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Privacy Disclosure for First Place

HOW WE PROTECT AND USE CUSTOMER INFORMATION

First Place and its affiliates* (collectively "First Place Companies" and together with First Place referred to herein as "us", "we" and "our") are concerned about and respect the privacy of your personal financial information. Our customers furnish sensitive information to us in the course of daily business, and we are committed to treating such information responsibly.

We are sending this privacy disclosure to help you understand how we handle customer information.

TYPES OF CUSTOMER INFORMATION WE COLLECT

Customer information means nonpublic, personal information about a customer. We collect customer information from many sources, including the following:

. Information we receive on applications or other forms
. Information about transactions with us or others
. Information we receive from consumer reporting agencies

Customer information does NOT include information from telephones directories, government records or widely distributed media.

*See the back of this privacy disclosure for a list of First Place affiliated companies


SHARING INFORMATION AMONG THE FIRST PLACE COMPANIES

The law permits us to share customer information between First Place Companies. First Place shares information among its affiliates to inform customers of the services provided by the affiliates and to facilitate the application process.

The following types of information may be shared among the affiliates:

. Identification information, such as name, address and telephone number
. Transactional information
. Deposit or loan account balances and payment history
. Externally gathered personal information. This information may be obtained from third parties such as creditors, financial institutions, investment companies or other financial entities.

YOUR PRIVACY CHOICES

We respect your privacy and offer choices as to whether we may share your customer information within the First Place Companies. If you prefer we not share your information within the First Place Companies, you may opt-out, directing us not to share your information. To indicate this choice please complete and return the opt-out form attached to this disclosure. Please allow us 30 days to process your form. Federal regulations require us to provide this notice on an annual basis, whether or not you have previously opted-out of information sharing. If you have previously opted-out of information sharing, you do not need to complete this form.

No response is necessary if you agree that we may share your customer information within the First Place Companies.

If you end your relationship with First Place, we will maintain your privacy choice on file for a period of seven years.

SERVICE PROVIDERS AND JOINT MARKETING VENTURES

We may disclose information we collect, as allowed by law, to companies that perform services on our behalf, or to other financial institutions with which we have joint marketing agreements. In many cases, information sharing is necessary for us to perform services, such as processing ATM transactions or bill payments. You may not opt-out of this sharing. When we provide your information to nonaffiliated third parties, we require those companies and institutions to provide their privacy policies to us.

EMPLOYEE ACCESS TO CUSTOMER INFORMATION

We have a written Information Security Program to maintain physical, electronic and procedural safeguards that comply with federal guidelines, to secure nonpublic personal information. Our employees are trained annually to be sensitive about confidentiality and customer privacy. Access to nonpublic personal information is restricted to those employees who need to know this information so we can provide products and services to you.

THIS STATEMENT DOES NOT EXPAND LEGAL OBLIGATIONS

This statement is not intended to create any liability other than already found in the law.

KEEPING UP-TO -DATE WITH OUR PRIVACY PRACTICES

We will provide notice of our privacy practices annually, as long as you maintain an ongoing relationship with us. You can always review our current disclosure on our Web site at:

www.firstplace.net

For information about our privacy procedures you may contact Brian E. Hoopes, Sr. Vice President and Chief Information Officer, Joanne Harrold, Internal Auditor, or Lynn A. Maizel, Compliance Officer by calling 330-726-3396 or 1-866-388-9255.

*First Place Companies:

First Place Financial Corporation
First Place Bank
First Place Insurance Agency Ltd.
Ravenna Title Agency Ltd.
Titleworks Agency, Ltd.

         
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