The directors, management, and staff of Seaway Bank and Trust Company are concerned about and respect the privacy of customers'/consumers' personal financial information. We understand that our customers furnish sensitive information to the bank in the course of daily business, and the bank is committed to treating such information responsibly. We know that our customers expect privacy and security for their personal and financial affairs.

The bank will take all the necessary steps to safeguard sensitive information that has been entrusted to us by our customers. The following privacy policy and disclosure outlines our bank's practice regarding personally identifiable financial information for consumers and those consumers who become our customers.

TYPES OF INFORMATION THE BANK COLLECTS

At Seaway Bank and Trust Company we collect nonpublic personal information about you from many sources, including the following:

• 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

Nonpublic, personal information does not include that which is available from government records, widely distributed media, or government mandated disclosures.

TYPES OF INFORMATION THE BANK DISCLOSES

The bank does not now, nor does it intend in the future, to disclose any personal financial information to any nonaffiliated or affiliated third party, with the exception of companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements. By law the bank may disclose certain personally identifiable information without allowing consumers the right to opt out of the bank's sharing agreements in the following circumstances:

• To companies who perform transaction processing for the bank in the following
      circumstances:
  • If the transaction, service or product is requested or authorized by the consumer
  • To maintain or service a consumer's account as part of a private label credit card or
        other loan extension program
  • In connection with a securitization, secondary market sale (including servicing
        rights) or similar transaction related to a consumer
• To disclose information necessary to enforce the bank's legal or contractual rights or the
      rights of any other person who is engaged in the financial transaction
• To disclose information required in the ordinary course of banking business, such as the
      settlement of claims or benefits, the confirmation of information to the consumer or the
      consumer's agent, and the billing, processing, or clearing of items in the normal course
      of business
• To provide information to insurance rate advisory organizations, guaranty funds or agencies,
      agencies that are rating the bank, persons who are assessing the bank's compliance
      with industry standards, and the bank's attorneys, accountants, and auditors
• To the extent permissible under the Right to Financial Privacy Act
• To a consumer reporting agency under the Fair Credit Reporting Act
• To comply with federal, state, or local laws, rules, and other applicable legal requirements

SERVICE PROVIDERS AND JOINT MARKETING VENTURES

The bank may disclose the following information to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements:

• Information we receive from you on applications or other forms, such as name, address, social security number, telephone number, assets, and income
• Information about your transactions with us, our affiliates, or others, such as account balances, payment history, credit card usage, and parties to transactions
• Information we receive from a consumer reporting agency, such as your creditworthiness and credit history

Although you will not have the option to opt out of this sharing agreement, if the bank shares information with a third party nonaffiliated marketing firm for the purpose of telling you about our new products or services, the bank will enter into a written agreement with the third party that will require the third party to maintain the confidentiality of the information in the same manner the bank would and to restrict its use.

The bank will not provide your personal information to nonbank companies for the purpose of their independent telemarketing or direct mail marketing of any nonfinancial products or services.

SAFEGUARDING CUSTOMER INFORMATION

At Seaway Bank and Trust Company we protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. The bank's financial privacy coordinator is responsible for maintaining internal procedures to ensure that our customers' information is protected.

All employees have a copy of this policy and are trained at least annually regarding the importance of safeguarding customer information. The financial privacy coordinator, the human resources director, and the appropriate department manager will take disciplinary action against any employee who violates the bank's privacy policy and procedures.

If we change our policy or practice by, for example, adding a category of information that we will disclose to a third party, we will notify existing customers and give them an appropriate time period to opt out of the disclosure.