VALLEY BANK
Revised: May 13, 2005

Valley Bank recognizes the responsibility to protect our clients’ private information. The success of our financial institution depends heavily on the level of trust and confidence with our clients. In continuing our commitment to provide quality service, Valley Bank adopts the following privacy principles.

Our Collection, Use and Retention of Client Information - Valley Bank collects and retains information about our clients only where we reasonably believe it would be useful in administering our business and providing products, services, and other opportunities to our clients. We collect and retain information only for specific business purposes. 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; and information we receive from a consumer reporting agency. We use this information to administer our clients’ accounts, to comply with certain laws and regulations, to help design or improve our products and services, and to understand our clients’ financial needs.

Our Maintenance of Accurate Information - Valley Bank has implemented procedures to help assure our clients’ financial information is accurate, current, and complete. While some procedures are required by federal or state law, we also have procedures for responding to requests to correct inaccurate information in a timely manner and to update information and remove old information.

Securities Procedures to Protect Information - Valley Bank maintains security standards and procedures to help prevent unauthorized access to confidential information about our clients. Technology is tested and updated to improve the protection of the bank’s information and to assure the integrity of the information.

Limited Access to Information - Valley Bank has procedures and security levels that limit employee access to personal information to those with a business reason to know such information. The importance of confidentiality and client privacy is addressed on an ongoing basis. Appropriate disciplinary measures will be taken to enforce employee privacy responsibilities.

Restrictions on the Disclosures of Account Information – We do not reveal specific information about our client's accounts or other personally identifiable data unless (1) our client has requested or authorized it; (2) the information is provided to help complete a transaction initiated by out client; (3) the information is provided to a credit bureau or similar information reporting agency; or (4) disclosure is lawfully permitted or required.

Maintaining Customer Privacy in Business Relationships with Outside Third Parties- At times it is necessary to provide personal information about our clients to a third party, such as a vendor or service company we hire to provide support or services for our products. These vendors and service companies agree to safeguard our confidential client information and must abide by applicable law. We will not sell personal information to a third party for the purpose of solicitation or provide such information to a third party for its own use.