Here is the reference- To me "at least once in any period of 12 consecutive months..." is the key for your situation. You did that.
§ 216.5 Annual privacy notice to customers required.
(a)(1) General rule. You must provide a clear and conspicuous notice to customers that accurately reflects your privacy policies and practices not less than annually during the continuation of the customer relationship. Annually means at least once in any period of 12 consecutive months during which that relationship exists. You may define the 12-consecutive-month period, but you must apply it to the customer on a consistent basis.
In life, there is a lot less that could get better and a lot more that could get worse.
MBA Fin/MBS HR
My views only!