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Privacy Policy  

Privacy & Non-disclosure Policy

It is our policy to protect the confidentiality of our customers and not disclose information about accountholders. We understand that persons and/or entities ("Accountholder") will furnish us with business and/or personal financial information ("confidential information") for the purpose of opening and maintaining their account. Such confidential information includes, but is not limited to, personal data, financial records, and account information. We understand that the confidential information provided by Accountholder is unique, valuable and highly confidential, and disclosure of the confidential information may might not be in the best interest of Accountholder.

We will not willfully disclose any part of the confidential information, except for the express purpose for which it was provided, without the consent of Accountholder. We will not use the confidential information for any purpose other than as set forth herein, and will not intentionally disclose any part of the confidential information to any third party, except to third parties who need such information for the purpose for which it was provided. In such cases, we will inform the recipient of the confidential nature of the information and will instruct to the extent possible such third parties to treat the confidential information in accordance with our policy.

We will advise Accountholder, except where prohibited by law, of any request or demand for confidential information by a third party. We will not produce any confidential information to a third party without the consent of Accountholder, except where necessary to comply with a valid court order. If we are served with a subpoena or demand for records or testimony, we shall advise Accountholder, except where prohibited by law, and provide Accountholder with the opportunity to contest any such subpoena or demand for its records if Accountholder so chooses. We will on a good faith basis abide by Accountholder's wishes with regard to taking legal measures to protect the confidentiality of Accountholder's records, providing Accountholder bears all legal expenses incurred in doing so. We assume no liability whatsoever for any breach of privacy, confidentiality or nondisclosure where a court of competent jurisdiction orders disclosure of account information or disbursement of funds from account or where compelled to do so by international anti-money laundering requirements.

This policy statement in no way constitutes a contract in itself or part of any existing contract and is subject to change without notice. However, we will on a best efforts basis seek to maintain continuity in our policies. If we do change this policy we will on a best efforts basis attempt to not institute such policies retroactively. Whether a policy change is enacted retroactively or proactively, on a best efforts basis we will attempt to give reasonable notice to accountholders of that policy change

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