Delta Bank PRIVACY POLICY SUMMARY

At Delta Bank, we are committed to protecting the privacy and security of our customers’ personal information and ensuring the accuracy of such information. The bank collects and maintains records about our customers to enable us to protect the security of customer’s accounts, conduct business consistent with federal banking laws, and satisfy legal requirements.

GENERAL OBJECTIVES

The general objectives of the Bank’s privacy policy are to establish internal controls and to assist in complying with the applicable regulations.

· Ensure the integrity and accuracy of personal information.

· Maintain confidentiality of information.

· Safeguard customer information

· Provide initial and annual privacy disclosures

· Conduct employee training

· Conduct ongoing compliance review to ensure adherence to the regulations

SAFEGUARDING AND SECURITY OF CUSTOMER INFORMATION

The Bank has established policies and procedures regarding the safeguarding of electronic information, physical security of bank assets, and personnel confidentiality and disciplinary policies procedures to ensure adherence compliance.

DEFINITIONS

Customers Defined:

· All consumer customers who have a continuing relationship with the Bank

· Deposit accounts

· Loan accounts

· Credit Card accounts

· Safe deposit accounts

INFORMATION COLLECTION PRACTICES

In regard to Delta Bank's (DNB) use of non‑public personal customer information, non‑public personal information is defined in applicable law and generally means financial information that is identified with the customer that is not obtainable from a public source. For example, an account balance is non‑public information. In contrast, the fact that a real estate loan exists is public information because a deed of trust is available from public government records. Non‑public information includes any list, description, or other grouping of customers that is created using non‑public information (whether or not the list also includes public information). For example, a list of loan customers that includes current loan balances would be non‑public. Non- public information does not include any list, description, or grouping that is created using only public information.

In the normal course of business, the Bank collects and maintains the following various types of information about customers:

Information we receive from customers on applications or other forms
Information about customers transactions with the bank
Information about customers transactions with nonaffiliated third parties
Information from a consumer reporting agency

The Bank obtains personal customer information primarily from the customer (for example when an account is opened or loan application submitted). The Bank may also obtain such information from other sources (for example, in conjunction with a loan application the Bank may obtain a credit report and ask for authorization to verify personal financial information). If the Bank is unable to obtain such information, the Bank may be prevented from providing a service and/or may be compelled to terminate an account or service the Bank currently provides. The Bank may also maintain personal customer information resulting from account and loan experience and transactions with the Bank.

COLLECTION OF INFORMATION

In the normal course of business, the Bank collects and maintains the following various types of information about customers:

(1) Identification information, such as account numbers, Social Security numbers, addresses and phone numbers

(2) Information regarding customers credit worthiness and credit capacity, such as customers assets, liabilities, employment, income and expenses that may be provided to the bank in a loan application

(3) Account activity information, such as loan or deposit balances and transaction histories.

USE OF PERSONAL INFORMATION

The Bank

The Bank may use customer personal information only for legitimate business purposes in a manner consistent with banking practices in compliance with applicable laws and regulations. The following summarizes the principal ways in which Delta Bank uses such information.

(1) To protect the security of an account. For example, the Bank may use customer personal information gathered in loan applications to insure that the loans are underwritten in a prudent manner consistent with the requirements of federal banking regulations.

(2) To satisfy legal requirements. For example, the Bank use Social Security numbers for federal income tax reporting purposes.

(3) To help the bank determine which products and services might meet the customers financial needs.

(4) To conduct activities expected in the normal course of business

WITHIN Delta Bank AND ITS AFFILIATED COMPANIES

Within DNB and its affiliates the uses of customer non‑public personal information:

(1) To protect the security of accounts. For example, the Bank uses customer personal information for identification purposes, to prevent unauthorized persons from accessing account information.

(2) To conduct business in a safe and sound manner. For example, the Bank uses information gathered in a loan application to ensure it is underwritten in a prudent manner consistent with the requirements of federal banking regulations.

(3) To satisfy legal requirements. For example, the Bank uses Social Security number for federal income tax reporting purposes.

WITH UNAFFILIATED THIRD PARTIES

Delta Bank and its affiliated company, Delta National Bancorp will sometimes disclose your personal information to companies or entities unaffiliated with Delta Bank only to the extent allowed by law as illustrated by the following circumstances:

1. Third Party Services

On a confidential basis, we may disclose your personal information to companies that provide services to Delta Bank, for example, check printers, credit reporting agencies, and ATM networks.

2. Joint Marketing or Private Label Credit Programs

On a confidential basis we may share your personal loan information with another bank or financial institution with which we maintain a participation relationship or a private label credit program, for example, the Delta Bank VISA credit card currently offered through arrangement with Independent Bankers Association with Equifax Card Services as the service provider.

3. Legal requirements

The bank is sometimes required to disclose personal information in order to comply with subpoenas, court orders, and legal reporting requirements, such as interest reporting to the Internal Revenue Service.

4. Credit Reporting Agencies

The bank may disclose information relating to the bank’s experience with a customers account to credit reporting agencies and similar organizations, such as Chex Systems.

5. Written Consent

The bank may disclose personal information with written consent, including a power of attorney or other authorization to act on a customer’s behalf.

6. Business Transfers

The Bank may disclose personal account information in connection with a proposed or actual transfer of accounts or line of business to another company.

The Bank may disclose customer’s personal information to protect accounts against fraud and unauthorized transactions, to resolve a customers dispute, and, as necessary to Delta Bank’s regulators, attorneys, accountants, and auditors.

In no event will the Bank share with an unaffiliated third party any account number or any access code to any account for any purpose other than as outlined in this policy without customer authorization.

LIMITATION ON USE OR DISCLOSURE OF CUSTOMER PERSONAL INFORMATION.

As described in the Policy, from time to time, Delta Bank will share customer personal information with affiliated and non-affiliated companies only in relation to transaction and experiences information, which the bank is authorized to do under the Fair Credit Reporting Act, or as otherwise allowed by law. For example, information about your payment history disclosed to a credit bureau, disclosures of personal information to another bank or financial institution with which we maintain a participation relationship or private label credit program (for example the Delta Bank Credit Card currently offered through an arrangement with IBAA and processed by Equifax Card Services), any specific disclosures which the customer consents to in writing, by fax (photocopy is Okay) or verbally.

SAFEGUARDING OF INFORMATION

PROTECTING PERSONAL CUSTOMER INFORMATION FROM UNAUTHORIZED ACCESS

Safeguarding customers personal information is important at Delta Bank. The Bank maintains policies, procedures and systems to protect personal information from being accessed by unauthorized persons. The Bank limits employee access to personal customer information to those with a legitimate business reason for such access. The Bank will retain customers’ personal information only as long as necessary to service the account, conform to safe and sound banking practices, or satisfy legal requirements. The Bank will train employees in the Bank’s privacy policies and procedures, and they are held accountable for adhering to them.

ACCURACY OF CUSTOMER INFORMATION

The Bank will maintain information about accounts as accurately as possible. The Bank will maintain internal controls to help ensure the accuracy of such information. If any such information is inaccurate or incomplete, the customer is to contact the bank and the bank will take appropriate action to correct or amend the records.

If a customer wishes to review information regarding their accounts, they may visit their local branch or call the Bank’s bookkeeping phone number or loan department. Depending on the research required to compile the requested information, the Bank may charge a fee for such services as described in the Account and Service Fees schedule given to customers when they opened their account. The bank will provide an estimate of such a fee. If the bank is unable to comply with the request (for example, because the information no longer exists or is impractical to retrieve), the bank will explain the reasons why.

If you have any questions please contact the Compliance Department at Delta Bank (209) 824-4030 or write 611 N. Main Street, Manteca, CA 95336