Your privacy is important to us. As a provider of correspondent bank products and services that serve financial institutions, Pacific Coast Bankers’ Bancshares and its affiliates (“PCBB”) recognize their responsibility for safeguarding our customers (who are community financial institutions) and their customers’ privacy as you interact with us online, including your use of our website located at www.pcbb.com. This notice covers many online services, including all of our websites, portals, applications, mobile apps, and social media sites or pages, as well as any interactions you may have while viewing content provided through one of our digital advertising campaigns.

As you review this Online Privacy Notice, here are a few general principles to keep in mind:

• Our online services are intended for a U.S. audience of financial institutions and not consumers. If you visit or use one of our online services, your information may be transferred or processed in the United States of America.
• Our website is not intended to solicit, collect or process personal information from any individual under the age of 16.

We use this privacy notice to clearly disclose to you our privacy practices in a manner that is easy to understand. If there is something you do not understand about our privacy practices, please feel free to contact us using the contact information listed at the end of this privacy notice.

If you are a California Resident, you have rights under the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA). However, the CCPA includes an exception for personal information covered by the Gramm-Leach-Bliley Act (GLBA), which governs financial institutions sharing and protecting of customers’ non-public personal information.

We may change this notice from time to time, so please check back often. Please keep in mind that some of the services mentioned specifically in this notice may not be available on the website at this time.

Online Collection and Use of Personal Information

When you visit or use our online services, we may collect personal information directly or indirectly from or about you such as your name, email address, postal address, telephone number(s), account numbers, location information, username and password or other unique identifiers. We may also collect other unique identifiers where we believe it is reasonably necessary for ordinary business purposes.

How do we use your information?

Our main goal in collecting information is to improve the site and provide you with the best possible experience on the website. For example, by using the information we collect, we can provide you and your institution with an easy to use and readily available forum to learn about PCBB financial services. We do not collect your data to sell to other parties. It is solely for the purposes of supporting our ongoing operations for our customers, research and analytical purposes, as well as marketing to you and your institution about enhancements or new solutions that might benefit your institution.

1. Support our everyday operations, including to meet risk, legal, and compliance requirements
1. Respond to your inquiries.
2. Perform accounting, monitoring, and reporting.
3. Enable information security and anti-fraud operations, verify your identity, as well as credit, underwriting, and due diligence.
4. Support audit and investigations, legal requests and demands, as well as exercise and defend legal claims.
5. Enable the use of service providers for business purposes.
6. Manage our business relationships.
7. Comply with policies, procedures, and contractual obligations.
8. For compliance, fraud prevention, and safety purposes, including protecting the security of account and personal information.
9. Defend or protect us, you, our client, or third parties, from harm or in legal proceedings.
10. Respond to court orders, lawsuits, subpoenas, and government requests.
11. Provide and manage products and services, as well as improve our products and services.

2. Research and Analytical Purposes
1. Understand how you use our websites, mobile applications, and other digital properties (collectively, the “Sites”).
2. The methods and devices you use to access our websites/portals/applications, in order to make improvements to our sites.
3. Conduct research and analysis, identify usage trends, determine effectiveness of promotional campaigns, and to drive product and services innovation.
4. Notify you of products or services available from PCBB and our affiliates.
5. Compile, analyze and do research on our users' demographics and behavior.
6. Detect, investigate and prevent activities that may violate our policies or be illegal.

3. Marketing and Advertising Purposes.
1. Personalize online content so that is applies to you and your institution’s interests.
2. Send you marketing and advertising communications about our products and services, tailored to your interests or more general in nature.
3. Collect information through our social media pages and other online interactions with you to assist in verifying your identity and account status. We may combine this online information with information collected from offline sources or information we already have.

Examples of information we collect

Some of the information we collect is personal to you or your institution, while other information is anonymous. Here are a few examples of information we might collect when you are on our website:

• When you report a problem with our website or services, we will collect contact information along with a description of your problem.
• When you contact us via the Contact Us page or subscribe to one of our newsletters, we ask for your name, title, phone number, email address, and information about your institution.
• When you contact us via the company email address, we will collect your contact information and any information you include in your email.
• When you visit and navigate our site, use our applications or third-party sites, or open our emails, we may collect technical information about your use of our site including IP address, device identifier, and viewing information.

With whom do we share your information?

We will not disclose any of your personally identifiable information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described below. These are some of the ways that your information may be disclosed:

• Service Providers. We occasionally work with other companies to provide limited services on our behalf, including packaging, delivering, or mailing, website development and operation, sending postal mail or email, analyzing website use, processing payments, providing investor information and processing data. We will only provide those companies the information they need to deliver the service, and they are contractually prohibited from using that information for any other reason.
• Data in the Aggregate. We may disclose “blinded” aggregated data and user statistics to prospective partners and other third parties. Blinded data is data that does not identify an individual person.
• Other. We also may disclose your information in special cases. For example, when we believe that we must disclose information to identify, contact or bring legal action against someone who may be violating our Terms of Use, or may be causing injury to or interference with our rights or property, other website users or customers and their information, or anyone else.
  PCBB and our service providers may disclose, access or monitor your personal information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service and improve our products and services and our information security. This includes third party partners and service providers we use to enable the detection of devices connected with fraud and other types of information security vulnerabilities, to prevent fraud, security threats and illegal or malicious behavior, and to enhance security on our website and other pages on the internet.

Understanding Cookies, Web Beacons and Other Tracking Technologies

PCBB, our services providers, and third parties engaged on our behalf may use cookies, pixel tags, or similar tracking technologies to gather personal information when you use, access, or otherwise interact with our websites, mobile applications, or other digital properties.

While we do not disclose your personal information in exchange for money, our use of these collection technologies may be considered a “Sale” or “Sharing” under California Law. California residents have the right to opt out of such selling/sharing activity. We may use the information for business purposes such as fraud prevention and monitoring our advertising and marketing campaign performance.

“Cookies” are small amounts of data a website can send to a visitor’s web browser. They are often stored on the device you are using to help track your areas of interest. Cookies may also enable us or our service providers and other companies we work with to relate your use of our online services over time to customize your experience. Most web browsers allow you to adjust your browser settings to decline or delete cookies but doing so may degrade your experience with our online services.

Clear GIFs, pixel tags or web beacons—which are typically one-pixel, transparent images located on a webpage or in an email or other message—or similar technologies may be used on our sites and in some of our digital communications (such as email or other marketing messages). They may also be used when you are served advertisements, or you otherwise interact with advertisements outside of our online services. These are principally used to help recognize users, assess traffic patterns, and measure site or campaign engagement.

Your Privacy Rights in California and other States

PCBB is a provider of correspondent bank products and services that solely serve financial institutions, and does not directly work with consumers. Yet we recognize consumers in various states have specific rights and we strive to protect those privacy rights.

If you are a California Resident, you have rights under the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA).

California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to or write us using the contact information at the bottom of this Privacy Notice. Make sure to state that you are a California Resident.

If you are a Virginia Resident, you have rights under the Virginia Consumer Data Protection Act.

Nevada law (SB 220), permits customers in Nevada to opt-out of the sale of certain kinds of personal information. A sale under Nevada law is the transfer of this personal information to third parties for monetary consideration so these third parties can then re-sell or license the sold information. We do not sell your personal information to third parties as defined in Nevada law.

In the future, you may have rights under the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and other state privacy laws that become effective. As of the data of this Privacy Notice, these laws contain exceptions for both GLBA covered data and B2B data. Please check back for updates as we may update this Privacy Notice to address these laws and any changes in these laws. When these new laws become effective, we will adhere to the privacy rights below to the extent they apply to the specific law.

Some of these state laws do not apply to personal information collected in the business to business context (B2B). We will not process privacy rights requests when these exceptions apply.

Various state privacy laws including the CCPA require us to provide you with more detailed descriptions of the personal information we collect. The personal information we may have collected depends on our relationship to you. We may have collected your personal information in the preceding 12 months. The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”)). Below is a chart that details our collection practices.

Categories of Personal Information of You or Your Customer	Representative Data Elements		Does PCBB Collect?
Identifiers		Real name	Yes
		Postal address
		Unique identifier or unique personal identifier
		Telephone number
		Email address
		Driver’s license number
		Passport number
		Social security number	No
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code§ 1798.80(e))		Name	Yes
		Signature	No
		Physical characteristics or description
		State or government issued identification card number
		Insurance policy number
		Employment information and history
		Bank account number
		Credit or debit card number
		Other financial information
		Medical Information
		Health insurance information
Protected classification characteristics under California or federal law		Date of birth/age	No
		Gender
		Military or veteran status
		Marital status
		Race
		Ethnicity or national origin
		Religion
		Disability
Commercial information		Records of personal property	No
		Products or services purchased, obtained, or considered
		Other purchasing or consuming histories or tendencies
Biometric information		Fingerprints	No
		Faceprints or face imagery
		Voiceprints and/or voice recordings that can be extracted
Internet or another similar network activity		Browsing history	Yes
		Search history
		Information regarding interaction with a website, application, or advertisement
Device information *Note: Some information included in this category may overlap with other categories.		Device identifier or identifying information, characteristics, or settings about the device you use to access our online services	Yes
		IP address
		Information in cookies, pixel tags or from collection technologies
		Mobile ad identifiers
		Mobile device information (with permission, such as location, contacts, camera)
Geolocation data		Physical location	Yes
		Movements	No
		Precise geolocation
Sensory data		Audio	No
		Visual
		Electronic
	Note: these data types are typically collected during phone and in-person for security and training purposes.
Professional / Employment Information		Current or past job history or performance evaluation	No
Non-public education information (per the Family Educational Rights and Privacy Act)		Education records, such as, enrollment, grades, transcripts, student schedules	No
		Student financial information, including tuition costs and reimbursement
Inferences drawn from other personal information		Inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics	No
	Note: Inferences are not performed based on any sensitive personal information collected
Sensitive Personal Information		Government identifiers (Social security, driver’s license, state identification card, or passport number)	Yes
		Complete account access credentials (usernames, account numbers or card numbers, combined with any security or access code, password, or credential required for allowing access to an account)
	Note: Some information included in this category may overlap with other categories.
		Precise geolocation	No
		Racial or ethnic origin, Religious or philosophical beliefs, or Union Membership
		Biometric information when used for the purpose of uniquely identifying a consumer
		Personal information collected and analyzed concerning a consumer’s health

Exercising Your Rights

Right to Request Deletion. You have the right to request that your personal information be deleted, assuming it is not required for normal business operations or exempted by the Gramm-Leach-Bliley Act (GLBA). We may save personal information when permitted by applicable law including, without limitation, when the information is needed to complete a transaction, to detect or protect against security incidents or illegal activity, and for a legal or compliance purpose.

If we delete your personal information, you will lose a personalized experience with our site and content might not be as relevant to you. If you have an account with us, it will be deleted and you will no longer be able to access it. You also will lose your account and purchase history. Please see the Submit a Request section below to submit a request to delete.

How to Submit a Request Regarding Your Privacy Rights?

Only you or a person authorized to act on your behalf may make a valid request related to your personal information, your institution’s information, or your customers’ information. . To exercise your rights to access, deletion, and correction, please submit a verifiable request to us by either:

• Email: privacy@pcbb.com
• Mail:
  PCBB
  Attention: Privacy
  1676 North California Blvd., Suite 300
  Walnut Creek, CA 94596

When you submit a request, you must provide:

1. Your first and last name
2. Email address
3. Phone number
4. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
5. Describe your request with enough detail that allows us to properly understand, evaluate, and respond to it, and
6. Any comments you want to share

Once a request to access, delete, or correct has been submitted, we will attempt to verify that you are the customer the request applies to and that you have the authority to ask for the information in cases where it involves your institution’s customers. We do that by taking the identifying information you provide (e.g., name, email address, account-related information) and using a combination of the information we have on file. If we are unable to verify your request with the materials you provided, we may reach out to you for additional information.

If you need further assistance, please send an e-mail with your questions or comments to privacy@pcbb.com.