ELECTRONIC PRIVACY POLICY

It is the policy of GulfSouth Private Bank to recognize and respect the privacy of all our customers and make available the privacy guidelines to all customers.

With the rapid growth in electronic commerce conducted over the Internet, GulfSouth Private Bank deploys on-line systems to facilitate the convenient delivery of services and it is the policy of GulfSouth Private Bank to safeguard our customer’s sensitive information. GulfSouth Private Bank considers the privacy of our consumers’ personal information an important element of their trust and confidence in the Bank.

It is the policy of GulfSouth Private Bank to collect, retain, and use the information about customers only where such information is believed to be useful and allowed by law to administer the business of GulfSouth Private Bank to provide products, services, and other financial opportunities to its customers.

GulfSouth Private Bank has established procedures to ensure the accuracy of customers’ financial information and that it is current and complete in accordance with reasonable commercial standards. It is the policy of GulfSouth Private Bank to address any requests to correct any inaccurate information in a timely manner.

It is the policy of GulfSouth Private Bank to limit employee access to personally-identifiable information to those with a business reason for knowing such information. GulfSouth Private Bank has in place a training program to educate the employees so that they will understand the importance of confidentiality and customer privacy.

GulfSouth Private Bank maintains appropriate security standards and procedures regarding unauthorized access to customer information. It is the policy of GulfSouth Private Bank to take disciplinary measures to enforce employee privacy responsibilities.

It is the policy of GulfSouth Private Bank not to reveal specific information about customer accounts or other personally-identifiable data to unaffiliated third parties for their independent use, except for the exchange of information with reputable information reporting agencies, to maximize the accuracy and security of such information, or in the performance of bona fide corporate due diligence, unless 1) the information is provided to help complete a customer-initiated transaction; 2) the customer requests it; 3) the disclosure is required by/or allowed by law (e.g., subpoena, investigation of fraudulent activity, etc.); 4) the customer has been informed about the possibility of such disclosure for marketing or similar purposes through a prior communication and is given the opportunity to decline (i.e., “opt out”). If a third party attempts by artifice or fraud to obtain confidential customer information from GulfSouth Private Bank, the Bank shall file an appropriate Suspicious Activity Report.

If personally-identifiable customer information is provided to a third party, it is the policy of GulfSouth Private Bank to insist that the third party adhere to similar privacy principles that provide for keeping such information confidential.

GulfSouth Private Bank makes available this policy, and its management and employees stand ready to assist customers with concerns regarding financial privacy expectations.