At Commercial Bank, the basis of each customer relationship, many of which span generations, is trust. You have chosen to do business with Commercial Bank, and we are obligated to honor that relationship with great care, beginning with the information you have chosen to share with us. We believe that your privacy should not be compromised. At the same time, we want to offer you the array of financial products and services you need to accomplish your financial goals. We believe we can do both through the privacy policy outlined below.

Respect of Right of Privacy
At Commercial Bank, we believe the confidentiality and protection of customer information is one of our fundamental responsibilities. And while information is critical to providing quality service, we recognize that one of our most important assets is our customer's trust. Thus, the safekeeping of customer information is a priority for Commercial Bank.

Collection and Use of Personal Information
We collect, retain, and use information about you only where we reasonably believe that it will help administer our business or provide products, services, and other opportunities to you. We collect and retain information about you only for specific business purposes, and we will tell you why we are collecting and retaining it upon your request. We use information to protect and administer your records, accounts, and funds; to comply with certain laws and regulations; to help us design or improve our products and services, and to understand your financial needs so that we can provide you with quality products and superior service.

Maintenance of Accurate Information
Commercial Bank has established procedures to ensure that your financial information is accurate, current and complete, in keeping with reasonable commercial standards. We also pledge to respond to requests to correct inaccurate information in a timely manner.

Limitations on Employee Access to Information
At Commercial Bank, employee access to personally identifiable customer information is limited to those with a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of customer information and on these Privacy Principles. Because of the importance of these issues, all Commercial Bank employees are responsible for maintaining the confidentiality of customer information and employees who violate these Privacy Principles will be subject to disciplinary measures.

Protection of Information via Established Security Procedures
Commercial Bank is 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 third parties. We maintain and grant access to customer information only in accordance with our internal security standards.

Restrictions on the Disclosure of Account Information
We do not reveal specific information about your accounts or other personally identifiable data to parties outside our bank for their independent use unless:

1. you request or authorize it
2. the information is provided to help complete a transaction initiated by you
3. the information is provided to a reputable credit bureau or similar information reporting agency, or
4. the disclosure otherwise is lawfully permitted or required.