INTRODUCTION

You provide important information about yourself when you do business with Commerce National Bank & Trust. This information is important because it helps us get a better picture of your needs, provide better service, and complete your transactions more effectively. Federal regulations require us to inform you of the types of information we collect, as well as how and with whom we share the information. Below is an outline of our information sharing policy.

CATEGORIES OF INFORMATION WE COLLECT

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other informational forms;
• Information about your transactions with us, such as payment history and account balances;
• Information we receive from consumer-reporting agencies.

INFORMATION SHARING WITH NON-AFFILIATED THIRD PARTIES

We do not disclose any nonpublic personal information about our customers or former customers to non-affiliated third parties unless:

• you have authorized us to do so;
• the information is required for us to complete a transaction you have requested;
• the information is provided to a consumer reporting agency in accordance with the Fair Credit Reporting Act;
• disclosure is required in order to comply with federal, state, or local laws or other applicable legal requirements.

SERVICE PROVIDER/JOINT MARKETING EXCEPTION

We choose carefully the companies that provide services for us (such as service and processing providers, check printers, or marketing services). These companies are contractually required to adhere to our strict standards of information security and confidentiality. They are not allowed to use our customer information for any purpose other than the intended service.

We may disclose the information we collect, as described above, to companies that provide service and processing, perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements, as permitted by law.

INFORMATION SHARING WITH AFFILIATES

Commerce National Bank & Trust provides information about its customers to third parties that are affiliates of Commerce National Bank & Trust. For example we share information with our insurance affiliate, CNB&T Insurance Services, LLC.

CONSUMER'S RIGHT TO OPT-OUT

As a consumer, you have the right to direct Commerce National Bank & Trust not to share nonpublic personal information about you with its affiliates.

To exercise your opt-out privilege:

• Mail or fax us your opt-out request, or
• Call us at (407)622-8181, or
• Email us at CustomerService@CNBT-FL.com

CONFIDENTIALITY, SECURITY AND ACCURACY

Our employees are governed by a code of conduct that includes the responsibility to protect the confidentiality of customers' financial and other personal information. Employees are bound by the Privacy Policy and are educated on implementing our security principles and practices. Only employees actively engaged in their assigned duties are authorized to access or use customer information. We maintain physical, electronic and procedural safeguards that comply with federal regulation to guard your nonpublic personal information.

We do not disclose information about our customers or former customers to anyone, except as outlined in this policy or as permitted or required by law, unless the customer expressly authorizes or requests it. Our strict policies for protecting customer information apply equally to active and inactive customers. In accordance with standard banking industry practice and the Fair Credit Reporting Act, we share customer information with reputable information reporting agencies.

We work to ensure that the information concerning you is accurate in all aspects. If we become aware of inaccuracies in our records, we will take prompt steps to make appropriate corrections. Please call (407)622-8181 if you have any questions.

HOW YOU CAN HELP PROTECT YOUR PRIVACY

Identity theft and fraud are on the rise. Help protect your privacy by following these simple steps:

• Do not share your account information, passwords or personal identification numbers with others.
• Do not provide confidential information by telephone to unknown callers.
• Do not provide confidential information online unless you initiated the contact, know the party with whom you are dealing and provide the information through a secure channel.
• When conducting business over the Internet, always use a secure browser and exit online applications as soon as you finish using them.
• Protect your account records; shred documents that contain confidential information.
• If you believe you are a victim of fraud or identity theft, please contact us immediately for assistance.

Commerce National Bank & Trust
1201 South Orlando Avenue
Winter Park, Florida 32789
(407)622-8181
(407)622-8191 fax
www.CNBT-FL.com