11/20/08

Please read this Privacy Policy carefully.

PRIVACY PRINCIPLES FOR INDIVIDUALS:

Protecting your privacy is important to our Bank and our employees. We want you to understand what information we collect and how we use it. In order to provide our customers with a broad range of financial products and services as effectively and conveniently as possible, we use technology to manage and maintain customer information. The following policy serves as a standard for all employees for collection, use, retention and security of nonpublic personal information.

What Information We Collect
We may collect "nonpublic personal information" about you from the following sources:
• Information we receive from you on applications or other loan and account forms;
• Information about your transactions with us or others;
• Information about your transactions with nonaffiliated third parties; and
• Information we receive from a consumer reporting agency, such as credit bureaus.
"Nonpublic personal information" is nonpublic information about you that we obtain in connection with providing a financial product or service to you. For example, nonpublic personal information includes information regarding your account balance, payment history, and overdraft history.

What Information We Disclose
We are permitted under law to disclose nonpublic information about you to other third parties in certain circumstances. For example, we may disclose nonpublic 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. We do not disclose any nonpublic personal information about you to anyone, except as permitted by law.
If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.

Our Security Procedures
We also take steps to safeguard customer information. We restrict access to your personal and account information to those employees who need to know that information to provide products or services to you. Employees who violate these standards will be subject to disciplinary measures. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Maintaining accurate information
We continually strive to maintain complete and accurate information about you and your accounts. If you ever believe that our records contain inaccurate or incomplete information about you, please let us know immediately. We'll correct any inaccuracies as quickly as possible.

Consumer reporting agencies
If you believe we have reported inaccurate information about your account to any consumer reporting agency, please let us know in writing. Be sure to include your complete name, current address, social security number, telephone number, account number, type of account, specific item of dispute and the reason you believe the information is wrong. We'll investigate your concern and correct any inaccuracies we find. We'll confirm any actions we take with you.

Internet Privacy
Browsing our Site
When you visit our website to view any pages, read product information, or use our online calculators and tools, you do so without telling us who you are and without revealing any personal information. While we do not collect identifying information about visitors to our site, we do use standard software to collect information for the strict purpose of tracking activity on our site. This allows us to better understand how many people use our site and which pages and features are most popular. To evaluate the usefulness of our site, we may gather and analyze data regarding usage such as:
• The name of your Internet Service Provider,
• The website that referred you to us (if any),
• The date and time the pages were accessed, and
• The page or pages you requested.

About "cookies"
To provide better service and a more effective web site, we use "cookies" as part of our interaction with your browser. A "cookie" is a small text file placed on your hard drive by our web page server. We do not use cookies to get data from your hard drive or to get your email address or personal identifying information.
Cookies are commonly used on web sites and do not harm your system. By configuring your preferences or options in your browser, you determine if and how a cookie will be accepted. We use cookies to determine if you have previously visited our web site and for a number of administrative purpose.

How We Handle E-Mail
When you send us an e-mail to comment on something or to ask a question, we will use your e-mail address to reply to you and for a limited time we will store your e-mail address, your message and our response for quality assurance. We may also do this to meet legal and regulatory requirements. If we collect your e-mail address in this manner, we won't use it to let you know about our products and services unless you have given us permission.
This information is not given or sold to any other organization.

E-Mail Security
Regular non-encrypted Internet e-mail is not secure. In the instances where our Internet e-mail addresses are provided, these are provided for information inquiries of a non-sensitive and non-confidential nature. E-mail you send us may not be secure unless we advise you that it is secure prior to transmitting your message. Therefore, we recommend that you not send us confidential information such as social security or account numbers via unsecured email. You may also contact us by phone, U.S. mail or by visiting your nearest banking center.

On-Line Banking Security
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, supported by the outside companies we work with, to make online banking secure and to protect your personal information. We also require an I.D. and password or PIN to access your accounts. If you do not provide this information, we cannot establish an online banking service for you.

You can also help safeguard your personal information by taking a few simple precautions. Protect your account, PIN, and customer access numbers. Do not share your I.D. or password with anyone, change your password regularly, and remember to sign off. Never disclose confidential information to unknown callers. When banking on the Internet, be sure to use a secure browser and current virus detection software, and never open e-mail from unknown sources.

Protecting your privacy online
Whenever we ask for personal information on our web site, we use Secure Socket Layer (SSL technology) for transferring data. This technology encrypts - or scrambles - your account information so it's virtually impossible to read by anyone other than employees at our Bank.

Secure Socket Layer (SSL) technology secretly encodes information that is being sent over the Internet between your computer and our Bank, helping to ensure that the information remains confidential.
The use of SSL requires that you have an SSL compatible browser. While older browser versions may support SSL sessions, we strongly recommends the following browsers.
• Windows and Unix operating systems: Netscape Navigator 4.08 of later, Netscape Communicator 4.7 or later and Microsoft Internet Explorer 4.01 or later.
• Macintosh: Netscape Navigator 4.08 or later, Netscape Communicator 4.7 or later and Microsoft Internet Explorer 4.5 or later.
You can download the latest version from either of the links below.

http://www.microsoft.com/ie/download/
http://home.netscape.com/download/index.html

Protecting Your Children
Our website is not targeted or marketed to children under the age of thirteen. We respect the privacy of your children, and we comply with the practices established under the Children's Online Privacy Protection Act. We do not knowingly collect or retain personally identifiable information from consumers under the age of thirteen.