At Community Southern Bank, we know that our clients expect and rely on us to maintain the confidentiality and privacy of all the information about them in our possession and control. Maintaining that trust and confidence of our clients is our highest priority. We never take for granted the trust our clients have placed in us and we honor that trust by managing our clients' personal information with the highest level of care and discretion. We are, and always will be, committed to maintain the confidentiality of client information.

Our clients are those individuals and businesses to whom we provide banking and other related financial services. We have adopted this policy to guide our conduct when we collect, use, maintain or release client information and to assist our clients to better understand our privacy practices.

PRIVACY PRINCIPLES

Recognize a client's expectation of privacy
We understand our moral, professional and legal obligations to our clients and former clients to maintain the privacy of all the information about them in our possession and control. We will obey all applicable laws respecting the privacy of this information and will comply with the obligations of the law respecting nonpublic personal information provided to us. We continually review and test our policies, procedures and our technology to insure that this information is safeguarded to our satisfaction and as required by law.

Client Information Security and Confidentiality
We take a number of steps to ensure that client information is adequately safeguarded. These steps include the following:

1. implementing a number physical and electronic security features to prevent unauthorized access;

2. limiting access to client information to those employees responsible for servicing the needs of the client and those colleagues who reasonably need such information to perform their duties and as required or permitted by law; and,

3. conducting periodic reviews of our computer systems, including security features.

Additionally, our employees are required to acknowledge their responsibility to maintain the confidentiality of client information.

Collection of Client Information
We collect, use and retain client information, including non-public personal information, about our clients and prospective clients that we believe is essential for us to understand and meet the their financial needs and requests, to administer and maintain their accounts, to provide them with products and services, to protect them and us from fraud or unauthorized transactions, and to meet legal requirements.

We only collect client information that:

1. we receive on applications to us for our products or services;

2. we receive from processing your accounts with us and the transactions in those accounts, such as deposit accounts and loans, as well as information from providing services to you such as investment advisory or trust services;

3. we receive from a consumer reporting agency, such as a credit bureau;

4. we receive in response to requests made to third parties about you or to confirm information that you have provided to use, particularly in the process of evaluating applications for loans.

5. we obtain through an information collecting device from a Web server. (For more information read our Online Privacy.)

Disclosure of Client Information
We do provide client information, including non-public personal information, to our vendors and other outside service providers whom we use when appropriate and necessary to perform and enhance our client services. When we provide client information to anyone outside our organization we only do so as required or permitted by law. We require all of our vendors and service providers, who receive client information from us, to agree to maintain the information in confidence, to limit the use and dissemination of the information to the purpose for which it is provided and to abide by the law. We monitor that each outside vendor and service provider receiving non-public personal information from us complies with our confidentiality requirements.

Under the following circumstances, we may disclose client information:

1. when requested by the client;

2. when informing you of other products or services;

3. when necessary, in our opinion, to verify or complete a client-initiated transaction;

4. when verifying the existence and condition of your account for a third-party, such as a merchant, another financial institution or a credit bureau;

5. when assisting a third-party in performing functions on behalf of the Bank; or,

6. when complying with law, regulation or a court or government order or request.

Client Information about Former Clients
We apply the same privacy policies and practices to our former clients that we do to our existing clients. All collected information is retained in accordance with Federal law.

Client Information; Accuracy
At Community Southern Bank, we recognize the importance of maintaining accurate client information that is provided to you in various forms, including account statements, online banking, and billing statements. If you ever notice that your information is inaccurate, please contact us. Upon your notification, we will correct any inaccuracies.

Employee Compliance
We educate all our employees about these privacy principles and their obligations to maintain confidentiality and privacy of client information as described in this Policy and our Code of Conduct and we take appropriate disciplinary measures to enforce these obligations.

Privacy Policy Availability
A copy of Community Southern Bank’s privacy policy may be obtained by visiting or contacting our office at 3234 South Florida Avenue, Suite J; Lakeland, Florida, 33803; (863) 648-2265.