OLD HARBOR BANK
PRIVACY POLICY

Overview
Old Harbor Bank recognizes that you expect the highest level of security and confidentiality for your personal information. We believe that your privacy should not be compromised. Therefore, we make protecting your privacy and safeguarding your personal and account information a priority.

Old Harbor Bank does not provide customer information to any unaffiliated organization for the purpose of independent telemarketing or direct mail marketing of any non-Old Harbor Bank products or services.

We continually strive to maintain complete and accurate information about you and your accounts. Should you ever believe that our records contain inaccurate or incomplete information about you, please notify us. We will investigate your concerns and correct any inaccuracies in a timely manner.

Our Privacy Policy outlines when and how we share nonpublic personal information about consumers with nonaffiliated third parties.

Types of Information We Collect
Old Harbor Bank collects various types of information on you. We collect the following types of loan and deposit information:

1)	Information we receive from you on applications or other forms, such as your address, social security number, income, financial status and employment information,
2)	Information we receive from third parties, such as a consumer reporting agency, and
3)	Account balances and transactional information, including your credit and/or deposit account histories.

Types of Information We Disclose
Old Harbor Bank may disclose all nonpublic personal information it collects as permitted or required by law. For example:

1)	In the normal course of business, for example, we may share payment histories with consumer reporting agencies and government agencies. We may also disclose loan and/or deposit account information with our internal and external auditors, both of which are nonaffiliated third parties, during the course of an audit of our books, records, policies and procedures;
2)	To third parties, when they are hired to help us provide a product or service that may benefit our customers. However, whenever we do share information, we insist that they adhere to similar privacy principles to protect our customers’ privacy. To further protect you, we share only the minimum amount of information necessary for the third party to assist us in offering our products or services;
3)	To comply with Federal, State, or local laws, rules and other applicable legal and regulatory requirements;
4)	In connection with a proposed or actual sale, merger, transfer or exchange of all or a portion of the Bank’s assets in which the acquiring/merging party would agree, in writing, to maintain the confidentiality of such information; and
5)	In order to service or process a product or service you request, or with your permission. For example, when you enroll in the Bank’s Online Banking services, your enrollment application is sent to the nonaffiliated third party we contracted with to service these products.

Who Receives this Information:
We may provide the following parties with our customers’ nonpublic personal information:

1)	Financial Service Providers – Examples of financial service providers are the Bank’s software vendors, and Online Banking service providers.
2)	Non-financial Companies – Examples of non-financial companies are credit bureaus, title companies, and insurance companies. The Bank may also disclose nonpublic personal information to its legal counsel, as well as its internal and external auditors.
3)	Law enforcement and government agencies - As allowable, and in some cases, as required by law, our customers’ nonpublic personal information may be provided to our law enforcement and government agencies (e.g., the Federal Deposit Insurance Corporation and Internal Revenue Service).

Sharing Information on Former Customers
Old Harbor Bank does not disclose nonpublic personal information on former customers to affiliated or nonaffiliated third parties, other than to comply with applicable laws, rules and other legal and regulatory requirements, or at the request/with the permission of the former customer, or as otherwise required or permitted by law.

Limitations on Employee Access to Information
Old Harbor Bank management ensures that our employees understand and uphold customer confidentiality and privacy. This is accomplished by adhering to the Bank’s Code of Professional Ethics, as well as maintaining experienced supervisory management. Access to account information is permitted only to employees who have a need to know that information in order to provide products or services to you..

Protecting your Information
We are committed to the security of your financial and personal information. All of our operational and data processing systems are in a secure environment that protects your account information from being accessed by unauthorized third parties. We maintain and grant access to customer information only in accordance with our internal security standards.

The personal information you may access or provide to us over the Internet has military grade data encryption, firewalls, and server authentication in order to protect your private data from being intercepted. Internet Banking Personal Identification Numbers (PINs) are established by you.

While the Bank uses state of the art technologies to protect your information, we cannot provide a guarantee that our systems will never be compromised.

Receiving and Responding to your Inquiries
At Old Harbor Bank, we value our customer relationships. We want you to understand how we use the information you provide and our commitment to ensuring your personal privacy. If you have any questions about how we protect your confidential information, please call your local branch, contact us through our website at www.oldharborbank.com or write to us at P. O. Box 14259, Clearwater, FL 33766-4259