Privacy Statement

At First Private Bank & Trust (FPB&T) w e understand that your privacy is important to you. We believe that protecting your information is a fundamental responsibility. And while information is often critical in providing a high standard of service, we recognize that the most important asset is your trust. That is why the safekeeping of all customer information is our priority at First Private Bank & Trust.

This policy applies only to individual customers who obtain a financial product or service primarily for personal, family or household purposes. If you become a former customer, this policy will still apply to you.
We may revise this policy at any time and will give you such notice of the changes as may be required by law.

OUR BANK'S INFORMATION MANAGEMENT PRACTICES
First Private Bank & Trust collects and retains non-public customer information (“customer information”) for business purposes only from some or all of the following sources:

•  Information we receive from you on applications or forms, such as your name, address, social security number, assets and income;
•  Information about your transactions with us, or our affiliate companies, such as your account balance, payment history, parties to transactions and credit card usage; and
•  Information we receive from a consumer-reporting agency, such as your creditworthiness and credit history.
•  Information from Outside Sources - information from outside sources regarding employment, credit and other relationships that will help us determine if you are eligible for products you request. Examples include employment history, loan balances, credit card balances, property insurance coverage and other verifications.

As required by the USA Patriot Act, we also collect information and take actions necessary to verify your identification. We will tell you why we are collecting and retaining the information upon your request.

RESTRICTIONS ON THE DISCLOSURE OF ACCOUNT INFORMATION
We may disclose all of the information we collect about you, as described above, to our affiliates and to certain nonaffiliated third parties, as permitted by law. These companies may include credit reporting agencies and companies that provide services related to your account, or sharing in response to lawful subpoenas, with our regulators or attorneys, or other legally permitted purposes.

We also may disclose all of the information we collect to companies that perform marketing services on our behalf. We do not, however, provide information to non-affiliated companies for the purpose of independent telemarketing or direct mail marketing of any products or services of those companies.

MANAGING INFORMATION WITHIN FIRST PRIVATE BANK & TRUST AND ITS AFFILIATES
FPB&T is owned by Boston Private Financial Holdings and is part of an affiliated group of companies owned by BPFH, including financial service providers such as other banks and investment management companies. FPB&T may share any of the categories of Customer Information among our holding companies or affiliate companies in order to complete transactions. For example, sharing information could save you time opening your new account since you may not need to furnish the same information twice. Sharing information also allows us to use information about your ATM, and check transactions to identify any unusual activity and then contact you.

MANAGING INFORMATION WITH COMPANIES THAT WORK FOR US
We may share any of the categories of Customer Information with companies that work for us. All nonaffiliated companies that act on our behalf and receive customer information from us are contractually obligated to keep the information we provide to them confidential, and to use the Customer Information we share only to provide the services we ask them to perform. These companies may include financial service providers such as payment processing companies, and non-financial companies such as check printing and data processing companies. These companies might assist us, for example, in processing your transactions, mailing account statements and fulfilling your service requests.

In addition, we may share any of the categories of Customer Information with companies that work for us in order to provide marketing support and other services, such as a service provider that distributes marketing materials. These companies may help us to market our own products and services.

The following companies are FPB&T affiliates:
Anchor Capital Advisors, LLC and Anchor/Russell
Bingham, Osborn & Scarborough, LLC
Borel Private Bank & Trust Company
Boston Private Bank & Trust Company
Boston Private Value Investors, Inc.
Coldstream Capital Management, Inc.
Dalton, Greiner, Hartman, Maher & Co., LLC
Gibraltar Private Bank & Trust Company
KLS Professional Advisors Group, LLC
RINET Company, LLC
Sand Hill Advisors, LLC
Westfield Capital Management Company, LLC

MAKING SURE INFORMATION IS ACCURATE
Keeping your account information accurate and up to date is very important. You have access to your account information, which includes your contact information, account balances and transactions and similar information which we provide to you through various means, such as account statements, telephone banking, Online Banking, and in response to specific requests. If your account information is incomplete, inaccurate or not current, please call or write to us at the telephone number or appropriate address for such changes listed on your account statement, bank records or other account materials. We will promptly update or correct any erroneous information.

This policy applies to consumer customer relationships established in the United States and is effective July 1, 2006 . You may have other privacy protections under state laws, such as Vermont and California . To the extent these state laws apply, we will comply with them with regards to our information practices.

Security Statement
This Internet Banking System brings together a combination of industry-approved security technologies to protect data for the bank and for you, our customer. It features password-controlled system entry, a VeriSign-issued Digital ID for the bank's server, Secure Sockets Layer (SSL) protocol for data encryption, and a router loaded with a firewall to regulate the inflow and outflow of server traffic.

Secure Access and Verifying User Authenticity
To begin a session with the bank's server the user must key in a Log-in ID and a password. Our system, the Internet Banking System, uses a "3 strikes and you're out" lock-out mechanism to deter users from repeated login attempts. After three unsuccessful login attempts, the system locks the user out, requiring either a designated wait period or a phone call to the bank to verify the password before re-entry into the system. Upon successful login, the Digital ID from VeriSign, the experts in digital identification certificates, authenticates the user's identity and establishes a secure session with that visitor.

Secure Data Transfer
Once the server session is established, the user and the server are in a secured environment. Because the server has been certified as a 128-bit secure server by VeriSign, data traveling between the user and the server is encrypted with Secure Sockets Layer (SSL) protocol. With SSL, data that travels between the bank and customer is encrypted and can only be decrypted with the public and private key pair. In short, the bank's server issues a public key to the end user's browser and creates a temporary private key. These two keys are the only combination possible for that session. When the session is complete, the keys expire and the whole process starts over when a new end user establishes a server session.

Router and Firewall
Requests must filter through a router and firewall before they are permitted to reach the server. A router, a piece of hardware, works in conjunction with the firewall, a piece of software, to block and direct traffic coming to the server. The configuration begins by disallowing ALL traffic and then opens holes only when necessary to process acceptable data requests, such as retrieving web pages or sending customer requests to the bank.

Using the above technologies, your Internet banking transactions are secure.

Contact Us at: 818-501-1700 or info@1stprivate.com