The Importance of Privacy
The Board of Directors and Management of Western Commercial Bank, understand how important personal privacy is to our customer.  This Statement describes our policies and practices concerning information we gather through our Web site about individual non-business customers (including information about their accounts, loans and other banking services for personal, family or household purposes) and information about other visitors to our Web site.  For a description of our general policies and practices concerning information about individual customers and former customers, including your right to opt out of certain kinds of information sharing, you may request a copy of our most recent Privacy Notice by calling Customer Service at 818 449-7700 or visiting our office.

Visiting our Web Site
When you visit our Web site, we do not collect personal information about you, unless you do one of the following:

Log into our online banking systems.
Send us an inquiry or e-mail message.

We gather statistics and other information about the usage of our Web site, such as the number of times each Web page was loaded into visitors' browsers and visitors' domain IP addresses (identifying numbers assigned to servers or computers used to access the Internet), in order to review how our Web site is used and how it might be improved, and to insure site security.

If you use our online banking systems, you may send us various kinds of information, depending on the services you use: for example, you may send us log-in information (user name and identifying number), information about the content of reports and data you request, and information about your accounts and transactions you wish to perform, such as funds transfers, stop payments and check orders.  We use the information you send us to respond to your requests, and we will maintain customary records of any resulting banking transactions.  We may retain any messages or information you send us for reference in connection with current or future inquiries and transactions, for internal administrative purposes (including data backup) and, in some instances, to fulfill legal requirements.  We may place a temporary “cookie” (a small text file) on your computer to identify you and provide you with customized information when you use certain features of our online banking systems.

Inquiries
If you send us an e-mail message or an inquiry through our Web site, the information you send (including your e-mail address and other identifying information in the message header) will be forwarded to the appropriate employee within Western Commercial Bank for response.  We use the information you send us to respond to your requests, and we will maintain customary records of any resulting banking transactions.  We may retain any messages or information you send us for reference in connection with current or future inquiries and transactions, for internal administrative purposes (including data backup) and, in some instances, to fulfill legal requirements.

Western Commercial Bank does not make your e-mail address or any other information you furnish by e-mail or through our Web site (including information you furnish when you use our online banking systems available without your consent to companies or persons not affiliated with Western Commercial Bank, except as follows:

We may provide information to third parties, such as funds transfer networks, in order to complete a banking transaction for you.

We comply with court orders, subpoenas and other legal process we determine to be valid, and we may provide information as otherwise required or permitted by law, including to bank regulatory agencies.

We may provide information to credit reporting agencies and similar services; to investigators or law enforcement authorities in connection with a fraud or similar investigation; and to potential purchasers in connection with the sale of accounts, loan assets or business lines.

We may provide information to contractors and agents who perform services for Western Commercial Bank and its customers, including auditors, attorneys, information services providers and others, to assist in performing their services.

Western Commercial Bank does not sell customer information gathered through our Web site to third parties for the purpose of marketing their products or services.  However, we may inform you about services and products that Western Commercial Bank offers, and we may retain third parties to assist us in doing so.  We have written policies that require Bank employees to keep customer information confidential and use it only for legitimate Bank purposes.

E-mail Messages
E-mail messages sent to Western Commercial Bank through the Internet, including inquiries sent through our Web site, are not encrypted (encoded).  Internet e-mail messages pass through many different computers and are not secure, so we recommend that you not use unencrypted Internet e-mail to send us confidential information, such as account numbers or financial information.  However, information and messages you send us from secure pages when you are logged onto online banking systems are encrypted.  Once we receive information and messages from you (whether or not they were encrypted), the information is stored on Western Commercial Bank’s computers, where various measures protect it from unauthorized access by outside parties.  For more information about our Internet measures and practices, click here.

The accuracy of the information Western Commercial Bank maintains is very important.  If you believe we have information about you that is incorrect, outdated or incomplete, or if the information you think is wrong appears on a statement or notice from us, you should call us at 818-449-7700 or the telephone number shown on the statement or notice.  We will look into the matter and correct our records as appropriate. 

Effective 10/17/2005