In the sections that follow, we describe the types of information that are collected, and how and why that information may be shared with others.

Nonpublic Personal Information We Collect

We collect nonpublic information about you from the following sources:

• From you, forms, via the Internet, by telephone or otherwise. Examples of this non-public information include your name, address, social security number, credit history and other financial information.
• From transactions with us, our affiliates or with others. Examples include your payment histories, account balances, ATM, debit or credit card usage and other transaction records.
• From credit reporting agencies, such as information relating to your creditworthiness, your credit score and credit usage.
• From third parties to verify information you have given us.

We do NOT disclose any nonpublic personal information about our customers or former customers, except as permitted by law

We may disclose nonpublic 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 nonpublic information about you:

• 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 or recurring direct deposit payments;
• In response to requests by our regulatory agencies or companies employed by the Bank, such as independent auditors, consultants or attorneys.

As we described in Our Pledge To You, Orange Community Bank is committed to preventing others from unauthorized access to your customer information, and we design technology and maintain procedures for this purpose. We take several steps to protect the customer information we have about you, including the following:

• We update and test our technology on a regular basis in order to improve the protection of customer information.
• We require outside companies and independent contractors to whom we provide customer information for servicing or processing purposes to enter into a confidentiality agreement that restricts the use of the information for those purposes and prohibits their independent use of the information.
• Each of our employees has responsibility for maintaining the confidentiality of customer information. Our policy is to prohibit employees from accessing your personal information unless there is a business reason to do so. We train our employees to recognize the importance of customer confidentiality. Employees sign a privacy policy as part of our Personnel Policies. Employees who violate these standards are subject to disciplinary measures.
• We maintain policies about the proper physical security of workplaces and records. Our physical, electronic, and procedural safeguards comply with federal regulations regarding the protection of customer information.

At Orange Community Bank, we work hard to ensure that the customer information we maintain is complete and accurate. We have procedures and processes for updating our customer information as well as removing old information.

We protect the integrity of customer information about you through measures such as maintaining backup copies of account data in the event of power outages or other business interruptions, using computer virus detection and eradication software on systems containing customer data, and employing other technical means (known as "firewalls") to protect against unauthorized computer entry into systems containing customer information.

Visitors to Orange Community Bank's website remain anonymous. We do not collect identifying information about visitors to our site. we may use standard software to collect non-identifying information about our visitors, such as:

• Date and time our site was accessed;
• IP address (a numerical address given to servers connected to the internet);
• Web browser used;
• City, state and country

OCB uses this information to create summary statistics and to determine the level of interest in information available on our site.

Visitors may elect to provide us with personal information via e-mail or online registration forms. This information is used internally, as appropriate, to handle the sender’s request. It is not disseminated or sold to other organizations.

Some areas of our website may use a "cookie" stored in the visitor's computer memory (RAM) or hard drive to allow the web server to log the pages you use within the site and to know if you have visited the site before.

This disclosure is available in our banking offices and will be provided to you annually as long as you maintain an ongoing relationship with us. The examples contained within this policy are illustrations and they are not intended to be exclusive. We reserve the right to make changes to this policy at any time.

If we decide to change this policy:

• We will notify you in advance and give you the opportunity to "opt-out" of the sharing of your information; and
• We will obtain your explicit prior consent in writing by means of an "opt-in", in accordance with the California Financial Information Privacy Act (effective July 1, 2004).

If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.

If you have questions or comments, you can contact us at:

Orange Community Bank
Attention: Operations Administration
1045 W. Katella Avenue, Suite 100
Orange, CA 92867

You may also contact us via our website at www.orangecommunitybank.net.

If you suspect that someone has had unauthorized access to your account with us, or access to your personal identifying information such as your Social Security Number or credit card information, please notify us immediately so we can take action to protect you. In addition, you should also report the crime to your local law enforcement agency and to the Federal Trade Commission ("FTC").

You may contact the FTC by phone at their toll-free number 1-877-IDTHEFT (1-877-438-4338). You may also enter information about your complaint into a secure FTC online database at the Federal Trade Commission's website.

Unsolicited Credit Offers

If you want to reduce the number of credit offers you receive, contact the National Consumer Credit Reporting Agencyies at 1-888-567-8688 (1-888-5OPTOUT) or visit www.optoutprescreen.com for details. Financial institutions and other companies provide information to the Credit Bureaus for credit verification, fraud control purposes and prevention of identity theft. You may direct these agencies not to sell or share this information about you for marketing purposes.