1. Keeping Customer Information Secure. We recognize customers’ expectations of privacy and security regarding personal and financial information and the need to keep that information secure. In order to safeguard this sensitive information within our organization, we have implemented standards and procedures designed to protect and prevent unauthorized disclosure and/or misuse of this information. Our privacy policy includes not only written files, but also personal information provided to us and transactions conducted on-line, including information provided when a customer requests or signs up for and uses any of our accounts or services, including account access and bill paying through our on-line banking services, or when a customer sends us e-mail. See the Security page of our website for more information about our security measures.

2. Retention and Use of Information. We collect, use and retain information about customers to identify and communicate with them, to provide them with products and services they have requested, to help us respond to questions from customers, and to inform customers about other financial services that may be of interest to them. We also use this information to comply with certain laws and regulations that may apply to us, or to an affiliate, and to help us design or improve our products and services. We collect information about customers only for specific purposes and, upon customer request, we will inform customers of the reason for asking personal information.

3. Maintenance of Accurate Information. We have procedures to see that client 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 client information, and we regularly review, test and update our technology and procedures to improve the security and accuracy of such information. We investigate client inquiries about information received from our affiliate banks (or from a credit bureau reflecting information we have provided) that the customer believes to be inaccurate and we take steps to correct information we determine to be incorrect.

4. Limiting Employee Access to Information. Each of our employees has the responsibility for maintaining the confidentiality of client information. The company requires all of its employees to protect the confidentiality of client information and to use it only for bank purposes. We have policies and security procedures to limit employee access to personal client information to those employees with a business reason to know such information. Internal access and sharing of information about customers within various service departments of the company occurs only to the extent appropriate to evaluate, structure, and facilitate the services that the customer has requested or to inform the customer of other financial services that may be of interest to him/her. We train our employees to recognize the importance of client confidentiality, and we take appropriate disciplinary measures to enforce employee privacy responsibilities.

5. Disclosure of Consumer Account Information to Others. We collect nonpublic personal information about you from the following sources:

   • Information we receive from you on applications or other forms.
   • Information about your transactions with us, our affiliates, or others.
   • Information we receive from consumer reporting agencies.

Except for California residents, we may disclose all of the information we collect, as described within the three bullet points above, to non-affiliated companies that perform marketing services on our behalf or to other non-affiliated financial institutions with which we have joint marketing agreements.

We do not disclose any other nonpublic personal information about you to anyone else, except as permitted by law.

We restrict access to nonpublic personal information about you to our employees who need the information to properly service your account(s), act upon your requests, or to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.

6. How - and why - information is shared. We limit who receives information and what type of information is shared. We do not reveal specific information about your accounts or other personally identifiable data to parties outside our affiliated banks and companies for their independent use unless: (1) you request or authorize it; (2) the information is provided to help complete a transaction initiated by you; (3) the information is provided to a reputable credit bureau or similar information reporting agency; or (4) the disclosure otherwise is lawfully permitted or required. We do not sell or provide account or personal information to companies for the purpose of independent telemarketing or direct mail marketing of any non-financial products or services of those companies.

7. Electronic Mail. Messages sent by e-mail may not be secured, may be intercepted by third parties and may not be immediately received by the appropriate department at Ohio Commerce Bank. Please do not use e-mail to send us communications that contain confidential information, which we require in writing or which need our immediate attention. Please call us instead at 216.910.0550. Be aware that "receipt" acknowledgment on an e-mail message means only that the message has routed into the Internet, not that the message has been received by Ohio Commerce Bank. Urgent or confidential matters should be addressed via phone or in person. Written authorizations should be provided via U.S. mail or in person.

8. Web Site Links. The links in this web site will let the user leave Ohio Commerce Bank’s site. The linked sites are not under the control of Ohio Commerce Bank, and Ohio Commerce Bank IS NOT RESPONSIBLE FOR THE CONTENT AVAILABLE ON OTHER INTERNET SITES. These links are provided as a convenience to users. Access to any other Internet sites linked to this web site is at the user's own risk. The inclusion of any link does not imply a recommendation or endorsement by Ohio Commerce Bank of the linked site.

9. About "cookies". Cookies are commonly used on web sites and do not harm your system. By configuring your preferences or options in your browser, you determine if and how a cookie will be accepted. We use cookies on our Internet Banking system for the sole purpose of providing additional security to our customer. There is no capturing of customer information. We also use cookies to collect anonymous traffic data that doesn’t personally identify a customer but is helpful for improving the customer’s experience.

These principles apply to individuals and we reserve the right to amend them, along with related provisions, at any time.