Borel Private Bank & Trust Company

Your Privacy Is Important to Us

Our customers and other individuals visiting our Bank and our web site are important to Borel Private Bank & Trust Company. We understand that your privacy is important to you. At Borel Private Bank & Trust Company, we believe the confidentiality and protection of your information is one of our fundamental responsibilities. While it is necessary for us to obtain information about you in order to provide quality service and products to serve your financial needs, we know that one of our most important assets is our customer's trust. Therefore, Borel Private Bank & Trust Company has established a comprehensive policy of protecting confidential information about you and your transactions. Described below are the circumstances under which we may receive and obtain non-public personal information about you and our policies to protect your privacy. If you have any questions about your privacy, information you are providing the Bank, information the Bank may obtain about you, how we use information provided to us, or any of our policies or products, please send us an e-mail at info@borel.com or write to us at Borel Private Bank & Trust Company, 160 Bovet Road, San Mateo, CA 94402 at 650-378-3700.

Use Of Terms And Definitions

In this Privacy Policy and Disclosure Statement, the terms "we", "our", "us" refer to Borel Private Bank & Trust Company. The terms "you" or "yours" refer to you, our customer. The words and phrase "non-public personal information" means personal information about you which is not available to the general public such as your: driver's license number, social security number, income, age, marital status, assets and debts, and in some instances your address and telephone number, e-mail address, internet service provider, or web browser.

Availability and Changes To Our Privacy Policy

This Privacy Policy and Disclosure Statement is available upon request at any of our Banking offices or through our web site. In addition, you will receive a copy of our Privacy Policy and Disclosure Statement whenever you open a deposit or loan account with us or obtain a banking service as a customer. You will also receive a copy of our Privacy Policy and Disclosure Statement at least annually if you have any open accounts with us.

From time to time we may make changes to this policy. Please ask one of customer service representatives if you wish to verify that you have obtained the most current edition of our Privacy Policy and Disclosure Statement.

A. Categories Of Information Which We Collect

In order to provide you with a product or service you have requested, we may collect the following types of 'non-public personal information' about you. The information we collect, may also be collected by other financial institutions when you obtain a product or service from them:

B. Categories Of Information Which We Disclose and When It Is Disclosed

Borel Private Bank & Trust Company may share your non-public personal information under the following circumstances:

Electronic Banking Information: We do not share this information with any other non-affiliated party or affiliate of the Bank unless required to do so by law or regulation. However, our web-site may contain links to other entities which will gather information about you if you visit that site. (See Section C.)

Borel Private Bank & Trust Company does not disclose or share account numbers or access codes with nonaffiliated third parties for the purpose of direct marketing or telemarketing the nonaffiliated third party's non-financial services or products (e.g. selling name and address lists).

C. Nonaffiliated Parties To Whom We Disclose Information For Routine Business Purposes

The following are the categories of Nonaffiliated Third Parties to whom we disclose information. Disclosure of information to each of these parties in these categories is permitted under the privacy laws and regulations. Each financial institution will share your non-public personal information under similar circumstances. Should you not wish to have your non-public personal information as described in this Policy and Disclosure Statement shared under the following circumstances you may wish to inquire as to what information will be shared before you request the service or product.

To financial service providers, such as a real estate brokers or appraisers; governmental loan guarantee agencies; secondary market mortgage agencies; title companies; real estate tax service providers; construction loan inspectors, etc.
When it is necessary for completing transactions and transfers, such as information which we must provide to our data processing vendors and automated teller machine (ATM) vendors.
To verify the existence and condition of your account for a third party, such as a credit bureau, merchant or other financial institution.
To comply with a regulatory, government agency, court order, law or regulation under which the information is requested.
To an account verification service, credit bureau or a local, state and federal law enforcement agency if we close your account due to unsatisfactory handling or if we believe fraud or a crime may have bee n committed involving your account.
To any direct deposit originators, governmental agencies or other service providers in the event of your death.
To other companies, vendors, consultants, financial institutions or networks which may be involved in processing, monitoring or reviewing your transactions.
When you have authorized us to provide the information to another party.
Upon your request, or to complete transactions, including sharing with third parties we engage to help deliver our services to you.
To verify individual's identities in order to reduce identity theft or fraud.
To a merchant who may request that we verify a check, draft or other item you have presented to them.

In some instances when we have entered into a joint marketing arrangement with either an affiliated or a non-affiliated financial institution or service provider, we do not provide your non-public personal information directly to the joint marketing company. Rather we only provide the means whereby you may contact that company either by completing an application form or a request for more information, such as request financial investment information. Some of these companies may include an offer for certain non-financial products (such as airline miles, buyer protection insurance, etc.) with the application form or other product request documents. If you decide to select that product or service you will be providing non-public personal information directly to those companies. If you have any questions regarding a product or service, please speak with us before completing any application or other form.

D. Sharing of Information With Affiliates

Under federal law, banks or financial service providers are permitted to share information about their experiences or transactions, such as account balance and payment history, with their "affiliates" (companies related by common control or ownership). At Borel Private Bank & Trust Company we do not share your personal nonpublic information with our affiliates. If we decide to change this policy, we will inform you of the change and give you an opportunity to prevent the sharing by "opting out."

Accuracy of Information

Borel Private Bank & Trust Company maintains procedures to insure that not only is the personal information you submit is accurately recorded and maintained, but that any inaccurate or incomplete information is corrected in a timely manner. If you have any reason to believe that your Personal Information is incorrect, please call us at 650-378-3700. We will investigate the problem and, if appropriate, update the Bank's records. You may also contact us by e-mail at comments@borel.com or write us at 160 Bovet Road , San Mateo , CA 94402 .

Privacy As A Former Customer

If you decide to close any of your deposit accounts with the Bank, you pay your loan in full, or any of your accounts become inactive or are closed for some other reason, we will continue to treat and safeguard your non-public personal information as described in this Disclosure. Our policies and procedures regarding your personal information associated with a closed account is the same as that of any open account you may have. Closed account information is retained for the period required by law or regulation and then removed from the Bank's records.

Employee Access To Customer Information

Our customers and other individuals visiting our web site are important to Borel Private Bank & Trust Company. We understand that your privacy is important to you. Therefore, Borel Private Bank & Trust Company has an established policy of protecting confidential information about you and your transactions. If you have any questions about your privacy information you are providing the Bank, or any of our policies or products, please send us an e-mail or write or telephone us.

Each Borel Private Bank & Trust Company employee is personally responsible for maintaining the confidentiality of customer data. The Bank requires all of its employees to agree in writing to protect the confidentiality of client information and to use it only for the Bank's purposes. Internal access occurs only to the extent appropriate to evaluate, structure and facilitate the services you have requested or to inform you of services or products you have requested or inquired about. Sharing of information about you is limited to other departments within the Bank and is used only for the purposes stated. Any employee who violates Borel Private Bank & Trust Company Privacy Policy will be subject to disciplinary action.

Information Security and Integrity

Borel Private Bank & Trust Company is committed to preventing others from unauthorized access to your personal information, and we maintain procedures and technology designed for this purpose. These include updating and testing our technology on a regular basis in order to improve the protection of your information; and, in addition to the safeguards noted above, we maintain policies and procedures about the appropriate physical security of workstations and records. Our physical, electronic and procedural safeguards comply with federal regulations regarding the protection of customer information. We also protect your information by maintaining backup copies of your account data, using computer virus detection and eradication software, using firewalls and other safeguards to protect against unauthorized access to our computer systems.

Website Monitoring

Like most websites, the Sites use "cookies" to allow you to move more quickly through the Sites. Cookies are small text files a websites can use to recognize repeat users and facilitate their ongoing access to and use of the Sites. We will not use cookies to collect personally identifying information, but only to collect information related to the characteristics of your computer, or when and how you reached the Sites. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning Sites. They do not pose a threat to a user's system or files. We use this information only for purposes of planning and tracking, as well as assessing the technical function of the Sites. By understanding how the Sites are accessed, we can continually improve it to respond to user's interests. However, Borel Private Bank & Trust Company cannot control the use of cookies by advertisers or third parties hosting data for Borel Private Bank & Trust Company. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. Please note that cookies may be necessary to enable you to use certain features on the Sites.

We reserve the right to perform statistical analyses and profiling of user behavior and characteristics in order to measure interest in and use of the various areas of the Sites and to inform third parties of such information. We will collect only aggregate data from these analyses to third parties; no personally identifiable information will be collected.

The Sites may provide you with links to the websites of third parties. In the event you choose to access such websites, we are not responsible for any actions or policies of such third parties. We recommend that you check the applicable privacy policy of such party before providing personally identifiable information to it, as its privacy policy may differ from ours.

Protecting and Restricting Use Of Your Personal Information

If you believe that someone has obtained unauthorized access either to your account with us or to non-public personal information about you, please notify a Bank customer service representative immediately. You should also report the crime to your local law enforcement agency. For information regarding identity theft and ways to protect your personal information you may contact the Federal Trade Commission ("FTC") web site at http://www.consumer.gov/idtheft .

You can have your name removed from some of the lists compiled by agencies or companies in the business of assembling and selling direct or telemarketing lists by sending a written request to the following organizations:

Mail Preference Service
c/o Direct Marketing Association
P. O. Box 282
Carmel, NY 10512
www.dmaconsumers.org/cgi/offmailinglist

National Do Not Call Registry
www.donotcall.gov/default.aspx
1-888-382-1222.

You must include your name, address and social security number. These organizations are responsible for notifying the agencies and companies that are in the business of compiling lists that you wish to have your name removed. You must send a separate written notice to each agency. This process may take up to three months before you see a reduction in advertisements and solicitations, but once enrolled, you will be on the list for five years.

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