known address;

¾     Posted, for clients using electronic services, on Nevada Trust Company’s electronic site and as part of the activity, requires you to acknowledge receipt of the notice; or

·         There are certain situations in which the subsequent delivery of the Privacy Notice may occur — We may deliver the Privacy Notice within a reasonable period of time after a client relationship has been established if:

¾     Nevada Trust Company and you orally agree to enter into a client relationship and you agree to receive the notice thereafter.

Annual Privacy Notice

On an annual basis, no less than every 12 months, Nevada Trust Company will provide you, and all of our other clients with a continuing relationship, with a Privacy Notice.  We will make this notice available in a clear and conspicuous manner.

Specific Client Data Protection/Privacy Focuses of Nevada Trust Company

The following categories of nonpublic personal information about Nevada Trust Company’s clients are collected and retained by Nevada Trust Company for internal information purposes:

·         Account balance information

·         Personal information provided by the client in the delivery of financial services.

The following categories of nonpublic personal information about Nevada Trust Company’s clients that are disclosed:

·         Nevada Trust Company does not disclose nonpublic personal information to either affiliated or nonaffiliated third parties, unless required or allowed by law. 

·         If Nevada Trust Company discloses other types of nonpublic personal information about a client to a nonaffiliated third party, it will only be for the purpose of the third party performing services or functioning on our behalf. 

Similarly, Nevada Trust Company does not disclose nonpublic personal information about former clients to affiliated or nonaffiliated parties, other than for permitted courses of business.

Client Opt-Out Option

If for some reason Nevada Trust Company decides to change its policy with respect to the disclosure of nonpublic personal information to affiliated or nonaffiliated parties, please be assured that you will be given the opportunity to exclude yourself and your personal information from being disclosed.  While it is our policy not to share nonpublic personal information, if business opportunities require a change to this policy you will be given an “opt-out” option.  The client’s opt-out option refers to allowing you to direct Nevada Trust Company not to disclose your nonpublic personal information to nonaffiliated third parties, except in those situations already permitted by law.

Reasonable opportunity will be provided to each of our clients to opt out if this situation should occur.  You may expect Nevada Trust Company to mail you a new Privacy Notice at that time reflecting our change of policy and provide you with an opt-out notice to complete.

Please know that Nevada Trust Company will not directly, or through any affiliate, disclose any nonpublic personal information about you to a nonaffiliated third party unless:

·         Nevada Trust Company has provided you, the client, with an initial notice;

·         Nevada Trust Company has provided you an opt-out notice;

·         Nevada Trust Company has given you a reasonable opportunity, before the time that the institution discloses the information to the nonaffiliated third party, to opt out of the disclosure; and

·         You choose not to opt out.

Limits on Sharing Account Numbers

By regulation, we are prohibited from disclosing your account number or access code for a credit card account, deposit account, or transaction account to a nonaffiliated third party, other than a consumer reporting agency, for use in telemarketing, direct mail marketing, or other marketing through electronic mail.

Client Requests to See Account Information

You will have the opportunity to access your account information and review it for potential errors in a timely and inexpensive manner if you so desire.  Data accuracy is important not only for each client, but in reducing reputation and strategic risks that can arise from reporting erroneous data about clients.

Nevada Trust Company management and staff must ensure the identity of the individual or client who is requesting account information.  We request your assistance in cooperating with our identification procedures when you contact us.  For information regarding your account information, please call or write to us at:

Nevada Trust Company
PO Box 93685
Las Vegas NV 89193-3685

(702) 696-0000