BANCORPSOUTH'S RESPONSIBLE USE AND PROTECTION OF CUSTOMER INFORMATION: OUR PRIVACY PRINCIPLES

(See also the separate Affiliate Marketing Notice)

The Family of BancorpSouth  Companies:

• BancorpSouth Bank
• BancorpSouth Investments Services, Inc.
• BancorpSouth Insurance Services, Inc., including its Stewart Sneed Hewes
•  Wright & Percy
•  Ramsey
•  Krug
•  Farrell 
•  Lensing
•  SMI Group
• JMG/ic divisions

Our Commitment

We want you to understand our long-standing commitment to personal privacy in our use of customer information. As we move forward with new products and services in an era of rapid technological and market changes, we will continue to maintain our dedication to assuring  that customer information is properly used and appropriately safeguarded. For these reasons, we have developed and adopted these Privacy Principles.

Our Goal

BancorpSouth's goal is to serve you as conveniently and effectively as possible and with the recognition that your relationship with BancorpSouth should always be treated with appropriate confidentiality. With BancorpSouth's Privacy Principles, we are confident you will agree that privacy and confidentiality remain guiding principles upon which BancorpSouth's services are based.

Our Policy Statement

BancorpSouth will take reasonable steps to protect the privacy of customer information. Our customers are protected not only by state and federal laws, but also by BancorpSouth's commitment to them. Current marketing practices and ever-changing technology have increased the amount of customer information that is collected and shared today. BancorpSouth is sensitive to customer concerns about the impact these developments might have on their privacy and BancorpSouth desires that our customers maintain confidence that their relationships with BancorpSouth are treated with appropriate confidentiality.

We will limit the collection and use of information about our customers to that which is necessary to administer our business, provide superior service, and extend offers that we believe will be of interest to our customers. This means we will use such information to help us identify and mitigate potential risks or loss to BancorpSouth and help identify additional products or services which we believe customers might want to know about.

As more fully explained below, we are lawfully allowed to share certain information with our affiliated companies and with companies with which we have joint marketing arrangements even if you request that we limit the sharing of other information. It is our policy to share the allowable information among our affiliated companies and joint marketing entities to the fullest extent permitted by law.

The Principles

Information Collection and Accuracy: Information about customers is accumulated from a variety of sources. Some information is provided to BancorpSouth directly by customers. Other data is developed by BancorpSouth as a result of providing a product or service to a customer. Still other information is obtained from outside sources. We will employ reasonable measures to ensure the accuracy, timeliness and completeness of our customer information. If we become aware of inaccuracies in our records, we will take steps promptly to make appropriate corrections.

[Customers should notify us if they receive information regarding a BancorpSouth relationship that they believe to be inaccurate.]

We may collect "nonpublic personal information" which is information about you that we obtain in connection with providing a financial product or service to you. Examples include information regarding your account balance, payment history and overdraft history. Nonpublic information about you may be collected from the following sources:

• Information we receive from you on applications or other loan, policy, claim and account  documents and forms, such as your name, address, assets and income, beneficiaries, and coverage selections or through our communications with you; 
   
• Information about or from your transactions with us, our affiliates or others, such as your account  balances, account activity, payment history, deposit history, financial benefits, parties to transactions, debit or credit card usage, insurance policy histories and coverages, and premium and claims information; 
   
• Information we receive from third parties, including motor vehicle reports and claims histories, and information received from consumer reporting agencies ("credit bureaus"), such as your payment or credit history. 
   
• Information we obtain to verify something you tell us in connection with an application or transaction with us, such as balances, employment, driving records, credit, and other relationships.

[For specific and appropriate products and services only, for example, health or life insurance, limited and additionally restricted nonpublic personal information may also include personal health information such as medical histories and records, and information about your habits, (such as smoking) and about an illness, disability or injury. Such personal health information will only be disclosed upon proper written authorization or as otherwise permitted or required by law. (See the Medical Information Section below).]

Our Use, Disclosure, and Sharing of Customer Information

Under the Gramm-Leach-Bliley Act  and Regulations:  We may disclose any of the kinds of "nonpublic personal information" (as defined and listed above) about you. We may disclose nonpublic personal information about you to our "affiliates," that is, companies related to us by common control or ownership (our "corporate family").

We also are permitted under law to disclose nonpublic personal information about you to"nonaffiliated third parties" in certain circumstances. For example, we may disclose nonpublic personal information about you to third parties to assist us in servicing your loan or account with us, to government entities in response to subpoenas, and to credit bureaus. In addition, we may disclose any of the kinds of "nonpublic information" (as defined above) to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing arrangements.

In addition to the allowable disclosures described above, we may disclose nonpublic information about you to the following types of "nonaffiliated third parties," that is, third parties that are not members of our corporate family but with which we may have or develop business relationships:

If you prefer that we not disclose this other nonpublic personal information about you to nonaffiliated third parties, you may opt out of those disclosures, that is, you may direct us not to make  those  disclosures  (other than disclosures permitted by law). See the Affiliate Sharing/Nonaffiliated Third Party section below. See also the separate Affiliate Marketing Notice required by the Fair and Accurate Credit Transactions Act (FACT Act) and regulations thereunder.

Under the Fair Credit Reporting Act:  Under certain circumstances our customers are protected by the Fair Credit Reporting Act. For example, for the purposes of prescreening business prospects, we may only use consumer reports when a customer or prospective customer has authorized a consumer reporting agency to furnish us a report or when making a customer or prospective customer a firm offer of credit or insurance. While you may not prohibit BancorpSouth from sharing your loan and deposit account history with consumer reporting agencies, you may request that consumer reporting agencies not provide information about you to companies wishing to extend"pre-approved" offers to you for their products or services. You may make this request by calling the "Opt Out Request Line" at 1-888-5OPT-OUT (1-888-567-8688).

We must also notify an applicant if we decline any application made by them and have used a consumer report during the processing of the application. If this occurs, even if the report was not the basis for the decision to decline the application, we will provide the applicant with the name and address of the reporting agency. Customers are entitled to obtain free copies of credit reports from the reporting agencies and have such reports corrected by the agency concerned if those reports contain inaccurate information.

Sometimes, as in the case of insurance, we are merely an agent for the carrier that actually provides the product. In such cases, any decision to decline an application for insurance will be made by the carrier, or another entity affiliated with the carrier, not by BancorpSouth, and the applicant's right to know whether a consumer report was used or why the application might have been declined will apply directly  to the carrier, not BancorpSouth. In that situation, BancorpSouth will tell the applicant whom to contact in order to ask questions or obtain more information.

BancorpSouth and its family of organizations, subsidiaries, divisions, departments, and companies are permitted to share within the BancorpSouth organization information concerning a customer's account history and experiences with BancorpSouth. We may also share among the entities, subsidiaries, divisions, departments, and companies that comprise the BancorpSouth organization and among its divisions:

• Information someone has given us as part of an application for one of our products or services, or information such as income information and credit history that we have received from a consumer reporting agency or other third party which is used to determine your eligibility for credit or for some other product or service (hereafter "Creditworthiness/product-worthiness information").

While it may result in customers not receiving product or service information of interest to them, we will respect anyone's wish that we not share this type of information. You may therefore direct us not to disclose to our affiliates this creditworthiness/product-worthiness information that does not relate solely to BancorpSouth's or its affiliates' experiences or transactions with you or your account. See the Affiliate Sharing/Nonaffiliated Third Party section below. See also the separate Affiliate Marketing Notice required by the Fair and Accurate Credit Transactions Act (FACT Act) and regulations thereunder.

Joint Accounts: If you share an account with someone else, for example, a joint checking or brokerage account, as co-maker on a loan, or if named on an insurance policy because of a joint interest in property, please share these privacy policies and principles (and any other notices and disclosures we make to you) so that each person with a relationship to your account(s) is aware of these policies, notices, and disclosures, and the information sharing options available. If you have a joint account, an opt out choice made by one party to an account will affect all parties to an account.

Additional Information as to Outsources and Outside Vendors: Occasionally, BancorpSouth makes a decision to sell a particular line of business (for example, mortgage servicing rights). Usually, an integral part of that business is its customer database. BancorpSouth reserves the right, in such circumstances, to transfer ownership of such customer databases or other  information to the purchaser.

Customers should also be aware that third parties with which BancorpSouth might have business relationships may also have access to customer information that has been obtained independently of BancorpSouth. Mailings and solicitations based on such information are not within BancorpSouth's control.

With Consumer Reporting Agencies & Other Companies: We may exchange information about our customers with reputable information reporting agencies, financial institutions, and merchants, in accordance with standard industry practice, so they can verify the existence and condition of customers' accounts.

With the Government: State and federal laws impose certain mandatory disclosures of customer information by financial institutions. We must comply with laws requiring mandatory production or disclosure. For example, the Bank Secrecy Act, Internal Revenue Code, Right to Financial Privacy Act, the Anti-Money Laundering Act, the Welfare Reform Act and various other laws and regulations require us or our contractors, under certain circumstances, to provide certain customer information to government agencies. We may be prohibited by law from informing you that such disclosure has been required or requested or that such disclosure is being made by us. [Federal law provides a "safe harbor" for a financial institution and its employees that provides complete immunity from civil liability for the reporting of known or suspected criminal offenses or suspicious activity by use of approved forms or by reporting through other means in accordance with applicable agency regulations.]

With Third Party Litigants: If you are involved in a legal proceeding, (for example, as a party or as a witness), both federal and state law provide parties to the litigation the right to compel the production of records and information from banks and other third party record keepers in certain situations. We will therefore disclose customer information to third party litigants when we are required to do so by lawful judicial process or by court order. In such circumstances, the parties to such proceeding have the obligation to comply with any notice requirements. BancorpSouth has no such notice obligation in these cases and will not therefore undertake to notify you.

Medical Information: In some situations, a person might disclose or authorize the disclosure of medical information as part of an application for a specific product, such as health or life insurance. BancorpSouth recognizes that when consumers provide medical information for such a specific purpose, they do not wish it to be used for other purposes, such as for marketing or in making a credit decision. We will therefore share such medical information only with those who need to know this information in order to process the application or to provide the services you have requested or initiated. We will not allow this information to be used elsewhere within BancorpSouth for any other purpose.

Our Employees: BancorpSouth employees are informed of their responsibility to protect confidential customer information and are bound by these Privacy Principles. Employees are governed by a code of conduct that includes the responsibility to protect the confidentiality of customers' financial and other personal information. Only employees actively engaged in the discharge of their assigned duties are authorized to access or use customer information.

Our Security Safeguards: We maintain security standards and procedures to help prevent unauthorized access to confidential information about you. We update and test our technology to improve the protection of our information about you and to assure the integrity of our information. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. We help protect customers against, and educate customers about how to protect themselves from, criminal use of their information. We use a combination of safeguards to protect customer information, such as employee training, rigorous security standards, encryption and fraud detection. We work with law enforcement officials to pursue individuals who fraudulently use information.

Your Use of Our Website and Internet Banking

       Our online banking products and our user-friendly Internet website "http://www.bancorpSouth.com" invite customers to provide nonpublic personal information about themselves through information request screens from the privacy of their own personal computer. BancorpSouth's internal security measures safeguard your personal information submitted by computer in several ways, including for example, encryption, passcodes and other safety features to ensure that online applications and the financial information you access through online banking are safe and secure.

To enhance customer service, BancorpSouth may occasionally use a "cookie" on our website which is a piece of information that a web server can store on your PC and retrieve later during a browser session only. Cookies do not contain your online banking password nor do they contain any information that will enable anyone to contact you via telephone, e-mail or regular mail. (For more information on the use of our website, please see the User Information and Privacy pages at where we have posted a link which is clearly marked as such.)

Your Options on Information Sharing

One of the benefits of doing business with BancorpSouth is that we are a complete financial services institution. For example, sometimes customers do not realize when they get their mortgage with us that they can also have their new home insured through BancorpSouth Insurance Services. This is just one example of the variety of services we offer. Many customers have said that dealing with one company has made achieving their financial goals easier. We therefore hope you will consider consenting to our information sharing, and we may on occasion ask you to give us your consent. Yet while BancorpSouth takes all the necessary steps to maintain your privacy in this process, we, of course, give you the option to decline this level of service, as we recognize individual choice is what matters most.

You therefore have the right to ask BancorpSouth to limit the sharing of information about you in the following areas and ways.

Affiliate Sharing/Nonaffiliated Third Party.  See also the separate Affiliate Marketing Notice required by the Fair and Accurate Credit Transactions Act (FACT Act) and regulations thereunder: Other than disclosures permitted by law, you may ask us not to share nonpublic information about you with nonaffiliated third parties ("opt out" of nonaffiliated third-party marketing) and you may also limit certain information shared about you within the BancorpSouth family of banks and companies ("opt out" of affiliate sharing). As does this policy, our annual and initial notices to you will provide a convenient form for you to complete and return to us in order to opt-out. Otherwise, call 1-888-797-7711 or write to BancorpSouth Customer Service Center, Attn: Customer Privacy, 2910 West Jackson Street, Tupelo, Mississippi38801, and we will send you an opt out form. To help us process your request for an opt out form, please include your name, address, telephone number, and the appropriate account or policy number(s). Please expect to allow us a reasonable period of time to update our marketing database once we receive your opt out request.

If you select opt out of affiliate sharing, you make the decision that you do not want information that has been provided to us on applications or information that we obtained from outside sources, such as consumer reporting agencies, which is used to determine creditworthiness or product worthiness shared among the BancorpSouth family of banks and companies, (however, we will continue to share other information about you with our affiliates as permitted by law, for example, information about specific transactions and experiences with a customer will still be shared with affiliates and others as permitted by the Fair Credit Reporting Act). Please note however, that each company within the BancorpSouth family of companies will continue to contact its clients and customers with offers of its own products and services. You may therefore continue to receive marketing messages via  your statement(s), as well as telephone and direct mail offers, from BancorpSouth companies.

These Privacy Principles apply to our consumer customers who have a continuing relationship with us and may be applicable to former customers. These principles are currently applicable to BancorpSouth banks and the subsidiaries, affiliates, divisions, departments and companies making up the BancorpSouth family in the conduct of their consumer business. We may change these principles, along with related provisions, at any time.

• For a printer friendly version of our privacy policy, click here.

• To print a copy of our opt out form. Click here.

• (To view and print our opt out form, you must have Adobe Acrobat Reader installed on your computer. To obtain a free copy, click here.)

• Click here  to view the Affiliate Marketing Notice.

Effective Date: This policy was last updated on June 2007.