TransAtlantic Bank, Member FDIC. Equal Housing Lender

NOTICE OF YOUR FINANCIAL PRIVACY RIGHTS

TransAtlantic Bank recognizes and respects each customer's expectation that their privacy will be protected. We will collect and use only that information about our customers needed for legitimate business purpose. We will strive to maintain information about our customers that is both accurate and complete.

TransAtlantic Bank will aim to limit access to information about our customers to those authorized individuals who have legitimate need to know. We will maintain security measures that guard access to and disclosure of information about our customers. TransAtlantic Bank will not disclose information about accounts or transactions to outside parties unless there is an appropriate legal or business justification. We will ask outside parties who process information about our customers to abide by the "TransAtlantic Bank's Privacy Rights."

In this notice we will tell you the sources of the information we collect about you. We will also tell you what measures we take to secure that information. We first define some terms:

We, our, and us, when used in this notice, mean TransAtlantic Bank.
You and Your, when used in this notice, mean the following types of customers:

Our consumer customers who have a continuing relationship by purchasing or holding financial products or services such as a(n):
Deposit account
Loan account
Credit card account
Safe deposit box
Retail installment contract we hold and service
All IRA accounts for which we act as custodian
Former consumer customers

Nonpublic personal information means information about you that we collect in connection with providing a financial product or service to you. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records. Hereafter, we will use the term "information" to mean nonpublic personal information as defined in this section.

An affiliate means a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control.

A nonaffiliated third party means a person we do not employ or a company that is not an affiliate of ours. This is also known as nonaffiliated third party, or simply, an "other party"

YOUR INFORMATION WE COLLECT

To serve you better and manage our business, it is important that we collect and maintain accurate information about you. We obtain this information from applications and other forms you submit to us, from your dealings with us, from consumer reporting agencies, from our Web sites and from third parties and other sources. For example, we collect information about you from the following sources:

Information you give us on applications or other forms
Information about your transactions and experiences with us
Information about your transactions with other parties
Information from a consumer reporting agency
Information we receive as a result of verifying customer information

INFORMATION WE MAY DISCLOSE

We do not disclose any nonpublic personal information about you to non-affiliated third parties, except as authorized by law. For example, some instances where we may disclose information about you to non-affiliated third parties include, but are not limited to, the following:

for servicing and processing transactions on your accounts (i.e. processing checks, wire transfer services, storage facilities)
to consumer reporting agencies, as necessary
in response to a subpoena, court order or other legal process, or in connection with an audit or bank examination
to offer our own products and services
to protect against fraud
for institutional risk control

To better service you and your account(s) effectively, to service and process your transactions, to let you know about products and services offered by us and other affiliates, and as otherwise required or permitted by law, we may disclose personal information within TransAtlantic Bank and its affiliates. We have the same policy about disclosing information about former customers as we do about current customers.

INFORMATION SHARING WITH AFFILIATES

We may disclose non-public personal information about you to our affiliates, which includes, among others, the following types of affiliates:

Financial service providers such as, mortgage bankers, securities broker-dealers, and insurance agents
Non-financial companies such as, retailers, direct marketers, airlines, and publishers
Others such as, non-profit organizations

Here are the kinds of information we disclose to our affiliates:

Information about your transactions and experience with us, such as:
Name
Address
Account balances
Account activity
Types of accounts
Payment history
Deposit history

Federal law allows us to disclose the transaction and experience information listed above with our affiliates. You do not have a right to opt out of the disclosure of this information. Unless otherwise permitted by law, TransAtlantic Bank does not share creditworthiness information (i.e., information from loan/credit applications, credit bureau information, credit reporting agency information, etc.) about you or your account with our affiliates.

TECHNOLOGY AND CUSTOMER INFORMATION:

Technology and new marketing practices have increased the amount of customer information collected and shared in today's marketplace. Consumers are concerned about the impact this development has or might have on their privacy and reputation. At TransAtlantic Bank, we are sensitive to the importance of these concerns. We want to serve customers as effectively and conveniently as possible, and such service involves making use of technology and customer information. But TransAtlantic Bank also wants its customers to be confident that their relationship with TransAtlantic Bank is treated with the appropriate confidentiality. We, therefore, commit to customers that we will take reasonable steps to protect the privacy of the information shared with us. Our customers are protected not only by state and federal laws but, even more importantly, by TransAtlantic Bank's commitment to them.

THE CONFIDENTIALITY, SECURITY, AND INTEGRITY OF YOUR INFORMATION

TransAtlantic Bank is committed to the security of your financial and personal information. We maintain physical, electronic, and procedural safeguards to protect this information. All of our operational and data processing systems are in a secure environment that protects your account information from being accessed by third parties. We maintain and grant access to customer information only in accordance with our internal security standards. Additionally, all of our service providers must implement appropriate measures to have a security program in place. We restrict access to information about you to those employees who need to know that information to provide products or services to you. TransAtlantic Bank's employee access to personally- identifiable customer information is limited to those with a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of customer information and on these privacy principles. Additionally, all of our employees are under a written "code of ethics" that requires the confidential treatment of our customers' information. Because of the importance of these issues, all TransAtlantic Bank employees are responsible for maintaining the confidentiality of customer information, and employees who violate these privacy policies will be subject to disciplinary measures. TransAtlantic Bank also helps protect customers against, and educate customers about how to protect themselves from, criminal use of their information. We use a combination of safeguards to protect customer information, such as employee training, rigorous security standards, encryption and fraud detection. We work with the law enforcement officials to pursue individuals who fraudulently use information. Moreover, any select information pertaining to you that we may have to, from time to time, share with our affiliated offices in order to properly service your account and meet your financial needs, is highly controlled and safe guarded to ensure that your privacy and confidentiality is not compromised.

ANNUAL NOTICE

TransAtlantic Bank will provide notice annually as long as you maintain an ongoing relationship with us. This policy may change from time to time but we will inform you of any changes in a timely manner. Additionally, you can obtain our Privacy disclosure at any of our offices/branches and on our website at www.transatlanticbank.com.

USE OF OUR INTERNET WEBSITE:

Our user-friendly Internet web site (www.transatlanticbank.com) invites customers to provide information about themselves as well as other information request screens from the privacy of their own personal computer. The personal information you provide to us over the Internet allows us to respond quickly to questions about our available products and services. We will also use this information to furnish you with suggestions about other products and services we believe may be of interest and benefit to you. TransAtlantic Bank's internal security standards safeguard your personal information submitted by computer in several ways. Encryption helps protect your private data from interception by a third party. We have also installed passcodes and other safety features to ensure the information you provide us on the Internet is safe and secure.

DO NOT CALL POLICY-TRANSATLANTIC BANK

It is the policy of TransAtlantic Bank to comply with all of the federal requirements regarding telemarketing and to protect the privacy of its customers in the event that it is conducted by its employees or a third party. If you, our customer, do not want to receive sales or marketing- related calls from TransAtlantic Bank you can request to have your name, address and telephone number placed on our internal "DO NOT CALL" list. We will record your request and honor it within (3) days by calling (305) 377-0200 operations department, writing to us at TransAtlantic Bank-Operations Dept.-48 E. Flagler Street Miami, FL 33131 or via e-mail at webmaster@transatlanticbank.com. Please notify us if your information changes or if you want to be removed from the bank's internal DO NOT CALL list. Inclusion on this list means that you will not receive sales calls by anyone representing TransAtlantic Bank. Please note that even if you, our customer, elect to be on the TransAtlantic Bank's internal DO NOT CALL list you will continue to be contacted to service your account when needed and will also receive future marketing information that is sent as a regular mailing or through our website to all of our customers.

THANKS FOR CHOOSING TRANSATLANTIC BANK

Whether it is on the Internet, in person, via telephone, or mail, we at TransAtlanticBank are committed to protecting your privacy. And you can rest assured, we will continue to provide you with the most up-to-date safeguards possible to ensure the safety of your personal financial information.

Click here to download the Privacy Disclosure form (in Adobe Acrobat Reader .PDF format)