When you visit our website, we do not collect personal information about you, unless you do one of the following:

• Log into Online Banking, Business Cash Management Online Banking, or Bill Pay systems.
• Send us an inquiry or e-mail message.

We gather statistics and other information about the usage of our website, such as the number of times each Web page was loaded into visitors’ browsers and visitors’ domain IP addresses (identifying numbers assigned to servers or computers used to access the Internet), in order to review how our website is used and how it might be improved, and to ensure site security.

We do not knowingly gather or use information from children without their parents consent. We are not responsible for data collected by or privacy practices of non-affiliated parties to which our website may link. You can view more information about the Children’s Online Privacy Protection Act (COPPA) by visiting the Federal Trade Commission (FTC) website at: www.ftc.gov.

If you use Online Banking, Business Cash Management, or Bill Pay systems, you may send us various kinds of information, depending on the services you use: for example, you may send us log-in information (User ID and User Password), information about the content of reports and data you request, and information about your accounts and transactions you wish to perform, such as funds transfers, stop payments and check orders. We use the information you send us to respond to your requests, and we will maintain customary records of any resulting banking transactions. We may retain any messages or information you send us for reference in connection with current or future inquiries and transactions, for internal administrative purposes (including data backup) and, in some instances, to fulfill legal requirements.

We may place a temporary “cookie” (a small element of data) on your computer to help identify you and provide you with customized information when you use certain features of our Online Banking, Business Cash Management or Bill Pay systems. A cookie does not retrieve data from your computer or carry viruses. Cookies help us keep track of your preferences and recognize return visitors. You may reject cookies, however when you login to online banking you will be challenged to provide additional indentifying information.

CalPrivate Bank does not sell customer information gathered through our website to third parties for the purpose of marketing their products or services. However, we may contact you to inform you about services and products that we offer, and we may retain third parties to assist us in doing so. We have written policies that require Bank team members to keep customer information confidential and use it only for legitimate Bank purposes.

If you send us an e-mail message or an inquiry through our website, the information you send (including your e-mail address and other identifying information in the message header) will be forwarded to the appropriate employee within CalPrivate Bank for response. We use the information you send us to respond to your requests, and we will maintain customary records of any resulting banking transactions.

CalPrivate Bank does not make your e-mail address or any other information you furnish by e-mail or through our website (including information you furnish when you use Online Banking, Business Cash Management or Bill Pay systems) available without your consent to companies or persons not affiliated with the Bank, except as follows:

• We may provide information to third parties, such as funds transfer networks, in order to complete a banking transaction for you.
• We comply with court orders, subpoenas and other legal process we determine to be valid, and we may provide information as otherwise required or permitted by law, including to bank regulatory agencies.
• We may provide information to credit reporting agencies and similar services; to investigators or law enforcement authorities in connection with a fraud or similar investigation; and to potential purchasers in connection with the sale of accounts, loan assets or business lines.
• We may provide information to contractors and agents who perform services for CalPrivate Bank and its customers, including auditors, attorneys, information services providers and others, to assist in performing their services.

E-mail messages sent to CalPrivate Bank through the Internet, except those sent through our website, are not encrypted (encoded). Internet e-mail messages pass through many different computers and are not secure, so we recommend that you not use unencrypted Internet e-mail to send us confidential information, such as account numbers or financial information.

We may provide links to sites outside of our website to alert you to products, information, and services offered by third parties. These links are provided as a courtesy to give you access to information that may be of interest to you, and may be to both private and public sector websites. Although we only provide links to sites we believe are reputable, we do not make any representations concerning the linked sites’ contents or availability. Please note that linked sites may have different privacy and information security policies than CalPrivate Bank. You should review each site’s privacy and information security policies carefully before you enter confidential information on that site.

The accuracy of the information we maintain is very important. If you believe we have information about you that is incorrect, outdated or incomplete, or if incorrect information appears on a statement or notice from us, you should call us at 619-437-1000 or the telephone number shown on the statement or notice; or you may write to us at: CalPrivate Bank, 9404 Genesee Ave., Suite 100 La Jolla, CA 92037. We will look into the matter and correct our records as appropriate. We may require you to provide written authorization before we make changes to your personal information.

CalPrivate Bank may update this Online Privacy Statement from time to time. If we make any material change to this Statement or in how we use your personally identifiable information, we will prominently post a notice of such change prior to implementing it and revise the effective date of this Online Privacy Statement.