PRIVACY POLICY

PURPOSE OF THIS NOTICE

Title V of the Gramm-Leach-Bliley Act (GLBA) generally prohibits any financial
institution, directly or through its affiliates, from sharing nonpublic personal
information about you with a nonaffiliated third party unless the institution
provides you with a notice of its privacy policies and practices, such as the type of
information that it collects about you and the categories of persons or entities to
whom it may be disclosed. In compliance with the GLBA, we are providing you
with this document, which notifies you of the privacy policies and practices of this
agency.

The GLBA further requires we inform you that you have a right to prevent us
from sharing nonpublic personal information about you with a nonaffiliated third
party for any purpose that is not specifically authorized by law. Your right to
prevent us from sharing nonpublic personal information about you with a
nonaffiliated third party for a purpose that is not specifically authorized by law is
called your right to “opt-out” of such information sharing.

OUR PRIVACY POLICIES AND PRACTICES

1. Information we collect:

We collect nonpublic personal information about you from the following sources:
• Information we receive from you on applications or other forms.
• Information about your transactions with us, our affiliates or others.
• Information we receive from a consumer reporting agency.
• Information we receive from medical records or medical professionals.

Unless it is specifically stated otherwise in an amended Privacy Policy Notice, no
additional information will be collected about you.

2. Information we may disclose to third parties:

We do not disclose any nonpublic personal information about our customers or
former customers to anyone, except as permitted by law.

3. Nonaffiliated third parties to whom disclosures may be made:

We disclose nonpublic personal information about you only to nonaffiliated third
parties as permitted by law.

4. Our practices regarding information confidentiality and security:

We restrict access to nonpublic personal information about you to those
employees who need to know that information in order to provide products or
services to you. We maintain physical, electronic, and procedural safeguards that
comply with federal regulations to guard your nonpublic personal information.

5. Our policy regarding dispute resolution:

Any controversy or claim arising out of or relating to our privacy policy, or the
breach thereof, shall be settled by arbitration in accordance with the rules of the
American Arbitration Association, and judgement upon the award rendered by
the arbitrator(s) may be entered in any court having jurisdiction thereof.

6. Reservation of the right to disclose information in unforeseen circumstances:

In connection with the potential sale or transfer of its interests, this agency and
its affiliates reserve the right to sell or transfer your information (including but
not limited to your address, name, age, sex, zip code, state and country of
residency and other information that you provide through other communications)
to a third party entity that (1) concentrates its business in a similar
practice or service; (2) agrees to be this agency’s successor in interest with regard
to the maintenance and protection of the information collected; and (3) agrees
to the obligations of this privacy statement.

Last Updated 6/30/2001