Privacy Policy

FACTS

WHAT DOES COMMODORE BANK DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives

consumers the right to limit some but not all sharing. Federal law also requires us to tell you how

we collect, share, and protect your personal information. Please read this notice carefully to

understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security Number

• Account Balances

• Payment History

• Credit History

• Credit Scores

• Checking Account Information

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Commodore Bank chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Commodore Bank share?

Can you limit this sharing?

For our everyday business purposes—

such as to process your transactions, maintain

your account(s), respond to court orders and legal investigations, or report to credit bureaus.

Yes

No

For our marketing purposes— to offer our products and services to you.

No

We do not share

For joint marketing with other financial companies.

No

We do not share

For our affiliates’ everyday business purposes—

information about your transactions and experiences.

No

We do not share

For our affiliates’ everyday business purposes—

information about your creditworthiness.

No

We do not share

For our affiliates to market to you.

No

We do not share

For nonaffiliates to market to you.

No

We do not share

What we do.

How does Commodore Bank

protect my personal information?

To protect your personal information from unauthorized access and use, we use security

measures that comply with federal law. These measures include computer safeguards

and secured files and buildings. We also maintain other physical, electronic and procedural safeguards to protect this information and we limit access to information to those employees for whom access is appropriate.

How does Commodore Bank

collect my personal information?

We collect your personal information, for example, when you:

• Apply for a loan

• Apply to open an account

• Give us income information

• Provide employment information

• Give us your contact information

• Show your driver’s license

We also collect your personal information from others, such as credit bureaus,

affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

• sharing for affiliates’ everyday business purposes—information about your creditworthiness

• affiliates from using your information to market to you

• sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

See below for more on your rights under state law.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

■ Commodore Financial Network Inc. (Holding Company) is our one affiliate.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

■ Commodore Bank does not share with nonaffiliates so they can market to you.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

■ Commodore Bank doesn’t jointly market.

Other important information

For Alaska, Illinois, Maryland and North Dakota Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing – without your authorization.

For California Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing – without your authorization. We will also limit our sharing or personal information about you with our affiliates to comply with all California privacy laws that apply to us.

For Massachusetts, Mississippi and New Jersey Customers. We will not share personal information from deposit or share relationships with nonaffiliates either for them to market to you or for joint marketing – without your authorization.

For Vermont Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing – without your authorization, and we will not share personal information with affiliates about your creditworthiness without your authorization.