Privacy Policy and Disclosure

The National Bank of Georgia has a commitment to protecting your privacy, because we understand how important personal privacy is to you. To express that commitment, we have adopted the following privacy principles, which reflect our intent to provide you with the best service available to you.

The directors, management, and staff of The National Bank of Georgia are concerned about and respect the privacy of customers'/consumers' personal financial information. We understood that our customers furnish sensitive information to the bank in the course of daily business, and the bank is committed to treating such information responsibly. We know that our customers expect privacy and security for their personal and financial affairs.

The bank will take all the necessary steps to safeguard sensitive information that has been entrusted to us by our customers. The following privacy policy and disclosure outlines our bank's practice regarding personally identifiable financial information for consumers and those consumers who become our customers.

TYPES OF INFORMATION THE BANK COLLECTS

We collect, retain, and use information about you only when we have a reasonable belief that such information will help us administer our business or provide products, services, and other opportunities to you. Information about you is collected and retained only for specific business purposes. We use information to protect and administer your records, accounts, and funds; to comply with certain state and federal laws and regulations; to help us develop or improve our products and services; and to understand your financial needs and provide you with quality products and service.

At The National Bank of Georgia we collect nonpublic, personal information about you from many sources, including the following:

• Information we receive from you on applications or other forms
  
• Information about your transactions with us, our affiliates, or others
  
• Information we receive from a consumer reporting agency

Nonpublic, personal information does not include that which is available from government records, widely distributed media, or government-mandated disclosures.

TYPES OF INFORMATION THE BANK DISCLOSES

The bank does not now, nor does it intend in the future, to disclose any personal financial information to any nonaffiliated or affiliated third party, except as permitted. By law the bank may disclose certain personally identifiable information without allowing consumers the right to opt out of the bank's sharing agreements in the following circumstances:

• To companies who perform transaction processing for the bank in the following circumstances:
  
  *If the transaction, service, or product is requested or authorized by the consumer
  
  *To maintain or service a consumer's account as part of a private label credit card or other loan extension program
  
  * In connection with a securitization, secondary market sale (including servicing rights), or similar transaction related to a consumer
  
• To disclose information necessary to enforce the bank's legal or contractual rights or the rights of any other person who is engaged in the financial transaction.
  
• To disclose information required in the ordinary course of banking business, such as the settlement of claims or benefits, the confirmation of information to the consumer or the consumer's agent, and the billing, processing, or clearing of items in the normal course of business.
  
• To provide information to insurance rate advisory organizations, guaranty funds or agencies, agencies that are rating the bank, persons who are assessing the bank's compliance with industry standards, and the bank's attorneys, accountants, and auditors.
  
• To the extent permissible under the Right to Financial Privacy Act
  
• To a consumer reporting agency under the Fair Credit Reporting Act
  
• To comply with federal, state, or local laws, rules, and other applicable legal requirements
  

MAINTENANCE OF ACCURATE INFORMATION

We have procedures to assist us in assuring that your financial information is current, complete, and accurate in accordance with established standards. We also have procedures in place to help us respond to your requests to correct inaccurate information in a prompt fashion. State and federal law mandate many of these procedures; however, we have implemented additional procedures to maintain current, complete, and accurate financial information, including procedures to update information and to remove stale information.

SAFEGUARDING CUSTOMER INFORMATION

At The National Bank of Georgia we protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. The bank has appointed a financial privacy coordinator, Michael R. Carson, who is responsible for maintaining internal procedures to ensure that our customers' information is protected. For example, information in loan files can only be accessed by employees who work in the loan origination or loan operations departments.

We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

All employees have a copy of this policy and are trained at least annually regarding the importance of safeguarding customer information. The financial privacy coordinator, the human resources director, and the appropriate department manager will take disciplinary action against any employee who violates the bank's privacy policy and procedures.

If we change our policy or practice by, for example, adding a category of information that we will disclose to a third party, we will notify existing customers and give them an appropriate time period to opt out of the disclosure.

The board of directors approved and adopted this policy on May 17, 2004.