At Mercantil Commercebank Trust Company, N.A. we respect the privacy expectations of our customers and we recognize our obligation to keep the information you provide to us secure and confidential. Our commitment is based on the principles and guidelines described below.

The policies and practices described in this disclosure are subject to change, but we will communicate any significant changes to you as required by applicable law. The policies and practices described in this disclosure replace all previous notices or statements regarding this subject.

Information Collection and Use of Information

We collect non public personal information about you from the following sources:

• Information we receive from you on applications or other forms such as your name, address, social security number, assets and income
• Information about your transactions with us, our affiliates or others such as your account balance and payment history

Information Sharing
We do not disclose any non public personal information about our customers or former customers to anyone, except as permitted by law. We are permitted by law to share non public personal information about you with:

• Our affiliates such as account history and experience
• Non-affiliated third parties as may be necessary to serve your needs such as specialists that perform business operations for us (i.e. check printers)
• Others only as permitted or required by law such as federal, state or local authorities (i.e.respond to a subpoena)

Protecting Customer Information
We are committed to protecting the security and integrity of customer information through procedures and technology designed for this purpose.

For example:

• We limit employee access to customer information to those who need to know this information in order to service customer relationships
• We maintain policies and procedures covering the proper physical security of workplaces and records
• Our physical, electronic and procedural safeguards comply with federal standards regarding the protection of customer information
• We require independent contractors and outside companies who work with us to adhere to our strict privacy standards

Internet and Electronic Communication
When you access our website, we use cookies as part of our interaction with your browser. A cookie is a small text file placed on your hard drive by our Web Page server. Cookies are commonly used on Web sites and do not harm your system. We use cookies to determine if you have previously visited our Web site and for a number of administrative purposes.

We use technological means (such as backup files, virus detection and eradication software, firewalls and other computer software and hardware) to protect against unauthorized access or alterations to customer data. Additionally, if you communicate with us via our Internet site or via e-mail, we may preserve the content of your e-mail, your e-mail address and our response so that we can more efficiently handle any follow-up regulatory requirements. As information sent to and from us via Internet e-mail may not be secure, please do not include confidential account information in your e-mail to us. To discuss confidential information, we ask that you contact us by telephone or in writing.

Protecting Our Children
We do not knowingly solicit data from children and we do not knowingly market to children. We recognize that protecting children’s identities and privacy online is important and that the responsibility to do so resides with both the online industry and with the parents.

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