Effective August 2, 2006

At AQUESTA Bank, we recognize the sensitive nature of your financial information, and take appropriate precautions to protect customers’ privacy. AQUESTA Bank is required by banking regulations to provide our customers with a document illustrating the types of customer information we collect and the circumstances under which we may share this information. This policy and/or disclosure statement describes those practices for AQUESTA Bank.

AQUESTA Bank will not trade, rent or sell customers information to anyone. AQUESTA Bank will not provide account or personal information to non-AQUESTA Bank companies for the purpose of independent telemarketing or direct mail marketing of any non-financial products or services. Only in extremely limited circumstances, outlined below, do we share your information with other financial services firms for marketing purposes.

This policy statement takes the place of any previous privacy policies issued by AQUESTA Bank. If, in addition to federal law, customers are protected by specific state and/or local regulations concerning information sharing, AQUESTA Bank will fully comply with those regulations as well.

The information AQUESTA Bank collects:

If you apply for a loan or a new account, AQUESTA Bank asks that you to provide information about your financial status, such as employment, income, monthly expenses and assets, as well as identifying information such as your address, telephone number and/or Social Security number.

In most cases, you give us this information yourself, in person, by mail, or through the AQUESTA Bank website. If AQUESTA Bank needs to know about your credit and repayment history, we also obtain information from consumer reporting agencies and other creditors. If you apply for insurance, we ask you to provide information relevant to underwriting the specific insurance product. This information, such as information about your health or driving record, is not used for any purpose other than to provide the service and insurance for which you applied.

Once you become a customer of AQUESTA Bank:

We maintain information about your transactions including account balances, securities holdings and repayment history. Because it's important to know what types of services may be most valuable to you, we obtain statistics and demographic information about current and prospective customers from marketing information firms. The information we collect is used to help us deliver the services you've requested easily and efficiently. It may also permit us to design and offer specific products and services that we believe will be useful to you and other customers.

AQUESTA Bank:

AQUESTA Bank employees are permitted access to the information they need to perform their jobs on your behalf. We maintain strict internal policies against unauthorized disclosure or use of customer information by employees. AQUESTA Bank has a number of non-affiliates and/or partners offering a wide variety of services such as mortgage banking, securities brokerage, insurance sales, leasing, consumer finance and many others. As permitted by law, information held by any of AQUESTA Bank non-affiliate and/or partners is available to other members of the AQUESTA Bank organization for authorized purposes, unless you, our customer, has specifically requested otherwise.

Third Party Sharing:

From time to time, we will make available the services of other products such as homeowner's insurance coverage for AQUESTA Bank mortgage applicants. In these cases, AQUESTA Bank will get your permission prior to sharing your information with the outside firm. AQUESTA Bank may get your written, online or verbal permission to share your information. If you grant permission, it will apply only to the specific program or programs you consent to. If you have previously requested that we block the sharing of your information, that request will remain in place for all other situations.

AQUESTA Bank service providers:

AQUESTA Bank has arrangements with companies whose experience is essential for our own services to operate properly. AQUESTA Bank may also share customer information with unaffiliated service providers who perform services for AQUESTA Bank that are connected with the processing of products and services that you already have or have requested. AQUESTA Bank shares information with such companies to support your experience and relationship with AQUESTA Bank. These companies may include other financial service providers such as insurance companies, payment processing companies, as well as companies such as check printing and data processing companies. These companies might assist AQUESTA Bank in a number of ways; for example, in fulfilling your service requests, or processing your transactions, or mailing your account statements. AQUESTA Bank may also share your information with companies we have hired to provide marketing and other services on our behalf, or with other financial institutions with whom we have cooperative marketing agreements. All of these companies are contractually obligated to keep the information that AQUESTA Bank provides to them confidential, and use the information only for the purposes of providing the services AQUESTA Bank asked them to perform for us or for you.

Credit bureau reporting:

In accordance with the Fair Credit Reporting Act (FCRA), and with industry standard banking practices, AQUESTA Bank routinely provides customer data/information to these agencies or other creditors.

E-mail:

AQUESTA Bank will use your e-mail address to provide you with information that is helpful for you to do business with AQUESTA Bank. These emails will only be sent to you if you are eligible or request these services from AQUESTA Bank. You may add or delete e-mail services from your account at any time. In addition, e-mail addresses retained by AQUESTA Bank may be used by us or shared with our affiliates, non-affiliates, service providers, third parties and representatives to provide you with information regarding products and services or other opportunities that may be of interest to you. AQUESTA Bank will not trade, rent or sell customers e-mail lists to non-financial industry related e-mail marketers.

Courts and/or government bodies:

Certain federal and/or state laws may require AQUESTA Bank to share information about you. For example, if you are involved in a legal matter, AQUESTA Bank may be ordered to provide information to a court or other party. Such shared information may include a disclosure in connection with a subpoena or similar legal process, a fraud investigation, an audit or examination. In these circumstances, only the specific information required by law, subpoena, or court order will be shared.

Former Customers:

AQUESTA Bank may share information about former customers with AQUESTA Bank affiliates, non-affiliates, service providers, third parties and representatives to marketing partners and other third parties as described above. However, former customers can also elect not to have their information shared, even after their relationship with AQUESTA Bank ends by contacting AQUESTA Bank and requesting that their information not be shared.

Keeping up-to-date with AQUESTA Bank Privacy Policy:

AQUESTA Bank will provide notice of our privacy policy annually, as long as you maintain an account with us. AQUESTA Bank reserves the right to make changes to this policy at anytime, and without notice. You can always review AQUESTA Bank’s current privacy policy by contacting AQUESTA Bank for a copy at (704) 439-4343.

Customers’ privacy is as important to us in the Internet world as it is everywhere else within AQUESTA Bank. While this policy governs AQUESTA Bank’s data sharing activities, there may be cases where we need to treat your information differently than described here while doing business with you on the Internet. In these cases, we will provide you with a clear, plain-language disclosure and obtain your authorization before proceeding. The authorization may come in the form of clicking on a disclosure, replying to an e-mail or enrolling in specialized Internet banking services. While additional privacy concerns may appear with the Internet, AQUESTA Bank will always protect your privacy in a manner that is consistent with the principles outlined in this policy.

AQUESTA Bank Information Systems Security Group is specific responsibility for ensuring that we have thorough security standards to protect our systems and your information against unauthorized. This group keeps up-to-date with ever-evolving security issues, tools and methodologies and they are consulted with all areas of AQUESTA Bank to ensure that appropriate security controls are built into all of AQUESTA Bank systems and software. AQUESTA Bank associates who have access to your information are bound by a code of conduct that requires the confidential treatment of customer information. They are subject to disciplinary action for breaches of this code. In addition, AQUESTA Bank maintains physical, electronic, and procedural safeguards to protect customer information. We continually assess new technology for protecting information, and upgrade our information security systems whenever it's appropriate.

1. Email: Do not use ordinary e-mail to communicate personal or confidential information to us. Use the secure server available at your Local Site. Ordinary e-mail messages sent over the Internet may be intercepted, lost or altered. We are not responsible for them and will not be liable to you or anyone else for any damages in connection with any messages sent by you to us using ordinary e-mail.


2. Registration: When you register for our website, you are asked to provide personal information including your taxpayer identification number and a AQUESTA Bank account number to authenticate your identity. The information you provide is based on the types of accounts you have at AQUESTA Bank. Once you log on to see your account information, everything you see is secure.

3. Passwords: You choose your own user name and password during the registration process. You are the only person who knows your password, and you can change it at any time. In addition, you should never reveal your user name or password to anyone. Because it is linked to a password, a user name alone cannot be used to log on to our website. Your user name will be disabled after three unsuccessful password attempts, and you will then need to reregister for access to the secure areas of our website. If you forget your password, call AQUESTA Banks Web Technical Support Services at (704) 439-4343. Most users tend to select a password that is easily recallable so they will not forget it. Although this seems harmless, such passwords are inherently weak because they can be anticipated and easily guessed by an impostor. Someone trying to guess your password will try your name, date of birth, nickname and those of your spouse and children. Choose a string of alphabetic characters that is easy to remember using one of the following techniques. Type a common word, but shift your hands up or down one or two rows on the keyboard. For example shifting down one row on the keyboard changes "FRIDAY" to "VFKCH."· Create an acronym from an expression. For example, take the first letter of a common expression, such as "This fancy stuff works!" to form the acronym "TFSW."

4. Secure Sockets Layer (SSL): Our website uses one of the most secure forms of communication available. To access secure areas, your browser must allow 128-bit encryption and Secure Sockets Layer (SSL) version 2.0 protocol. These technologies provide the highest level of security and privacy when you access your account information, initiate online account transactions, or send secure messages. Specifically, a 128-bit encryption means there are 2128 possible key pairs or 288 (a three followed by 36 zeroes) times as many key combinations. That means a computer would require exponentially more processing power to find the correct key.

5. Firewalls: We have implemented a comprehensive security infrastructure to both control and monitor the environment. We also arrange for regular independent security reviews of our environment to both qualify and maintain compliance to set organizational requirements.

6. Timeouts: Secure areas of our website have built-in timers that terminate your access after extended periods of inactivity. You share responsibility for maintaining the security of your personal account information on AQUESTA Bank website. When you finish viewing your account information, you should log off from the site.

7. Web-Linking: Your use of hyperlinks on the Site is at your own risk. We provide hyperlinks to other locations on the Internet for information and convenience purposes only. No endorsement of third party websites or content is implied. We are not responsible for the content of any other websites or pages linked to or from the Site or any Local Site. We have not verified the content of any such websites, or pages. It is recommended that you view the linked website's terms or privacy policy pages to understand how use of that website may affect you. We are not responsible for the accuracy, timeliness or the continued availability or the existence of content, hyper links, or third party websites or pages linked to the Site or any Local Site. Links to downloadable software sites are for convenience only and we are not responsible or liable for any difficulties or consequences associated with downloading the software. Use of any downloaded software is governed by the terms of the license agreement, if any, which accompanies or is provided with the software. The Site may offer access to news services, market analysis, financial planning tools or other information provided by third parties on the Site or any Local Site. No endorsement or approval of any third parties or their advice, opinions, information, products or services is expressed or implied by any information on the Site or any Local Site. We do not control, cannot guarantee, and are not responsible for the accuracy, timeliness or even the continued availability or existence of such content.

8. Trade Marks & Copyright:
Copyright in the pages, screens, information, and all material in their arrangement, included in the Site or any Local Site is owned by or licensed to us or the AQUESTA Bank unless otherwise noted. You may imprint, copy download or temporarily store extracts from the Site or any Local Site for your personal information or when you use any products and services of any Local Site. You may not alter or otherwise make any changes to any material that you print or download from the Site or any Local Site, including, without limitation, removing any identifying marks or legends from such material. You may not distribute these materials to others. Any other use is prohibited unless you first request and obtain our written permission. In particular no one may use a part of the Site or any Local Site on any other website, or link any other website to the Site or any Local Site, without our prior written permission or the consent of the relevant AQUESTA Banks. Content from a third party provider available on or through the Site or any Local Site may not be duplicated, distributed, published, transferred, transmitted, copied, altered, sold, used to create derivative works or otherwise misused. You must comply with all terms disclosed to you as required from time to time by any third party supplier of data or services to the Site or any Local Site, including but not limited to, where necessary, entering into a direct agreement with such third party in respect of your use of their data. You may not use the Site or any Local Site for any purpose which is unlawful, abusive, libelous, obscene or threatening.