Professional Business Bank / Spectrum Bank
Notice of Your Financial Privacy Rights

This is our Privacy Disclosure Policy. When we use the words “you” and “your” we mean the following types of customers:

• Our consumer customers who have continuing relationships by purchasing or holding financial products or services such as:
  • Deposit account
  • Loan account
  • Credit card
  • Retail Installment contract we hold and service

We will tell you the sources of the information we collect about you. We will tell you what measures we take to secure that information.

We first define some terms:

WE, OUR, and US, when used in this Policy, means Professional Business Bank.

NONPUBLIC PERSONAL INFORMATION means information about you that we collect in connection with providing a financial product or service to you. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records.

An AFFILIATE is a company we own or control, a company that owns or controls us, and a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control.

A NONAFFILIATED THIRD PARTY is a person we do not employ or a company that is not an affiliate of ours. This is also known as nonaffiliated third party, or an “other party”.



THE INFORMATION WE COLLECT
We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms.
• Information about your transactions with us, our affiliates, or others; and
• Information we receive from a consumer reporting agency.

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as authorized by law.



THE CONFIDENTIALITY, SECURITY AND INTEGRITY OF YOUR NONPUBLIC PERSONAL INFORMATION
We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect this information.

YOUR NONPUBLIC PERSONAL INFORMATION AND NON-AFFILIATED THIRD PARTIES
We will not disclose information about you to anyone except as disclosed in this policy or as permitted by law.



DISCLOSURE OF NONPUBLIC INFORMATION IN OTHER CIRCUMSTANCES

• Sharing with companies under contract to perform services for us or on our behalf such as data processing, statement preparation and mailing.
• Check printers.
• When you authorize us to release information.
• When it is necessary or helpful in completing a transaction you have requested.
• To verify the existence and condition of your account for a third party, such as a merchant, other financial institution or a credit reporting agency.
• To an account verification service, in addition to a credit reporting agency, if we close your account due to unsatisfactory handling, fraud, attempted fraud or criminal activity.
• To comply with a law, regulation, legal process or court order which applies to us or to an affiliate and agents such as independent auditors, consultants or attorneys.
• In response to an inquiry about sufficient funds to cover a check you have written.
• To local, state or federal authorities, if we believe a crime may have been committed.
• To paying agencies after the death or incapacity of a recipient or beneficiary of recurring direct deposit payments.

INFORMATION ABOUT FORMER CUSTOMERS
We do not disclose nonpublic personal information about former customers, except as permitted by law, or if requested by you.

Rev. 7/03