First Command Privacy Policy

At First Command, we value you as a customer and are committed to respecting and
protecting your privacy. The First Command Privacy Policy, which applies to the First Command entities identified in Section 7, First Command Family of Companies, is designed to explain what type of information we collect, how it is used, and with whom and under what circumstances it will be shared.

First Command Bank has implemented measures to protect your privacy when banking online with us. For a description of information we collect during online banking and explanations of how it is used and may be shared, read the First Command Bank Online Privacy Policy.

1. Collection of Information

We collect information about you to provide you with superior customer service, save you time, better respond to your needs, and manage our business and risks. We collect information about you from the following sources:

• Directly from you on forms, applications, and other similar documents; via the Internet; by telephone; or other-wise. Examples of this type of information includes your name, address, names of family members, marital status, Social Security Number, employment information, and financial situation, etc.


• From transactions with us or with companies through which we provide you products and services. For example, account balances, holdings, and history (bank, mutual fund, annuity, etc.); insurance coverages, limits, rates, beneficiaries, and claims history.
• From consumer report agencies, such as information relating to your creditworthiness, your credit score, credit usage, and claims history.
• From third parties to verify the information you have given us and protect against fraudulent activity as required by the USA PATRIOT Act.

2. Protecting Your Information

Keeping your information secure is one of our most important responsibilities. We maintain physical, electronic and procedural safeguards that comply with federal regulations to protect your information. We limit access to customer information to those employees and others who have a business reason to know this information. We maintain strict internal policies against unauthorized disclosure or use of client information. Even if you are no longer a customer, we will treat your information in the same manner as if you were still a customer.

3. Information Sharing With Third Parties

Individuals or companies outside the First Command Family of Companies are considered third parties. We will not share your information with third parties so they may market their products to you. Accordingly, you do not need to tell us to refrain from sharing your information with third parties.

We may share the information we collect about you as described above with third parties only as permitted or required by law. For example, we may share information:

• With service providers that assist us with a variety of business activities, including marketing on our behalf, customer service, account administration, online support, and research.
• To protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability.
• To process your requests or provide services regarding a financial product or service you request or authorize (such as mutual funds, financial planning services, insurance, deposit accounts, loans, credit cards, etc.). Companies with whom we may share your information in this regard include mutual fund companies, insurance companies, banks, and transfer agents which maintain your accounts.
• With government entities in response to subpoenas or regulatory requirements.
• With consumer reporting agencies and/or credit bureaus.
• Pursuant to your written consent.

All third parties with whom we share your information are required to protect the confidentiality of the information provided by us and may only disclose such information as permitted by law.

4. Information Sharing Within the First Command Family of Companies

We are required to inform you of your rights to limit our ability to share information within our family of companies. Your rights are described below.

• You may direct us not to share information about your creditworthiness received from you or others (such as information from your application or your employment or credit history) within our family of companies. However, even if you direct us not to share information about your creditworthiness, we may still share certain other information about you within our family of companies as permitted by law (such as your name, address, transactions or balances with us, or survey results).
  
    The reason you share your information with a First Command financial advisor or other First Command representative is so that we may use your information to determine whether the investment, insurance and banking products and services we offer are a good fit for you and to provide you with recommendations and service for these products and services, generally as part of a comprehensive financial plan and related services. In order to accomplish your objective and provide the recommendations and services you request, your First Command financial advisor or other First Command representative may provide your information to First Command Financial Planning, Inc., First Command Financial Services, Inc. and/or First Command Bank and these entities will share your information with each other to ensure that recommendations and services provided consider your complete financial picture (as necessary) and complement each other. Should you choose to exercise your right to prohibit sharing of information among our family of companies, we may be unable to establish or continue a relationship with you as your choice may limit our ability to serve you in this manner.
  
    For information purposes, financial planning and investment products and services are offered by First Command Financial Planning, Inc.; insurance products and services are offered by First Command Financial Services, Inc. (in certain states, First Command Financial Services, Inc. is a separate domestic corporation and does business in California as “First Command Insurance Services”); and banking products and services are offered by First Command Bank.
• You may also direct our companies not to market products or services to you based on information received from one of our other companies. This limitation, however, does not apply in certain circumstances permitted by law, such as if you already have a pre-existing relationship with the company desiring to market its products or services to you.

To inform us about your choices, you may write to the First Command Legal and Compliance Department, 1 FirstComm Plaza, Fort Worth, TX 76109-4999 or call 800-443-2104. Your decision will not expire until you revoke it in writing.

5. Protecting Medical and Health Information

We do not share any medical or health information with third parties or within the First Command Family of Companies, except as necessary to process transactions or services you have requested or initiated. For example, we may share medical or health information you have provided to us in connection with an insurance application with insurance companies to determine your eligibility or for underwriting purposes.

6. The Internet

Industry standard encryption and other security features safeguard our websites and any information you share with us through these websites. All information that we obtain about you through your use of our websites is protected and shared only as described in this notice. Use of our websites may result in “cookies” or similar files being placed on your hard drive for security purposes, to facilitate site navigation, to personalize your experience while visiting our site, and to enhance the overall effectiveness of the site. In all cases, cookies and similar files that we place on your computer do not contain any personal information unless encrypted and do not identify you as an individual or by account number.

Please remember that we will never ask you to provide sensitive information such as user IDs, passwords or account numbers via e-mail. If you receive an e-mail request for this sort of information, do not respond to it and contact us immediately.

We may provide links to non-First Command websites, such as credit bureaus or product providers. If you choose to link to websites not controlled by First Command, we are not responsible for the privacy or security of these websites, including the accuracy, completeness, reliability or suitability of their information. If you are asked to provide information on one of these websites we strongly urge you to carefully study their privacy policies before sharing your information.

7. First Command Family of Companies

The First Command Privacy Policy is provided to you by First Command Financial Services, Inc., and its wholly owned subsidiary companies that offer you various financial services:

• First Command Bank
• First Command Financial Planning, Inc.
• First Command Financial Services (Alabama)
• First Command Financial Services (Hawaii)
• First Command Financial Services (Montana)
• First Command Financial Services (Nevada)
• First Command Financial Services (New York)
• First Command Financial Services (Wyoming)
• First Command Life Insurance Company
• First Command Services Corporation

8. Making Sure Your Information is Accurate

You have the right to review the information we have collected about you to ensure that it is accurate and current. You can also request corrections to any personal information maintained by us.

To review the information we collect about you, submit a request in writing to the First Command Legal and Compliance Department, 1 FirstComm Plaza, Fort Worth, TX 76109-4999. You must describe the kind of information you want to review and include your full name, address, telephone number, and date of birth. Upon receipt of your request, we will contact you within 30 business days to describe what information is available for your review. We will not provide information that we feel is privileged.

To correct information about you, send a written request as describe above, explaining your desired correction. Upon receipt of your request, we will contact you within 30 business days to inform you whether we will make the correction or tell you why we will not. We cannot correct consumer report information, such as your credit report. To do this, you must contact the consumer report agency that provided it.

9. Tips to Protect Your Information

First Command works hard to keep your information secure. You can help by following these tips to protect your information:

• Store personal information in a safe place, and tear up or shred old receipts and account statements before throwing them away.
• Protect your PIN numbers and passwords. Do not share them with anyone unless for a service or transaction you request, and you are confident the other party will protect the information as you would.
• Carry only the minimum amount of identifying information you require.
• Pay attention to billing cycles and statements. Inquire if you do not receive a bill.
• Check account statements carefully to ensure that all charges, checks and withdrawals are authorized.
• Guard your mail from theft. Do not leave bill payment envelopes in your mailbox with the flag up. Instead, deposit them in a post office collection box or at the local post office. Promptly remove incoming mail.
• Order copies of your credit report from each of the three major credit bureaus once a year to ensure they are accurate.
• If you believe you are a victim of identity theft, take immediate action and keep records of your conversations and correspondence. While the steps you must take will vary with your individual circumstances, four basic actions are appropriate in almost every case:


1. Contact the fraud departments of the three major credit bureaus to place a fraud alert on your credit file:
• Equifax (www.equifax.com): 1-888-766-0008 / P.O. Box 740241, Atlanta, GA 30374-0241
• Experian (www.experian.com): 1-888-397-3742 / P.O. Box 9532, Allen, TX 75013
• Trans Union (www.transunion.com): 1-800-680-7289 / P.O. Box 6790, Fullerton, CA 92834


2. Contact the creditors for any accounts that have been tampered with or opened fraudulently.
3. File a report with your local police, or the police in the community where the identity theft took place, and get a copy of the police report.
4. File a complaint with the Federal Trade Commission (FTC). Complaints can be filed by phone at 1.877.IDTHEFT, or through the FTC's identity theft web site at www.consumer.gov/idtheft.



10. Our Commitment




Whether it’s on the Internet, in person, by telephone or by mail, we at First Command are committed to protecting your privacy. And you can rest assured that we will continue to safeguard to the extent possible your information.

Current clients will receive a current copy of the First Command Privacy Policy on an annual basis. In addition, it is available at www.firstcommmand.com or www.firstcommandbank.com. This notice replaces any previous notices provided to you by us about the privacy, security and protection of information. We may amend this notice at any time. We will inform you of changes as required by law.

We hope this information has been helpful to you. If you have any questions about the privacy, security and protection of your information, you may contact us by writing to the First Command Legal and Compliance Department, 1 FirstComm Plaza, Fort Worth, TX 76109-4999.