Privacy Policy

Privacy is one of the most important services we provide our customers. The safeguarding of your information is a priority to us. This is true whether we are working with networks, paper files or computers. We look for ways to increase the security of your information that you entrust with us. Commerce National Bank respects the privacy of its customers and is committed to protecting their information on our Web site. If you have any questions, please contact us at the phone number listed in our Web site.

This Customer Privacy Policy only applies to individuals and families. It does not apply to any other type of client; for example, businesses or corporations.

Our Collection, Retention, and Use of Customer (Consumer) Information

We collect, retain, and use information about customers only where we reasonably believe that it will help administer our business or provide products, services, and other opportunities to them. We only collect non-identifying information about visitors to our Web site such as: (1) date and time the site was accessed, (2) what pages were visited, (3) what servers were used, and (4) the city of the visitor as identified by the server address. We use information to protect and administer customer records, accounts, and funds; to comply with certain laws and regulations; to help us design or improve our products and services; and to understand customers financial needs so that we can provide them with quality products and superior services.

This information is used as appropriate by employees of the Bank to respond to a request submitted through the Web site, and may be used to send you information, offers or special promotions concerning Bank products or services. This information is not otherwise disseminated outside the Bank and is never sold to organizations.

For a full description of our privacy policies please see Commerce National Bank Customer Privacy Principles.

We train and require our employees to protect the privacy of information about our customers regardless of the medium used to fulfill customer financial needs. To protect the privacy of our customers, we use appropriate security standards and procedures to control access to customer information.

Email

Email is not a secure way of communicating. Please do not send us any sensitive personal information via email.

Technical Safeguards Used for the Internet Banking System

The Internet Banking System brings together a combination of industry-approved 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, Secured Socket 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 makes 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.

UNAUTHORIZED ATTEMPTS TO UPLOAD OR CHANGE INFORMATION ON THE WEBSITE ARE STRICTLY PROHIBITED AND ARE SUBJECT TO PROSECUTION UNDER THE COMPUTER FRAUD AND ABUSE ACT OF 1986 AND TITLE SEC. 1001 AND 1030.

Commerce National Bank - Customer Privacy Principles

At Commerce National Bank our customers are our highest priority. As financial services professionals entrusted with sensitive financial information, we respect the privacy of our customers and are committed to treating customer information responsibly. Our Customer Information Privacy principles serve as standards for all Commerce National Bank employees for collection, use, retention, and security of all consumers' information.

We use the eight Privacy Principles below to guide us in dealing with consumer information.

Privacy Principles

1. Recognition of Customers' Expectation of Privacy
   We believe the confidentiality and protection of customer information is one of our fundamental responsibilities. And while information is critical to providing quality service, we recognize that one of our most important assets is our customers' trust. Thus, the safekeeping of customer information is a priority with the Commerce National Bank.
2. Our Collection, Retention, and Use of Customer (Consumer) Information
   We collect, retain, and use information about customers only where we reasonably believe that it will help administer our business or provide products, services, and other opportunities to them. We collect and retain information about customers only for specific business purposes - and we tell customers why we are collecting and retaining it upon their request. We use information to protect and administer customer records, accounts, and funds; to comply with certain laws and regulations; to help us design or improve our products and services; and to understand customers financial needs so that we can provide them with quality products and superior services.
3. Maintenance of Accurate Information
   We have established procedures to ensure that customer financial information is accurate, current and complete, in keeping with reasonable commercial standards. If account information is found to be incomplete, inaccurate or not current, a customer can call us or write us at the telephone number or address listed on their account statement. We will investigate all concerns and correct any inaccuracies in a timely manner.
4. Limiting Employee Access to Information
   Employee access to personally identifiable customer information is limited to those with a business reason to know such information. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, periodic training programs and these Privacy Principles. Our employee's access information about customers when needed to maintain their accounts or otherwise meet specific needs. We may also access information about customers when considering a request for additional services or when exercising our rights under the law or any agreements with them. We take appropriate disciplinary measures to enforce employee privacy responsibilities.
5. Security Procedures to Protect Information
   We maintain security standards and procedures to help prevent unauthorized access to confidential information about customers. We safeguard information according to established security standards and procedures, and we continually assess new technology for protecting information.
6. Restrictions on the Disclosure of Account Information
   We do not reveal specific information about accounts or other personally identifiable data to parties outside of Commerce National Bank for their independent use unless: 1) it is requested or authorized; 2) the information is provided to help complete a transaction initiated by a customer; 3) the information is provided to a reputable credit bureau or similar reporting agency; or 4) the disclosure is required by or allowed by law (e.g., subpoena, investigation of fraudulent activity, request by regulator, etc.). We do not provide account or personal information to non-affiliated Commerce National Bank companies for the purpose of independent telemarketing or direct mail marketing of any non-financial products or services.
7. Maintaining Customer Privacy in Business Relationships with Third Parties
   Sometimes it is necessary to provide personally identifiable information about customers to a third party, such as a vendor or service company that we hire to prepare account statements or to provide support services for one or more of our products. These vendors and service companies agree to safeguard our confidential information about customers and their products and services with us must abide by applicable law.
8. Disclosing Our Privacy Commitment to You
   We want customers to understand how we use the information they provide and our commitment to their personal privacy. As a result of our commitment, we have developed these Privacy Principles, which are made readily available to our customers. If you have questions about how Commerce National bank protects confidential information, please call one of our branches or contact us using the e-mail reply function located on our Web page.

Former Customers

In the event you end your relationship with us, or become an inactive customer, we will continue to treat the information we have about you as if you were still our customer and adhere to the policies and practices descibed in this disclosure.

Changes to Our Privacy Policy

These Privacy Principles apply to individuals, and we reserve the right to change them, along with related provisions, at any time. Should we make changes to our Privacy Statement, we will notify you in Bold Font on our Home page with the new effective date of our Privacy Statement.

Effective Date: 8/22/2011