Your privacy is just as important to us as it is to you. The following are our customer privacy guidelines:

1.       We will not sell or trade our customer data to outside entities.

 2.       We collect non-public personal information about our customers from the following sources:

                •   Applications and other forms

                •   Customer transactions with us, our affiliates, or others

3.       We do not disclose any non-public personal information about our customers or former customers to anyone, except as permitted by law. We reserve the right to disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, to perform necessary credit checks or collect or report debts owed to us, to protect our rights or property, or to otherwise process or service your account or a transaction made at your request.

 4.       We only collect the customer information we need. We limit the collection of information about our customers to what we need to know to provide customer services, to offer new products and services, and to fulfill legal and regulatory requirements.

 5.       We protect the confidentiality of all personal data. We restrict access to customers' non-public personal information to those employees who need to know that information in order to provide products or services to our customers. We maintain physical, electronic and procedural safeguards to protect our customers' non-public personal information.

 6.       Sharing information with our affiliates. We may share information described above with our affiliates for business purposes, such as servicing customer accounts and informing customers about new products and services, as permitted by applicable law. Our affiliates are companies controlled or owned by us.

 7.       Opt-out policy.  Customers may opt-out of the disclosure of non-public personal information to a non-affiliated third party by giving us notice in writing, by e-mail or by calling 415.995.2000, x20.

 8.       Anti-money laundering procedures. To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify and record information that identifies each person or entity to which we provide services.  When our customers engage our services, we will ask for information that will allow us to confirm the identity of our customers.  We may also ask for company formation and other relevant documents.

 9.       Changes to our privacy statement. This privacy statement may be updated from time to time.  This privacy statement was last updated on January 1, 2016.