Fidelis values your trust and respects your expectation of privacy. As such, we are committed to maintaining the confidentiality of your personal financial information. This document outlines our privacy policy for visitors to our web site, as well as for consumers who have a continuing relationship with us, such as a client account, facilitation of loans, or safe deposit box.

Visitors to Our Web Site. Visitors to our web site remain anonymous, unless they register for a service or otherwise elect to disclose their identity to us. Although we do not collect personally identifying information about persons who simply visit our site, we do collect certain limited information about visitors, such as their IP address (a numeric address assigned automatically to computers when they access the Internet). We also may place "cookies" on a computer to track a visitor's use of our web site. A cookie is a piece of data that is stored on your hard drive. It takes up very little room on your system and helps us to customize our site and make its navigation easier for you. We sometimes use cookies to help estimate the number of visitors to our site and to determine which areas are the most popular. Unless you register with us for a service (such as our online banking service), the cookie does not provide us with any personally identifying information about you, such as your name or address.

Our Collection and Use of Information About You. We may collect nonpublic personal information about you in order to understand your needs, administer our business, process transactions, and provide you with products and services. We obtain nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms (such as your name, address, social security number, assets and income);
• Information about your transactions with us, our affiliates, or others (such as your account balance, payment history, parties to transactions, and credit usage); and
• Information we receive from a consumer reporting agency (such as your creditworthiness and credit history).

Our Disclosure of Information. We may disclose all of the information we collect, as described above, to other financial institutions with whom we have joint marketing agreements, such as insurance agents and card issuers, so that they can market goods and services to you. We also may disclose:

• Some of this information, such as your name and address, to companies that perform marketing and other services on our behalf (e.g., to companies that assist us with mailings).
• Information regarding our experience and transactions with you with financial service providers, such as financial institutions, securities broker-dealers, and insurance agents, with which we are related by common ownership or affiliated by corporate control, so that they may offer or provide additional services to you. We also may share other information we obtain about you with those companies (e.g., information from applications and credit reports), unless you notify us before the information is initially communicated that you do not want us to share that information. You can tell us not to share such information by calling us at #######
• Information about your accounts and transactions: (a) where it is necessary or helpful to effect, process or confirm your transactions; (b) to verify the existence, history and condition of your account for credit reporting agencies; (c) to comply with legal process, such as subpoenas and court orders; (d) to law enforcement authorities if we believe a crime has been committed; (e) if you give us your consent; and f) as otherwise permitted by law. We do not disclose nonpublic personal information about our current or former customers to unaffiliated third parties except as set forth in this policy.

State Rights. Depending on where you live, you may have additional privacy protections under some state laws. For example, certain state laws may restrict the types of information we may disclose about you, limit the parties with whom we may share such information, or require us to provide you with additional notices or opt-out rights. We will comply with applicable state laws before sharing nonpublic personal information about you. We may do this by sending a separate notice of those rights to you.

Maintaining Accurate Information. We have procedures in place that help us to maintain the accuracy of the personally identifiable information that we collect. Please contact your branch of account or call our customer service center at ###### , if you believe that our information about you is incomplete, out-of-date, or incorrect.

Information Security. We restrict access to nonpublic personal information about you to those employees who have a need to know such information (e.g., to process your transactions or provide services to you). We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Links to Other Web Sites. Our web site may feature links to third party web sites that offer goods, services or information. Some of these sites may appear as windows-within-windows at this site. When you click on one of these links, you will be leaving our site and will no longer be subject to this policy. We are not responsible for the information collection practices of the other web sites that you visit and urge you to review their privacy policies before you provide them with any personally identifiable information. Third party sites may collect and use information about you in a way that is different from this policy.

Services and Advertisements by Third Parties. Third parties may offer services from time to time at our web site. If you provide them with information, their use of that information will be subject to their privacy policy, if any, and will not be subject to this policy. If you accept third party goods or services advertised at our web site, the third party may be able to identify that you have a relationship with us (e.g., if the offer was only made through our site).

Minors. We feel strongly about protecting the privacy of children and teenagers. As such, we do not knowingly collect personally identifiable information from minors through our web site.

Changes to this Policy. We may amend (add to, delete, or change) the terms of this Privacy Policy from time to time by posting a notice of the change (or an amended Privacy Policy) at this web site. If required by law, we will send you a notice of the change. Your continued use of our web site or any on-line service following notification will constitute your agreement to the revised Policy.