1st Time User

ELECTRONIC BANKING DISCLOSURE

We Respect Your Confidentiality and Value Your Trust.

Evolving technology and new market practices have increased the amount of customer information collected and shared in today’s marketplace. Consumers may be concerned about the impact that collection of this information may have on their privacy. At Passumpsic Savings Bank we are sensitive to the importance of these concerns. Our goal is to serve you as effectively, efficiently and conveniently as possible, while also protecting the confidentiality and security of the information you provide us. We do not disclose information about you to third parties unless you request or authorize it, or disclosure is otherwise permitted or required by law.

We use technology to manage and maintain customer information in order to provide our customers with a broad range of financial products and services as efficiently as possible.
We want you to understand what information we collect about you and how we use it. This Notice describes our policies and practices for the collection, use and security of nonpublic personal information about our individual customers (consumers), including both present and former customers.

What Information We Collect

• We may collect “nonpublic personal information” about you from the following sources:
• Information we receive from you on applications for a loan or other product or service, or on other loan or account forms;
• Information about your transactions with us, with other companies related to us by common control or ownership (“affiliates”) or with others; and
• Information we receive from third parties such as credit bureaus and consumer reporting agencies

“Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial product or service that you obtain for personal, family or household purposes. For example, nonpublic personal information includes your social security number and information about your assets, liabilities and income, and your accounts and relationships with us, such as account balances, loans, loan charges, payment history and overdraft history.

What Information We Disclose

As further described below, we may disclose some or all of the nonpublic personal information
we collect about you to third parties within or outside our corporate family.

To Affiliates:

We are permitted under law to share with companies related to us by common control or ownership (“affiliates”) your name, address, telephone number, and similar identifying or contact information, as well as information about our own experiences or transactions with you or your account, such as your account balances and your payment history with us. We may also share other information about you (such as credit reports and information we receive from you in applications) with our affiliates when authorized by you. Our affiliates include our mortgage company subsidiary, Northeast Home Loan, and our parent company, Passumpsic Bancorp,
a mutual holding company.

To Nonaffiliated Third Parties:

In certain circumstances, we are permitted or required under law to disclose nonpublic personal information about you to third parties that are not members of our corporate family (“nonaffiliated third parties”). For example, we may disclose nonpublic personal information about you:

To our auditors or to regulatory authorities in connection with a financial audit or examination
of the bank;

• To government entities or in response to a subpoena or court order;
• To credit bureaus or other consumer reporting agencies;
• To persons acting in a fiduciary or representative capacity on your behalf;
• To companies we hire to provide operational support or to assist us in assessing the quality of services we provide to you;
• To complete a transaction initiated by you or to provide a product or service specifically requested or authorized by you.

We may disclose nonpublic personal information about you and your accounts to nonaffiliated third parties who assist us in marketing our own products and services, such as printers, mail houses and advertising and marketing firms.

We may also disclose certain nonpublic personal information about you to other financial service providers with which we have joint marketing agreements. Our joint marketing partners may include firms that offer the following kinds of financial products and services: insurance, securities brokerage, credit cards, leasing, mortgage banking, tax preparation, fiduciary services, estate and financial planning, and investment management and advisory services. The types of nonpublic personal information we may disclose in these situations is limited to information about our own transactions or experiences with you (such as the fact that you maintain an account relationship with us and your account balances and payment history with us), as well as your name, address, telephone number and similar contact information.

We require nonaffiliated third parties to whom we disclose customer information to maintain the confidentiality and security of that information.

Health and Medical Information

We will not use or disclose, internally or externally, personally identifiable health or medical information about you for any purpose other than underwriting or administration of an insurance policy, claim or account, or otherwise for the purpose for which the information was disclosed
to us, or as permitted or required by law.

Our Security Procedures

We maintain physical, electronic and procedural safeguards in accordance with standard banking industry practices and regulatory requirements to help prevent unauthorized access to confidential information about you.

We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, training programs and our policy on ethics, and we train them in the proper handling of customer information. Employees who violate our policies and procedures are subject to our normal disciplinary process.

Maintaining Accurate Customer Information

We make every effort to maintain complete and accurate information about you and your accounts. If you believe any information we have on file is not accurate, please contact us.
We do not recommend that you contact us by email if your message includes sensitive account or other personal information, as transmissions over the Internet may not be secure.

How to Contact Us

• If you have questions or comments on this Privacy Notice, you may:
• Call us at 1-800-370-3196
• Send us an e-mail at depositservices@passumpsicbank. com
• Write to us at:

  Passumpsic Savings Bank

  497 Railroad St. ,
  P. O. Box 38
  St. Johnsbury, VT 05819

Please direct all correspondence about this Privacy Notice to the attention of the Security Officer.

This Privacy Notice (last revised February 2011) replaces all earlier versions of the Notice.
We reserve the right to change our privacy practices and this Notice from time to time in the future. If we do so, you will receive a revised and updated copy of this Notice at that time.

This privacy statement does not apply to business customers or accounts. It is not intended to create a contract or to create or expand our legal obligations.

Online Security

Internet/Online Security and Privacy Guidelines

Customers may have concerns about the security and privacy of their transactions involving the use of the Internet. Passumpsic Savings Bank is committed to protecting the security of customer information in the Internet environment.

How we use information collected over the Internet is covered by our Privacy Notice.

The security measures applied by Passumpsic Savings Bank are covered by the
SECURITY AND PRIVACY section of our Online Banking.

Protecting Information Online

Protect Your Personal Information on-line. Whether you are a customer or just visiting us Online at passumpsicbank. com, we safeguard the information you provide to us. How we protect this information is described below.

How We Handle Email

We preserve the content of your email, your email address and our responses so that we are able to handle more efficiently any follow-up questions you may have. We may also do this to meet legal and regulatory requirements. If we think that a particular Passumpsic Savings Bank account or service might apply to your situation, we may occasionally contact you at your email address to inform you of potential benefits and availability.

Your emails to us should be sent to Passumpsic Savings Bank. Email us at depositservices@passumpsicbank. com

Email correspondence sent over the Internet may not be secure. Therefore, you should not include confidential information (such as your account numbers, Social Security number,
tax identification number or account password) in any email communication to us. Our email response to you will not include confidential account information. You may contact us by phone, by U. S. mail or by visiting your nearest banking office to review that information.

What We Do with Online Surveys

The information you provide in response to promotions on our Website will be used for internal marketing purposes, including developing Website information and products and services that you may find helpful. In addition, we may inform you of new products and services from Passumpsic Savings Bank based on information you provide us.

How We Secure Online Banking

When you bank online with us, we, along with the outside companies we work with to bring these services to you, have access to your information. Information is retained on our system or the system of the appropriate outside company, depending on what is required in order to serve you.

We use state-of-the-art Internet technology to make online banking secure and to protect your personal information. We also require I. D. and a password to access your accounts. If you do not provide this information, we cannot establish an online banking service for you.

You can help maintain the security of your banking information by not sharing your I. D. or password with anyone, by changing your password regularly, and by remembering to log off.

Protecting Your Privacy Online

Whenever we ask for personal information on our Website, we use a Verisign secure site to transfer data. This technology encrypts or scrambles your account information so it’s protected from unauthorized viewers.

When Information is Collected and Not Collected

Some areas of our Website require information, such as your email address or your account number, to enable you to perform certain tasks (for example, review your accounts or correspond with us). In those cases, we collect your information, if necessary, to interact with you. If you do not interact with us and you browse our Website anonymously, then personal information such as your email address is not collected.

Protecting Our Children

We do not knowingly solicit data from children, and we do not knowingly market to children.
We recognize that protecting children’s identities and privacy online is important and that the responsibility to do so rests with both the online industry and with parents.

Count on Our Commitment to Your Privacy

You can count on us to keep you informed about how we protect your privacy and limit the use of information you provide to us—whether at our banking offices, over the phone or through the Internet.

A Note About Links to Other Sites

Our Website has links to other sites. In a few cases we link to private organizations, with their permission. Before leaving the Passumpsic Savings Bank Website, a page will appear informing you that you are leaving our server. Once you link to another site, you are subject to the Privacy Notice of the new site.

Please note that since we cannot control information on other Internet sites, we are not responsible for the content of sites linked from passumpsicbank. com. and do not endorse
any product or service that may be referred to on those sites.

PASSKEYBANKER

(First posted February 5, 2001)

Passumpsic Savings Bank Online Access Agreement and Disclosure

Please read the Passumpsic Savings Bank Online Access Agreement and Disclosure (the “Agreement”) below. It includes disclaimers of liability and other matters of interest to users.
By pressing the “I Agree” button at the end of the Agreement, you agree to the terms and conditions of the Agreement. If you press the “I Do Not Agree” or “Cancel” buttons, you will be returned to the Passumpsic Savings Bank home page.

You must scroll down to read this entire document. When finished click the “I Agree” button if you wish to accept the Agreement and continue.

Please print or download a copy of the Agreement for your files. You can print the Agreement
in a number of ways. Right-click over the page to access the Print option on that menu, or use the browser’s Print icon. You can also go to the File and Print commands in the browser window.

You should also read and download a copy of Passumpsic Savings Bank’s Privacy Policy which you may view by clicking on the link located at the top of this page or on our home page at http://www. passumpsicbank. com.

You may request a copy of this Agreement or our Privacy Policy by calling a Bank Customer Service Representative at 1-800-370-3196 (or for local calls in the St. Johnsbury, Vermont area, 748-3196) during regular business hours.

Your use of Passumpsic Savings Bank’s online banking services (“PasskeyBanker”and Telephone Banking ) constitutes your agreement to the terms of this Agreement and acknowledgement that you have received a copy of Passumpsic Savings Bank’s Privacy Policy.

TABLE OF CONTENTS

1. Eligibility to Become an Online Banking Customer

2. Accessing Your Bank Accounts through PasskeyBanker

a. Accounts

b. Fee

c. Electronic Mail (E-mail)

d. New Services

e. Benefits of Using PasskeyBanker

f. Obtaining Account Balance and Transaction History

g. Joint Accounts

h. Account Statements

3. Your Electronic Signature

4. Security; Your PasskeyBanker Password

5. Payment Account

6. Your Responsibilities

a. Release and Indemnification

b. Screen Scrapers and Information Aggregators

c. Computer Performance

7. Limited Liability

8. Days and Hours of Accessibility; Cut Off Time for Transactions

9. Maintaining Sufficient Available Funds; Overdrafts

10. Limits on Certain Transfers

11. Changes to Charges, Fees or Other Terms

12. Disclosure of Account Information; Your Consent to Disclosure

13. Electronic Funds Transfer Notices

a. Questions or Errors Correction on PasskeyBanker Banking and Bill Payment Transactions

b. Unauthorized Use of Your Password

c. Limitation of Our Liability

14. Other Agreements; Governing Law

15. Your Consent to Electronic Delivery of Documents and Notices

16. Certain Warranties

17. Right to Terminate this Agreement

18. Severability

19. Captions

Introduction

This Online Access Agreement for accessing your accounts through Passumpsic Savings Bank’s internet banking service (“PasskeyBanker”) explains the terms and conditions governing the following online services: certain banking transactions and other banking services offered through Passumpsic Savings Bank Online Services. The accounts that may be accessed through PasskeyBanker Services and Telephone Banking include only accounts maintained with Passumpsic Savings Bank. By using PasskeyBanker and/or Telephone Banking you agree to abide by the terms and conditions of this Online Access Agreement.

The terms “we,” “us,” “our,” and “Bank” mean Passumpsic Savings Bank. The terms “you” and “your” means the person(s) or entity(ies) in whose name(s) the account(s) is/are titled and who has/have enrolled for PassKey Banker and Telebanking under this Agreement. “Authorized user(s) means the individual or individuals who are named in a Corporate Resolution (or similar authorization for a non-corporate entity) as having full authority to access your accounts, and engage in transactions on such accounts, through PassKeyBanker and Telebanking pursuant
to this Agreement. The term “business day” means every day except Saturdays, Sundays
and federal holidays. You can use your computer or other Internet access device to access PasskeyBanker 24 hours a day, 7 days a week, except during any special or scheduled system maintenance periods. Telebanking will also be available 24 hours a day, 7 days a week, except during any special or scheduled system maintenance periods.

This Agreement contains special terms and conditions for accessing your eligible Passumpsic Savings Bank accounts online through PasskeyBanker. Your PasskeyBanker transactions will also be governed by the applicable Terms and Conditions of your account agreements, account fee schedules and other disclosures given to you at the time you opened your account(s), and as they may be amended from time to time (referred to in this Agreement as your “General Terms and Conditions”). If there is a conflict between this Online Access Agreement and the General Terms and Conditions, this Agreement will control.

You agree that we may provide by electronic communication any notice, account statement, data, records, communication or disclosure required to be provided orally or in writing to you. But we may require written confirmation from you of your electronic communications with us. Additional information on electronic delivery of communications from us is contained in Section 15 of this Agreement.

1. Eligibility to Become an Online Banking Customer

To access your accounts via PasskeyBanker, you must:

• have a Passumpsic Savings Bank deposit and/or loan account for which you are primary or secondary account signer (special title accounts like Estate, Trust, etc. can not be used for online enrollment) or an account in the name of your business entity.
• if a business entity, provide a Corporate Resolution (or similar authorizationfor non-corporate entities) naming authorized employees to use PassKeyBanker
• have an E-mail address
• have a taxpayer ID number or tax exempt number
• select your personal, confidential password
• have access to the internet with a secure browser that supports Secure Socket Layer (SSL) and [128]-bit encryption, such as Microsoft Internet Explorer version 6. 0 or higher or Netscape Navigator version 6. 1 or higher
• (for individuals) be at least 18 years old

In Passumpsic Savings Bank’s sole discretion, it may refuse to open any account(s) for new customers and it may refuse to accept any existing or new customer for PasskeyBanker services.

2. Accessing Your Passumpsic Savings Bank Accounts through PasskeyBanker

a. Accounts

To use PasskeyBanker, you must enroll for the service and have one or more eligible Bank accounts (listed below) and an online password.

Passumpsic Savings Bank Accounts Accessible through PasskeyBanker:

• Checking Accounts
• Statement Savings Accounts
• Statement Money Market Accounts
• Club Accounts
• Loans (other than credit card accounts)

b. Fees

At this time, there are no monthly or transaction fees for accessing your account(s) through PasskeyBanker. Other fees, as described in the applicable General Terms and Conditions,
may apply to services ordered online.

We reserve the right to change our fee structure in the future, including charging fees for the PasskeyBanker service. You will be notified in advance of any such changes.

Please note that you are also responsible for any fees or charges that may be assessed and billed by your online service provider and/or telephone company.

c. Electronic Mail (E-mail)

Internet E-mail is not a secure way to communicate with the Bank. Therefore, you agree that if you contact us via E-mail about PasskeyBanker you will NOT include in your E-mail any confidential information about you or your account (such as your account number, taxpayer ID number or password). If it is necessary for you to communicate confidential information to the Bank for any reason you should do so by contacting a Bank customer service representative in person, by telephone or in writing at the telephone number and address given in Section 13a,
or by visiting one of our banking offices.

As described in Section 15 of this Agreement, you agree to receive communications regarding your account(s), including change-in-term notices regarding PasskeyBanker electronically.

We will not immediately receive E-mail that you send. Therefore, you should not rely on E-mail
if you wish to communicate with us immediately. We will not take actions based on your E-mail requests until we actually receive your message and have a reasonable opportunity to act.

You cannot use E-mail to initiate transactions on your account(s). For banking transactions, please use the appropriate functions within the PasskeyBanker web pages or call a customer service representative at 1-800-370-3196 (or for local calls in the St. Johnsbury, Vermont area, 748-3196), during regular business hours, for assistance.

d. New Services

Passumpsic Savings Bank may, from time to time, introduce new PasskeyBanker services.
We will update this Online Access Agreement to notify you of the existence of these new services. By using these services when they become available, you agree to be bound by the terms contained in this Agreement, as it may be amended from time to time.

e. Benefits of Using PasskeyBanker

Through PasskeyBanker, you can manage your eligible accounts from your home or office on your personal computer. You can use PasskeyBanker to:

• View account balances and review transaction history.
• Transfer money between Passumpsic Savings Bank accounts.
• Transfer money to pay your Passumpsic Savings Bank loan accounts.
• Set up an Automatic Transfer to make monthly transfers from one Passumpsic Savings Bank account to another Passumpsic Savings Bank account.
• Pay your bills to merchants and other third party payees.

f. Obtaining Account Balance and Transaction History

You may obtain balance and transaction history for all eligible accounts that are enrolled in PasskeyBanker. See Section 2. a for a listing of accounts accessible through PasskeyBanker. Account balance and transaction history will reflect account activity through the close of the previous business day. Account history information for deposit accounts is generally available online for the previous statement cycle and the current statement cycle, and for loan accounts for the previous and current year, month and day.

g. Joint Accounts

If two or more people hold a joint account, there are two ways for them to enroll for PasskeyBanker services. First, each account holder may enroll separately, and each will have his or her own password and his or her own separate Online Access Agreement. For PasskeyBanker services, each joint account holder could have his or her own account history set up in the categories he or she establishes. The joint account holders will have access to and share the account history for their jointly held accounts, but they will not share access to any accounts that are separately held. Each joint account holder may perform transactions, obtain information, terminate his or her Online Access Agreement or transact business, take actions or perform transactions permitted under this Agreement. The Bank may rely on the instructions of any joint account holder who has PasskeyBanker password access to the joint account. The Bank is not required to obtain the consent of or give notice to the other joint account holder(s). A joint account holder will not be permitted to gain access to any accounts other than accounts for which he or she is a sole or joint owner.

Alternatively, one holder of a joint account may enroll for PasskeyBanker services with one password. The unenrolled account holder(s) would not be entitled to PasskeyBanker access and would not be entitled to use PasskeyBanker services. But Passumpsic Savings Bank cannot verify the identity of a user whose password has been shared with another person, and Passumpsic Savings Bank will not be responsible for unauthorized access to an account if a joint account holder or other PasskeyBanker customer shares his or her password with another person.

To gain access to mortgage or other loan account information, the primary holder of the account must enroll in PasskeyBanker. Co-signers or guarantors on the account(s) will not have PasskeyBanker access to mortgage or other loan account information.

h. Account Statements

Your PasskeyBanker transactions (including bill payments) will be reflected on your regular account statements.

3. Your Electronic Signature

The first time you access any of your accounts through PasskeyBanker you will be deemed to have signed this Agreement and will be confirming your consent to be bound by all the terms and conditions of this Agreement and will be acknowledging your receipt and understanding of this Agreement and its disclosures. Each time that you engage in a transaction (including bill payment) using PasskeyBanker, you will be deemed to have given a signed authorization to the Bank to act on your electronic instructions.

4. Security; Your PasskeyBanker Password

PasskeyBanker services are offered in a secure environment, provided you use a secure browser. See the computer system requirements described in Section 1 of this Agreement.

The first time you log in to use PasskeyBanker you will be given instructions as to what your initial password is. PasskeyBanker will require you to immediately change this initial password to continue on in the system. For added security, the password is sensitive to upper and lower case letters. For this reason, it is very important to remember your selected password.

Your online password will give you access to your accounts through PasskeyBanker and we are entitled to act on instructions received under that password. This password can be changed within PasskeyBanker. For security reasons, we recommend that you change your online password regularly, that you memorize your password and that you do not write it down or give it to anyone. You agree to keep your password and account data confidential to prevent unauthorized access to your account and to prevent unauthorized transactions on your accounts.

Commercial/Non-Personal-In order to gain access to your accounts via PasskeyBanker, a user must enter your access I. D. number and the confidential password that you select as described above. You are responsible for keeping those numbers confidential. You also agree that requiring use of your access I. D. number and confidential password to access PasskeyBanker is appropriate to your business operations and environment and constitutes a commercially reasonable security procedure.

Commercial/Non-Personal-You agree to divulge your password only to persons who are authorized users on the accounts, as reflected in your Corporate Resolution (or similar authorization for non-corporate entities). Your password can be changed within PasskeyBanker. For security reasons, we recommend that you change your online password regularly, and in all events whenever there is a change in authorized users of the accounts. We also recommend that authorized users memorize the password and that they do not write it down. You agree to keep your password and account data confidential to prevent unauthorized access to your account and to prevent unauthorized transactions on your account(s). Only authorized personnel within your company should have access to this secure password.

If you forget your password, the Forgot Password option is available at the log on screen or you may contact the Bank to have a new temporary password issued to you.

5. Payment Account

Although there are no fees at this time for accessing your accounts via PasskeyBanker, you may be asked to designate a payment account for selected services such as Bill Payment, or for payment of any PasskeyBanker fees and charges should the Bank decide to impose such fees and charges in the future. You agree to pay promptly all fees and charges for services provided under this Agreement, and authorize us to charge the account that you have designated as the payment account, or any other account, for such fees and charges.

If you close the payment account, you must notify us and identify a new payment account for the selected services. If you fail to designate a new payment account, we may charge any other account (including a loan account to the extent there are no funds available in a deposit account). Additionally, if you close all your accounts, you must notify Customer Service immediately to cancel your PasskeyBanker services.

We may cancel your PasskeyBanker services at any time without prior notice due to insufficient funds in one of your accounts. After cancellation, at our discretion, we may reinstate your PasskeyBanker services once sufficient funds are available in your accounts to cover any fees and other pending transfers or debits. In order to request reinstatement of your services, you must call Customer Service at 802-748-3196. These cancellation rights are in addition to those contained in Section 17.

6. Your Responsibilities

Selection, use and dissemination of your password is at your own risk. You should not furnish your password to anyone who is not an authorized user on your accounts. If, despite Passumpsic Savings Bank’s advice, you give your password to anyone, you do so at your own risk. Anyone to whom you give your password will have full access to your accounts, even if you attempt to limit that person’s authority. The Bank is not responsible for establishing the identity of any person using your password or otherwise confirming that they are an authorized user. You must notify the Bank immediately if your password is lost, stolen or compromised.

Other provisions relating to your responsibilities to notify us in certain instances are set forth in Section 13 of this Agreement.

You will be bound by all actions taken and charges incurred by any authorized user pursuant to this Agreement.

You are responsible for paying any applicable fees if there are insufficient funds in your account, or if you provide incorrect or inaccurate information. You are liable for all transactions that you make or authorize, or for all transactions that any of you make or authorize if you are using a joint account, even if the person you authorize exceeds his or her authority.

a. Release and Indemnification

You hereby release Passumpsic Savings Bank, its subsidiaries and other affiliates from any and all liability - and you agree not to make a claim or bring any action against the Bank or any of its subsidiaries and affiliates - for honoring or allowing any actions or transaction by a person or authorized user to whom you have allowed account access, whether that person is a joint account holder or any other person who has gained access to your password.

You indemnify and agree to hold harmless Passumpsic Savings Bank, its subsidiaries and other affiliates and the supplier of the software for Passumpsic Savings Bank’s online banking service from and against any and all claims, losses, liability, cost and expenses (including reasonable attorneys’ fees) arising from your violation or breach of this Agreement or of any third party rights, including copyrights, proprietary and privacy rights, or any applicable federal, state or local law, regulation or ordinance.

Your obligation under this Section will survive termination of this Agreement.

b. Screen Scrapers and Information Aggregators

You should be aware of a practice commonly known as “screen scraping” or “information aggregation” whereby so-called “information aggregators” make available to their customers
a web site on which the customers may view information obtained from other web sites. For example, a customer, Jane Doe, might have brokerage accounts, credit card accounts, bank accounts, insurance accounts and loans with a number of different entities that provide online access to Ms. Doe. For each entity with which Jane Doe has online account access, Ms. Doe might have a separate user ID and password, and she would have to log in separately to each entity’s web site to view account information or to perform a transaction on a particular account.

An information aggregator, or “screen scraper,” instead gives Ms. Doe the option to view and manage all of her online accounts held by the various banking, securities, insurance and lending entities in one place - on the aggregator’s web site. Often, the composite information from the various entities is reformatted to the information aggregator’s standards. To make this possible, the information aggregator will ask you for your user ID and password for the various online accounts you wish to view on the information aggregator’s web site. If you give the information aggregator this information, you do so at your own risk. Passumpsic Savings Bank cannot verify the identity of the person gaining access to your account with your user ID and password, whether that person is you, an authorized user, or another individual to whom - despite the Bank’s advice - you have given your password, or an information aggregator. Passumpsic Savings

Bank, its subsidiaries and other affiliates will not be liable for the consequences if you share your password and account information with others.

Passumpsic Savings Bank’s privacy policies protect customers’ nonpublic personal information. If you choose to give your password and account information to a screen scraper or information aggregator, you should consider whether that person or company will protect your nonpublic personal information to the same extent that Passumpsic Savings Bank will. You should read carefully the screen scraper’s or aggregator’s terms and conditions of service before you subscribe for its services. Passumpsic Savings Bank is not responsible for the actions or practices, including information sharing practices, of any screen scraper or aggregator.

Passumpsic Savings Bank reserves the right to monitor your PasskeyBanker usage. We may terminate your PasskeyBanker service if we have reason to believe an information aggregator or screen scraper is gaining access to your accounts.

c. Computer Performance

Passumpsic Savings Bank, its subsidiaries and other affiliates assume no responsibility and disclaim any and all liability for loss or damage associated with the functionality or operation of your computer, your connection to the PasskeyBanker service, your browser software or your Internet service provider’s services or performance, including loss or damage arising out of computer viruses.

7. Limited Liability

Passumpsic Savings Bank agrees to make reasonable efforts to ensure performance of PasskeyBanker. We will be responsible for acting only on those instructions sent through PasskeyBanker which are actually received and cannot assume responsibility for malfunctions in communications facilities not under our control that may affect the accuracy or timeliness
of messages you send. We will not be responsible for any losses or delays in transmission
of instructions arising out of the use of any Internet access service provider or caused by any browser software. We will not be responsible should you give incorrect instructions or if your payment instructions are not given sufficiently in advance to allow for timely payment or delays in mail service.

Passumpsic Savings Bank’s liability is also limited as described in Sections 6 and 13.

Without limiting the generality of the previous two paragraphs and except as specifically otherwise provided in this Online Access Agreement or where the law requires different standards, you agree that neither we nor our service providers (including without limitation, any third party payment agents of the Bank with respect to the bill payment feature of PasskeyBanker) will be responsible for any loss, property damage or bodily injury, whether caused by the equipment, software, the Bank, OR by any Internet browser providers such as Netscape (Netscape Navigator browser) and Microsoft (Microsoft Explorer browser), OR by Internet access providers OR by online service providers OR by an agent or subcontractor of any of the foregoing, nor shall we or the service providers be responsible for any direct, indirect, special or consequential, economic or other damages arising in any way out of the installation, use or maintenance of the equipment, software, the Online Services, or Internet browser or access software or arising out of any computer virus or unauthorized access to or alteration of the PasskeyBanker program.

NEITHER PASSUMPSIC SAVINGS BANK, ANY SUBSIDIARY OR OTHER AFFILIATE OR SERVICING AGENT OF THE BANK, ANY TRANSMISSION OR INTERNET ACCESS PROVIDER NOR ANY SOFTWARE SUPPLIER, MAKES ANY EXPRESS OR IMPLIED WARRANTIES CONCERNING PASSKEYBANKER SOFTWARE OR SERVICES OR BROWSER, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT OF THIRD PARTY PROPRIETARY RIGHTS UNLESS DISCLAIMING SUCH WARRANTIES IS PROHIBITED BY LAW.

IN NO EVENT WILL PASSUMPSIC SAVINGS BANK OR ANY OF ITS SUBSIDIARIES OR OTHER AFFILIATES BE LIABLE TO YOU OR ANY THIRD PARTY UNDER THIS AGREEMENT FOR INDIRECT, SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES.

8. Days and Hours of Accessibility; Cut Off Time for Transactions

You can access your accounts through PasskeyBanker seven days a week, 24 hours a day. However, at certain times, some or all of the PasskeyBanker online services may not be available due to system maintenance. During these times, you may use a Passumpsic Savings Bank ATM or (if during regular business hours) a bank branch to conduct your transactions; however, the bill payment feature may not be available.

A transfer initiated through PasskeyBanker by 5:00 p. m. (Eastern Time) on a business day is posted to your account the same day. All transfers completed after 5:00 p. m. (Eastern Time)
on a business day or on a Saturday, Sunday or banking holiday will be posted on the next business day.

Every day is a business day except Saturdays, Sundays and federal holidays.

9. Maintaining Sufficient Available Funds; Overdrafts

You are responsible for maintaining at all times sufficient available funds in your accounts to cover all debits or withdrawals, in whatever form, including those made through PasskeyBanker.

Uncollected funds in your payment account are not considered as part of the available balance until the funds have cleared.

If we receive requests of any kind for debits from your account, whether or not received via PasskeyBanker Bill Payment, check, ATM transaction or otherwise, and there are not enough available funds in the account to cover all the requests, we reserve the right to pay or decline to pay any such items and to decide the order in which they are paid, unless otherwise required
by law. If an overdraft is created, overdraft fees will apply.

10. Limits on Certain Transfers

Your ability to transfer funds between and/or make payments from certain accounts is limited by law, as described in the General Terms and Conditions for such accounts. You may make up to a total of 6 pre-authorized, automatic or telephone transfers or payments per statement cycle from your Non-PersonalSavings or Money Market Accounts to other accounts or third parties. Transfers and payments from Non-Personal Savings and Money Market Accounts made through PasskeyBanker are counted against the permissible number of transfers or payments.

If a hold has been placed on deposits made to an account from which you wish to transfer funds, you cannot transfer the portion of the funds held until the hold expires.

11. Changes to Charges, Fees or Other Terms

We reserve the right to change the charges, fees or other terms described or incorporated into this Online Access Agreement. When changes are made to any fees, charges, or other material terms, we will update this Online Access Agreement and either send a paper notice to you at the address shown on our records, or send you an electronic mail message (E-mail). The notice will be posted or sent at least thirty (30) days in advance of the effective date of any additional fees for online transactions, or of any stricter limits on the type, amount or frequency of the transactions or any increase in your responsibility for unauthorized transactions, unless in our reasonable judgment an immediate change is necessary to maintain the security of the system. If such a change is made, and it can be disclosed without jeopardizing the security of the system, we will provide you with electronic or written notice within thirty (30) days after the change. As always, you may choose to accept or decline changes by continuing or discontinuing the accounts or services to which these changes relate. Your continued use of PasskeyBanker after we notify you of a change will signify your acceptance of the change. We also reserve the sole discretion, in our business judgment, to waive, reduce or reverse charges or fees in individual situations. Changes to the fees and charges on your accounts will also be governed by the applicable General Terms and Conditions for those accounts.

12. Disclosure of Account Information; Your Consent to Disclosure

You authorize the Bank to disclose to third parties (whether or not affiliated with the Bank) information you have provided or that we or our subsidiaries or other affiliates have obtained about your accounts with us and the transfers you make:

• To comply with government agency or court orders or requests; or
• To verify the existence and condition of your account for a third party, such as a credit bureau or merchant; or
• Where it is necessary for completing transfers, including bill payments, or other account transactions; or
• To provide services relating to your account or to offer other products and services;
• In accordance with the Bank’s Privacy Policy, which is posted on the Bank’s website; or
• For any other purpose if it is otherwise required or permitted by law or if you give us your permission

Except as otherwise prohibited by law, by enrolling for PasskeyBanker you expressly agree that Passumpsic Savings Bank may share with its subsidiaries and other affiliates the information about you that you provide, or that Passumpsic Savings Bank obtains as a result of your transactions or other account activity, for, among other things, the purpose of offering you products and services that we believe may be of interest to you.

You agree that Passumpsic Savings Bank may download certain information about you, including customer identification information, to your computer or other access device. This is known as an Internet “cookie. ” You can disable this feature on your Internet browser if you so choose.

13. Electronic Funds Transfer Notices (Does not apply to Commercial/Non-Personal Accounts)

PasskeyBanker enables you to transfer funds to or from your eligible Passumpsic Savings Bank accounts. The federal Electronic Funds Transfer Act provides you with certain rights and responsibilities with respect to such transfers, called “Electronic Funds Transfers. ” Before you complete your first electronic funds transfer using PasskeyBanker, you must read this section which explains your rights and responsibilities under the Electronic Funds Transfer Act.

a. Questions or Error Correction on PasskeyBanker Banking and Bill Payment Transactions

In case of questions or errors about online funds transfers or bill payments made through PasskeyBanker, you should do one of the following as soon as possible:

• Call Customer Service at 1-800-370-3196 (or for local calls in the St. Johnsbury, Vermont area, 748-3196), or visit a Customer Service Representative at one of our banking offices.
• Write to Passumpsic Savings Bank, Customer Service Department, 497 Railroad Street, PO Box 38, St. Johnsbury, VT 05819, as soon as you identify any errors or discrepancies in your statement or transaction record, or if you need more information about a transaction listed on the statement or transaction record.

We must hear from you no later than sixty (60) days after we have sent the first paper or online statement on which the problem or error appeared. By contacting us, you will not be liable for unauthorized transfers or withdrawals that occurred during the 60-day period, except for transfers and withdrawals resulting from lost or stolen password as described below in subsection b. If you don’t contact us within this 60-day time period, you could be held responsible for all unauthorized transfers and withdrawals that occurred between the end of the 60-day period and the time you actually notified us, and if the transaction could have been prevented if we had been notified.

Naturally, we may extend the time periods if you were prevented from contacting us for a good reason (such as a long trip or hospital stay).

If you notify us orally, we may require that you send us your complaint or question in writing within ten (10) business days.

When you tell us about the problem, please:

• Tell us your name and account number.
• Describe the error or the transaction you are unsure about, and explain as clearly as you can why you believe it is in error or why you need additional information.
• Tell us the dollar amount of the suspected error.
• For a bill payment, tell us the checking account number used to pay the bill, payee name, scheduled payment date, payment amount, reference number, and payee account number for the payment in question.

We will determine whether an error occurred within 10 business days (20 business days if the transfer involved a new account) after we hear from you, and we will correct any error promptly. If we need more time, however, we may take up to 45 calendar days (90 calendar days if the transfer involved a new account, a point-of-sale transaction or a foreign-initiated transfer) to investigate your complaint or question. If we decide to do this, we will provisionally credit your account within 10 business days (20 business days if the transfer involved a new account) for the amount you think is in error, so that you will have use of the money during the time it takes us to complete our investigation. If we ask you to put your complaint in writing and we do not receive it within 10 business days, we may not provisionally credit your account while we complete our investigation. We will tell you the results of our investigation within three business days after we complete our investigation. If we decide that there was not an error, we will send you a written explanation. You may ask for copies of the documents used in our investigation.

b. Unauthorized Use of Your Password

Be sure to keep your online password to yourself; this number is an important means of protection for you. Don’t write it on your personal computer or any computer materials, or any other access device. Contact a Customer Service Representative at 1-800-370-3196 (or 748-3196 for local calls in the St. Johnsbury, Vermont area) immediately if you believe than an unauthorized person has obtained access to your online password. The telephone is the fastest way to alert us that someone may be using your software or online password without your permission. You could lose all the money in your account.

If you cannot telephone, visit one of our banking offices or write us at the address provided above in Section 13a.

If you notify us within two business days after discovering that someone has obtained access to your PasskeyBanker online password, you will not be held responsible for any unauthorized transfers or withdrawals over $50, providing that you are not trying to defraud us.

If you do not contact us within two business days, and we can prove that we could have stopped someone from accessing your account without permission if you had told us, we can hold you responsible for unauthorized transfers or withdrawals that occur between the end of the two-business-day period and the time you actually notified us. In any event, your maximum liability for such unauthorized transfers or withdrawals during this period is $500.

c. Limitation of Our Liability

As described elsewhere in this Agreement, if we do not complete a transfer to or from your Bank account on time or in the correct amount or we fail to cancel a transfer if properly requested, we will only be liable for your actual losses. However, there are some exceptions. We will NOT be liable:

• If, through no fault of ours, you do not have enough money in your account to make a transfer or bill payment.
• If a legal order directs us to prohibit withdrawals from the account.
• If your account has been frozen.
• If your account is closed.
• If you, or anyone you allow, commits any fraud or violates any law or regulation.
• If any electronic terminal, telecommunication device or any part of the electronic fund transfer system is not working properly and you knew about the breakdown when you started the transfer.
• If you have not provided us with complete and correct payment information, including without limitation the name, address, account number, and payment amount for the payee on a bill payment.
• If you have not properly followed the instructions for using PasskeyBanker service.
• If circumstances beyond our control (such as flood, fire or improper transmission or handling of payments by a third party) prevent or delay the transfer or bill payment, despite reasonable precautions taken by us.

Passumpsic Savings Bank cannot be responsible for customer errors or negligent use of the PasskeyBanker service and will not cover losses due to your:

• Input errors or misuse of the online service.
• Negligent handling or sharing of passwords leading to an unauthorized access to your accounts.
• Leaving your computer unattended during an Online Banking session - you must “Sign Off/Log Off” to end your session.
• Failure to report known incidents of unauthorized account access immediately.

14. Other Agreements; Governing Law

In addition to this Online Access Agreement you agree to be bound by and will comply with the requirements of the applicable General Terms and Conditions relating to the accounts, the Bank’s rules and regulations, the rules and regulations of any funds transfer system to which the Bank belongs, and applicable Vermont and federal laws and regulations. We agree to be bound by them also.

15. Your Consent to Electronic Delivery of Documents and Notices

You agree that we may send or provide by electronic communication any notice, communication, statement, document or disclosure required to be provided orally or in writing to you. We may require written paper confirmation from you of any electronic communications this Agreement permits you to make to the Bank.

Your consent to electronic delivery of documents and notices applies to any and all transactions effected by you using the PasskeyBanker service and any and all notices, agreements, confirmations, account statements and other disclosures, information, data or records (“Electronic Records”) that are required to be or that may be provided by Passumpsic Savings Bank to you. You will not attempt to circumvent receiving any Electronic Records. You are deemed to have received any Electronic Records sent to you when they are made available to you. If you elect to receive e-stmts you must supply the Bank with your account numbers and a valid e-mail address. You will receive an e-mail message notifying you that your statement is available. Upon signing on to Passkey Banker with your user name and password, you then choose the account number, click the “DOCUMENTS” button, click on the statement line, and then choose the statement you need and your statement will appear using ADOBE, you can download free adobe reader upgrades at www. adobe. com You may print a copy of any Electronic Records by using a printer and the “print” function of your software.

Although you consent to electronic delivery, you may withdraw your consent or request paper copies of Electronic Records at any time. If you wish to withdraw your consent to delivery of Electronic Records, you must do so in writing to Passumpsic Savings Bank at the address set forth in Section 13a of this Agreement. You may also write to that address to request paper copies of Electronic Records and to update information Passumpsic Savings Bank uses for contacting you electronically or you may update the information by using “Modify Account Access” feature of PasskeyBanker system.

Passumpsic Savings Bank reserves the right to charge a fee to provide paper copies of Electronic Records.

16. Certain Warranties

By signing this Agreement you warrant that (i) execution of this agreement has been properly authorized by your Board of Directors or other governing body if you are not a corporation and (ii) each authorized user on your account(s) is at least 18 years old. By using PasskeyBanker for the first time, you will be deemed to have read our Internet/Online Security and Privacy Guidelines.

17. Right to Terminate this Agreement

We reserve the right to terminate this Online Access Agreement and your access to Internet banking services through PasskeyBanker, in whole or in part, at any time and for any reason.

You may terminate this Agreement at any time by notifying us electronically or by mail at the address provided in Section 13a of this Agreement. This will not terminate your accounts with Passumpsic Savings Bank.

18. Severability

In the event any one or more of the provisions of this Agreement are for any reason held to be invalid, illegal or unenforceable, the remaining provisions will remain valid and enforceable.

19. Captions

The section and paragraph captions in this Agreement are for convenience only. They do not constitute part of this Agreement and they will not limit or otherwise affect any of the provisions of this Agreement.

By using the PasskeyBanker service you agree to all of the terms of this Agreement and in particular: you confirm that you are at least 18 years of age and meet the other requirements for eligibility in Section 1 of this Agreement; you acknowledge having received a copy of Passumpsic Savings Bank’s Privacy Policy; you consent to electronic delivery of Electronic Records as set forth in Section 15 of this Agreement; and you consent to the sharing of information about you and your transactions as set forth in Section 12 of this Agreement.