Fidelity Bank is committed to protecting the privacy of its customers’ information. As part of our commitment to protecting our customers’ privacy, we have adopted the following privacy principles and have implemented them at all levels of our organization.

Recognition of a Customer’s Expectation of Privacy
We understand that our customers expect their personal and financial affairs to be held in the strictest confidence. As a customer of Fidelity Bank, you have entrusted us to protect your privacy and to safeguard your personal information. We take this responsibility seriously and have designed policies and procedures to prevent misuse of this information.

Privacy Principles

The Information That We Collect
Nonpublic personal information is information about you that we obtain in connection with providing a financial product or service to you. For example, nonpublic information includes account balances, payment history, and overdraft history. It does not include information that is available from public sources such as telephone directories or government records. We collect nonpublic personal information from the following sources:

     • Information we receive from you on applications or other forms
     • Information about your transactions with us
     • Information about your transactions with nonaffiliated third
       parties
     • Information from a consumer reporting agency

Use, Collection and Retention of Customer Information
We collect, retain and use information about you only where it is allowed by law and we reasonably believe it is useful in administering the bank’s business, and in providing products, services and other opportunities to you. We do not currently sell data. Additionally, we do not have any future plans to change our policy on selling data. In the event that we begin to sell customer data, you will be notified and presented with the opportunity to “opt out” whereupon your personal data will not be sold.

Maintenance of Accurate Information
We have established procedures to ensure that your financial information is accurate, current and complete in accordance with reasonable commercial standards. We will respond in a timely manner to written customer requests to correct inaccurate information. If you discover any information we have about you that is incorrect, please let us know.

Limiting Employee Access to Information
We restrict access to nonpublic personal information about you to those employees who need to know that information 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.

Security Procedures Protect Your Information
We establish and maintain security procedures designed to help prevent unauthorized access to your private, confidential information. We also update and test our computers, hardware, software, and other technology to assure the integrity and security of our information systems.

Restrictions on the Disclosure of Account Information
Fidelity Bank does not reveal specific information about you or your transactions to unaffiliated third parties for their independent use, unless the information is provided

     • to help complete a customer-initiated transaction,
     • to help administer the bank’s bona fide business,
     • at the customer’s request,
     • to comply with a legal requirement (i.e. subpoena),
     • to a reputable information reporting agency (i.e. credit bureau) or
     • after you have been informed about the possibility of
       such disclosure through prior communication and are given
       the opportunity to decline (i.e. “opt out”).

Maintaining Customer Privacy in Business Relationships with Third Parties
Whenever we provide specifically identifiable customer information to a third party, we insist that the third party adhere to similar Privacy Principles that provide for keeping such information confidential.

Delivery of Privacy Notices
We will deliver a Privacy Notice to all new bank customers and at least annually thereafter. In addition, if our privacy policy and procedures are going to change, we will promptly deliver a revised Privacy Notice to our customers that accurately describes the revised policy and procedures.

Special Information Applicable to Electronic (Internet) Banking
Our Privacy Principles will apply to your confidential and private information with regard to both traditional and non-traditional (i.e. Internet) banking activities. However, due to the unique nature of the Internet and the ease with which information can be exchanged, we feel it is important for you to be aware of the unique issues surrounding Internet Banking.

To better serve legitimate Internet Banking customers:

     • We collect generic information about visitors to our website.        This information includes the date and time of access,
       the Internet service provider’s address, the web browser
       used, and the visitor’s physical location.
     • We require you to utilize specific passwords for access to
       confidential and private information. We will remind you of your
       responsibility to safeguard login ID and passwords. In addition,
       commercial customers should carefully screen those
       employees to whom user ID and passwords are granted.
     • We utilize encryption, firewall, router, third party verification
       procedures and other security software and hardware to help
       prevent unauthorized eavesdropping of and access to your
       confidential and private information.
     • We utilize virus protection software to help prevent the spread
       of computer viruses.

Closed and Inactive Accounts
We will continue to adhere to our Privacy Principles for closed and inactive accounts.

Fidelity Bank is chartered under the laws of the State of Texas and by state law is subject to regulatory oversight by the Texas Department of Banking. Any consumer wishing to file a complaint against Fidelity Bank should contact the Texas Department of Banking through one of the means indicated below:

In Person or by U.S. Mail:
           Texas Department of Banking
           2601 North Lamar Boulevard, Suite 300
           Austin, Texas 78705-4294

           Telephone Number: (877) 276-5554
           Fax Number: (512) 475-1313
           E-mail: consumer.complaints@banking.state.tx.us
           Website: www.banking.state.tx.us