PRIVACY POLICY

We value you as a customer and are committed to protecting your personal information from unauthorized access. We do this in various ways. For example, the bank safeguards your personal information by restricting access to those employees who have a need to know it in order to transact your banking business. We also maintain physical, procedural and electronic safeguards that comply with federal standards to protect your personal information. Additionally, we do not disclose any nonpublic personal information about you to anyone, except as permitted by law; nor do we disclose nonpublic personal information about former customers.

When we use the terms, “you” and “your,” we mean a consumer customer who has a continuing relationship with us, such as deposit accounts, loans, safe deposit boxes, etc.

Defining Other Terms

Affiliate means any company that controls, is controlled by, or is under common control with another company. Heritage Bank of Florida does not have any affiliates.

Collect means to obtain information that we organize or can retrieve by the name of an individual or by an identifying number or other identifying information assigned to the individual.

Consumer: Any individual who is seeking to obtain or has obtained a financial product or service from a bank for personal, family, or household purposes is a consumer of that bank. The definition of consumer includes individuals who:

• apply for a financial product or service (e.g., a loan or a deposit account) for personal, family, or household purposes, and/or
• actually obtain a financial product or service (e.g., a loan or a deposit account) for personal, family, or household purposes

Customer: A customer is a consumer with whom a bank has a continuing relationship. In other words, consumers who have a deposit account, obtain a loan, or obtain an investment advisory service are considered customers.

Nonaffiliated third parties: People or entities that are not affiliates of the bank, or people who are not jointly employed by the bank and a nonaffiliated third party.

The terms “we” and “our” and “us” refer to Heritage Bank of Florida.

Nonpublic personal information consists of:

• Personally identifiable financial information that is not publicly available information (such as public records, telephone directories, etc.); and
• Lists, descriptions or other groupings of consumers that were either:
1. created using personally identifiable financial information that is not publicly available information, or
2. contain personally identifiable financial information that is not publicly available information.

Personally identifiable financial information is any information a bank collects about a consumer in conjunction with providing a financial product or service. This includes:

• information provided by the consumer during the application process (e.g., name, phone number, address, income)
• information resulting from the financial product or service transaction (e.g., payment history, loan or deposit balances, credit card purchases)
• information from other sources about the consumer obtained in connection with providing the financial product or service (e.g., information from a consumer credit report or from court records).

Exceptions To The Rule

The FDIC’s privacy rule restricts information sharing with nonaffiliated third parties. However, the rule provides several exceptions, allowing the bank to share nonpublic personal information with a nonaffiliated third party in order to:

• market the bank’s own financial products or services
• market financial products or services offered by the bank and another financial institution (joint marketing)
• process and service transactions the consumer requests or authorizes
• protect against potential fraud or unauthorized transactions
• respond to judicial process, or
• comply with federal, state or local legal requirements.

CIP POLICY

IMPORTANT INFORMATION ABOUT NEW PROCEDURES FOR OPENING AN ACCOUNT MANDATED BY THE USA PATRIOT ACT:

To help the government fight the funding of terrorism and money laundering activities, the USA PATRIOT Act, a Federal law, requires all financial institutions to obtain, verify and record information that identifies each person who opens an account, including business accounts.

What this means for you:

When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. If you are opening an account on behalf of a business entity, documents relating to the business may also be requested.