Privacy Policy

The Commonwealth National Bank
Privacy Pledge to You

Confidence is knowing that you have a financial partner that respects and protects the privacy of your personal financial information. At Commonwealth National Bank, we are committed to keeping your trust and confidence, therefore we set a high standard on quality service, and we deliver on this standard each and every day - because it's the right thing to do. The Commonwealth National Bank Privacy Pledge is our way of communicating the kind of information we collect, how we use it, and the standards and procedures in place to safeguard your personal financial information.

The Commonwealth National Bank family of companies is committed to helping you realize your dreams by anticipating, understanding and meeting your financial needs. As we work together to provide the broad array of financial products and services you want and need, we pledge to protect the personal information you have entrusted to us. You can be confident that Commonwealth National Bank will not sell or share customer information or customer lists to outside marketers or with any non-affiliated person, company, or organization except in legally permitted circumstances.

INFORMATION WE COLLECT

The information we collect is limited to what we believe is necessary or useful to conduct our business; to administer your records, accounts and funds; to comply with laws and regulations; to help us design or improve products and services; and to understand your financial needs so that we can provide you with quality products and superior service.

We collect this information from the following sources:

Information we receive from you on applications or other forms, such as your assets, income and other debt. Information about your transactions and experiences with us, our affiliates or others, such as your account balance, payment history, parties to transactions and credit card usage. Information we receive from a consumer report, such as information regarding your creditworthiness or credit history. Information we receive through our online services, such as information relating to Web site navigation, customer contact and optional surveys. Information we receive from public records and market research, such as demographic information. Information we obtain from outside sources relating to their employment, credit or other relationships with you, such as a verification of employment history, loan or credit card balance or insurance coverage. Information we have obtained at your request, such as aggregated information from multiple financial service providers.

INFORMATION WE SHARE

We do not share information about our customers or former customers, except as described in the Commonwealth National Bank Privacy Pledge.

Sharing Among Our Affiliated Companies In the course of our business, we may share some or all of the information described above among our affiliates. We may share information with affiliates providing financial and related services, such as our securities broker-dealers, our insurance companies and agencies, our banks and our mortgage companies. We may also share with our affiliates providing non-financial services, such as our operations and servicing companies. This gives us a more complete knowledge of your total relationship with us and helps us meet your financial needs. The law allows us to share identifying information and information about our transactions and experiences with you, such as your account balances and payment history. You may direct us not to share other information that is assembled or used to determine your eligibility for a product or service, such as that shown on consumer credit reports and asset and income information from applications.

If you prefer that we not share this other information among our affiliates, you may choose to opt out (or ask us not to share within the Commonwealth National Bank family of companies). To opt out, simply notify us by calling 1-800-240-2948. Commonwealth National Bank customers can also opt out by writing to us at: Commonwealth National Bank Bank, Privacy Officer, P. O. Box 2326, Mobile, AL 36652-2326. Your opt-out request will become effective as soon as reasonably practicable after we receive it.

We will mail the Commonwealth National Bank Privacy Pledge annually to the address to which we send your product or account information. If there are multiple owners of a product or account, we will treat an opt-out request by one of the owners as applying to that owner only, unless that person requests on behalf of other owners that their information not be disclosed.

You only need to notify us once if you choose to limit the information shared among our affiliates. If you have notified us in the past, there is no need to do so again. We will continue to honor your request, subject to modifications by you and other exceptions described in the Commonwealth National Bank Privacy Pledge.

We do not share medical or health information among our family of companies except to process transactions or to provide services you have requested or initiated.

Sharing With Companies That Work With Us In order to conduct company business, and to offer products or services that may complement your relationship with us, we may share some or all of the information we collect, as described above, with the following companies (including our affiliates):

Companies that perform services for us or on our behalf, such as vendors we hire to prepare account statements or to provide support for one or more of our products and services. Companies that perform marketing services on our behalf or other financial institutions with which we have joint marketing agreements, such as insurance companies and credit card issuers. These companies act on our behalf, and are contractually obligated to keep the information we provide them confidential and to use the information only for the purposes authorized.

Sharing In Other Situations We may share some or all of the information we collect, as described above, as otherwise authorized or required under applicable law. This includes, for example, disclosures to credit reporting agencies; disclosures to process and service your requested or authorized transactions; disclosures in connection with recording deeds of trust, mortgages and other security instruments in public records; disclosures in connection with subpoenas or other legal processes; disclosures as part of fraud investigations; disclosures in connection with audits and examinations; disclosures in connection with the sale of accounts to another financial institution; and disclosures pursuant to your authorization or consent.

PROTECTING INFORMATION ABOUT YOU

We restrict access to information about you to those employees who need to know that information as part of their job responsibilities. We also educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our Code of Conduct. We take appropriate disciplinary measures to enforce employee privacy responsibilities.

Commonwealth National Bank also maintains strict information security procedures, including physical, electronic and procedural safeguards, to protect the confidentiality of your information. We will continue to test and update our technology to improve the protection of your information.

We understand your concerns about recent occurrences such as identity theft, and we employ standard identification procedures designed to deter these situations. To protect yourself from fraud and identity theft, the first step is monitoring your credit and checking for accuracy. The law entitles you to receive one free credit file disclosure every 12 months from each of the national consumer credit reporting companies.

Monitoring your credit for accuracy is an important step to take in protecting yourself from fraud and identity theft.

Commonwealth National Bank does not contact customers via e-mail to verify or request security information. If you receive such a fraudulent e-mail, please do not respond; instead forward it to phishing@ecommonwealthbank.com . If you believe your account information may have been compromised, please contact us immediately at 1-800-Commonwealth National Bank (1-800-734-4667). For more information about guarding your account and personal information, please visit our Web site at www.eCommonwealthBank.com.

PROTECTING INFORMATION ABOUT FORMER CUSTOMERS

The Commonwealth National Bank Privacy Pledge regarding the collection, use and disclosure of information about former customers is the same as our pledge to current customers.

OTHER HELPFUL PRIVACY INFORMATION

We Want To Maintain Accurate Customer Information We have established procedures to keep your information current and complete. These procedures include responding to requests to correct inaccurate information in a timely manner. If you believe our customer records contain incorrect information about you, call or write to us at the telephone number or address listed on your account statement, bank records or other documentation, or visit our Web site at www.eCommonwealthBank.com to send us a secure e-mail. We Protect Online Information To learn more about online security, visit our Web site at www.eCommonwealthBank.com and refer to our Online Privacy Guidelines.

You Can Limit Pre-Approved Credit Solicitations To request that your name be removed from pre-approved credit solicitations developed through credit reporting agencies, you can call 1-888-567-8688 or write to the agencies listed below. Include your name, address and Social Security number.

Experian
Consumer Opt-Out
901 West Bond
Lincoln, NE 68521
Equifax, Inc.
Options
P.O. Box 740123
Atlanta, GA 30374-0123

TransUnion LLC
Name Removal Option
P.O. Box 97328
Jackson, MS 39288-7328

QUESTIONS ABOUT THE Commonwealth National Bank PRIVACY PLEDGE

If you have questions about the Commonwealth National Bank Privacy Pledge or about the privacy of your information, please call us at 1-800-394-0543 between 7 a.m. and 7 p.m. CT, Monday through Friday and from 7 a.m. to 2 p.m. CT on Saturday, or visit our Web site at www.eCommonwealthBank.com to send us a secure e-mail.

KEEPING UP TO DATE WITH THE Commonwealth National Bank PRIVACY PLEDGE

The Commonwealth National Bank Privacy Pledge is subject to change. You can always review the current Commonwealth National Bank Privacy Pledge on our Web site at www.eCommonwealthBank.com , or visit any of our offices to obtain a copy. We will notify you annually about the Commonwealth National Bank Privacy Pledge as long as you maintain an ongoing relationship with us.

MISCELLANEOUS INFORMATION

The Commonwealth National Bank Privacy Pledge applies to individuals who obtain or have obtained from us a financial product or service that is used primarily for personal, family or household purposes. The laws of some states may impose separate or additional requirements before particular types of information about customers in those states can be disclosed. This Commonwealth National Bank Privacy Pledge is provided in compliance with applicable law and replaces all prior notices, statements or agreements with respect to the same subject matter.

SPECIAL PRIVACY NOTICE FOR CALIFORNIA AND VERMONT RESIDENTS

California and Vermont law place additional limits on disclosing information about California and Vermont residents so long as they remain residents of those states.

In accordance with California law, we will not disclose information we collect about California residents to unaffiliated companies, except as permitted by law, which includes disclosures with the consent of the California resident and disclosures to service the resident's accounts with us, as well as other lawful disclosures.

In accordance with Vermont law, we will not disclose information we collect about Vermont residents to unaffiliated companies and will not disclose application and third party credit-related information about Vermont residents to our affiliated companies except as follows: as permitted by law; to companies that perform marketing or other services on our behalf; name, contact and transaction and experience information to other financial institutions with which we have joint marketing agreements; or with the authorization or consent of the Vermont resident.

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