Bay State Bank (“the Bank”) understands how important personal privacy is to our customers and website visitors. This Online Privacy Policy explains how information is collected, protected, and used when you interact with our website, online banking, and mobile applications.

We may update this Online Privacy Policy from time to time. When changes are made, we will revise the “Last Updated” date above and, where appropriate, provide additional notice. We encourage you to review this policy periodically to remain informed about our information handling practices.

Bay State Bank recognizes that our customers expect privacy and security for their personal and financial affairs. We understand the importance of safeguarding sensitive information entrusted to us and maintain standards and procedures designed to prevent misuse of that information.

Bay State Bank collects, retains, shares, and uses customer information only as necessary to administer our business, provide financial products and services, and meet legal and regulatory requirements.

We use customer information to:

· Maintain and service accounts

· Process transactions, including real-time payments and transfers

· Improve products, services, and the overall client experience

· Understand customer financial needs and deliver appropriate solutions

· Protect against fraud and unauthorized activity

We may also collect and share information as required to comply with applicable laws, regulations, subpoenas, or regulatory requests. For additional information, please refer to our Privacy Policy.

When you enroll in or interact with our online services, including our website and mobile applications, we may collect:

· Identity Information: Name, email address, phone number, Tax Identification Number

· Financial Information: Account numbers, balances, and transaction activity

· Device Information: Device type, browser, operating system, IP address, and usage data

· Functional Data: Photos (for mobile deposit), contacts (for payment services), or location (for branch/ATM services), when permitted

Where applicable under state or federal law, you may request deletion of your personal information by contacting us at 800.244.8161.

Certain information may be retained as necessary to:

· Maintain your account relationship

· Comply with legal and regulatory obligations

· Support fraud prevention and security efforts

To provide a better and more effective website experience, Bay State Bank uses “cookies” as part of our interaction with your browser. Cookies are small text files stored on your device.

We use cookies to:

· Maintain secure sessions

· Improve website performance

· Understand how visitors use our website

We do not use cookies to collect personally identifiable information or to determine your identity.

· Strictly Necessary Cookies – Required for website functionality, including login sessions and form navigation

· Performance Cookies – Help us understand how visitors interact with our website and improve usability

· Functionality Cookies – Allow us to remember user preferences and personalize your experience

Most web browsers automatically accept cookies, but you may modify your browser settings to decline them. Disabling cookies may impact your ability to use certain features of our website.

Use of online and mobile banking services may require the Bank to share personal information with third parties that support service delivery, including our core and digital banking providers such as COCC.

This information is used solely to provide requested services and is protected in accordance with applicable security standards.

If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect location data when you use the Services even when the app is closed or not in use; for example, to provide our fraud detection services. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the App.

Secure Messaging within online and mobile banking provides a protected method of communication. Access requires authentication credentials.

The Bank retains copies of Secure Messaging communications to assist with servicing requests and follow-up inquiries.

Email is not a secure method of communication. Please do not send confidential or sensitive information via email. Instead, use Secure Messaging, contact us by phone, or send information via regular mail

The Bank maintains procedures designed to ensure that customer financial information is accurate, current, and complete. We will not provide information to consumer reporting agencies if we know it to be inaccurate.

Access to personally identifiable information is restricted to employees who require it to perform their job responsibilities. Bank management enforces policies and procedures designed to uphold privacy standards.

Bay State Bank maintains security standards and procedures to protect customer information, including:

· Encryption and secure authentication methods

· Multi-factor authentication for digital banking

· Ongoing system monitoring and testing

· Controlled internal access

Online banking access requires secure credentials. Protecting this information is essential to maintaining account security.

Some third-party services may allow you to access your accounts through external platforms. Bay State Bank cannot guarantee the security of these services.

Important: Any transactions initiated using credentials you provide to third parties may be considered authorized. Use caution and only share information with trusted providers.

Bay State Bank does not disclose specific customer account information to non-affiliated third parties except when:

· The customer authorizes or requests it

· It is necessary to complete a transaction

· It is provided to credit reporting agencies

· Disclosure is required or permitted by law For additional details, please refer to our Privacy Policy.

At Bay State Bank, protecting your information is part of how we build trust and serve our community. We remain committed to safeguarding your information while delivering a secure and seamless banking experience