Protecting customer information received through all of our service channels - at banking offices, via ATMs, by telephone, and through our Web site - is of the highest importance to us.

At Pacific Business Bank we understand that our customers ("you" or "your") have an expectation that the personal information you provide to us is to be kept confidential. Accordingly, we have a long-standing policy of protecting confidential information about you and your transactions. Our privacy policy, described below, applies not only to written files, but also to personal information you provide us through transactions you conduct on-line, by telephone, or when you send us E-mail.

Collection and Retention of Non-Public Personal Information - We collect and retain information about you to identify and communicate with you, to provide you with products and services you have requested, to help us respond to your questions, and to inform you about other financial services that may be of interest to you.

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

• Information we receive about your identity, such as your name, address, social security number, or driver's license numbers;
• Information about your transactions with us, or others, such as your account balance, loan payment history, or ATM, debit or credit card usage;
• Information that we receive from you on applications or other forms, such as information about your income and assets;
• Information we receive from consumer reporting agencies, such as your credit history and creditworthiness; and
• Information we receive from marketing analysis companies for marketing purposes, such as economic and demographic data.

Disclosure of Non-Public Personal Information to Non-Affiliated Third Parties - We do not disclose non-public personal information about you or our former customers to non-affiliated third parties, except as permitted or required by the California Financial Information Privacy Act Division Code 1.2. We may disclose all of the information we collect, as described in the Collection and Retention of Non-Public Personal Information section above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements to offer financial products and services to you.

Disclosure of Non-Public Personal Information in Other Circumstances -We may also disclose non-public personal information about you as necessary to effect, administer, or enforce transactions that you have requested or authorized, or in connection with servicing or processing a financial product or service you have requested or authorized, or to maintain or service your accounts with us, or as otherwise described below. We normally disclose information:

• When it is necessary or helpful in completing a transaction;
• To verify the existence and condition of your account for a third party, such as a merchant, another financial institution or a credit reporting agency;
• To an account verification service, in addition to a credit reporting agency, if we close your account due to unsatisfactory handling, fraud, attempted fraud
or criminal activity;
• To comply with a law, regulation, legal process or court order which applies to us or to an affiliate;
• In response to an inquiry about sufficient funds to cover a check you have written;
• When you authorize us to;
• To other companies, financial institutions and networks which may be involved in processing your transactions;
• To local, state or federal authorities, if we believe a crime may have been committed;
• To paying agencies after the death or incapacity of a recipient or beneficiary of recurring direct deposit payments;
• To our agents and affiliates and to third parties who perform services or functions on our behalf to facilitate the delivery of information related to your accounts or to other financial services that may be of interest to you;
• In response to requests by our regulatory agencies or requests by agents of the Bank or its affiliated companies, such as independent auditors, consultants or attorneys.

Our Employees’ Access to and Use of Customer Information - Each of our employees has responsibility for maintaining the confidentiality of customer information. We require all of our employees to agree in writing to protect the confidentiality of customer information and to use it only for our business purposes. Our policy is to prohibit employees from accessing your personal information unless there is a business reason to do so. Internal access and sharing of information about you within our various service units occurs to evaluate structure and facilitate the services you have requested or to inform you of other financial services that may be of interest to you. We train our employees to recognize the importance of customer confidentiality. Employees who violate these standards are subject to disciplinary measures.

Our Security Procedures – We also take other steps to safeguard customer information by maintaining physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information.

Maintaining the Accuracy of Customer Information - We have procedures to see that customer information is maintained in a commercially reasonable manner so that it is accurate, current, and complete. We also have procedures to see that requests to correct inaccurate or incomplete information are acted upon in a timely manner. We maintain security standards and procedures to help prevent unauthorized access to confidential customer information, and we regularly review, test and update our technology and procedures to improve the security and accuracy of such information. We investigate your inquiries about information received from us (or from a credit bureau reflecting information we have provided) that you believe to be inaccurate and we take steps to correct information we determine to be incorrect.

Maintaining Confidentiality in Our Business Relationships with Other Companies -From time to time we contract with other businesses to perform specific services in support of our products. When it is necessary to provide confidential customer information to a third party, we require each business that we select to agree to adhere to the same privacy standards, laws and regulations that apply to us. That is, we require such third parties to agree to safeguard non-public personal information regarding our customers in accordance with our own privacy policies.

On-line Banking Security - At Pacific Business Bank we take security very seriously. The latest methods in Internet system security, as upgraded from time to time, are used to increase and monitor the integrity and security of our system.

Internet security does not rely on technology alone. Without everyone's participation, all the security systems and technology in the world are worthless. You must treat your User ID and password with the same care as a debit card and PIN. In addition, you must make sure that no one is physically watching when you enter your password. If you are logged in to the service, be sure to log off of the service and exit the browser when you leave the computer unattended. You should also take standard precautions to keep you system clean and free from viruses that could be used to capture password keystrokes and financial information.

If you should have additional questions regarding security of our internet site, Please visit our site at www.PacificEnterpriseBank.com or contact us at 949-623-7600

Availability of Disclosure of Privacy Policy – This disclosure is available in our banking office and on our website at www.PacificEnterpriseBank.com

Children’s Privacy - Our web site is directed to a general audience. We do not knowingly solicit or collect personal information from children on our site.

If you should have additional questions regarding security of our internet site, Please contact us at (949) 623-7600. This disclosure of our privacy policy applies to consumers. We may make changes to this policy at any time. All notices we furnish to you may be sent by mail addressed to the last address shown in our records for you or presented to you upon login to the online service within the time frames required under state or federal law.
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                                                                                                Revised June 2008