Privacy Policy

Introduction

International Bank of Commerce/Commerce Bank (the"Bank") clearly understands your concerns regarding information collected in today's technological environment. This Privacy Notice is designed to assure all customers/consumers with whom we deal of our commitment to strict standards of security and confidentiality. Additionally, this Privacy Notice will inform you of the types of information we collect, how it is used, and with whom and under what circumstances it is shared.

Your Privacy is Important to Us

We recognize the importance of confidentiality and trust when handling your private and financial information. We also recognize the right to privacy and of the privacy of your personal information. We count each of these issues among our most important responsibilities. We believe you may appreciate receiving offerings of products and services that maybe useful to you. At the same time, we understand the need to safeguard information that you have provided to us and that you expect privacy and security for your personal and financial affairs.

Information Collection

The Bank will collect information about you only where we reasonably believe the information will be necessary or useful in processing or administrating the products and services you have requested from us. Additionally, in compliance with the USAPATRIOT Act Rules, the Bank collects information necessary to verify a customer's identity. We collect nonpublic personal information about you from the following sources:- Information we receive from you on applications, surveys, on-line registrations, or other forms,- Information about your transactions with us and our affiliates, - Information we receive from consumer-reporting and debit-reporting agencies, providers of marketing and demographic information, and other non-affiliated financial institutions, including information regarding your creditworthiness, check history, and credit history, and-Information we obtain in connection with our efforts to protect against fraudulent and/or improper activity. This information will be referred to as "customer information".

Information Sharing Within Our Affiliated Family of Companies

As the Bank is a diversified financial services company, its company family group is made up of a number of bank and non-bank subsidiaries and affiliates. To provide you with the highest quality of service, inform you of product and service opportunities that may be of interest to you, and for other business purposes, we may disclose all of the customer information that we collect about you, as described above, to our parent company, International BancShares Incorporated, and its subsidiaries and affiliates to the extent permitted by applicable law.

Information Sharing With Third Party Service Providers and Joint Marketers

The Bank also may disclose all of the customer information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.

Your Opt Out Rights

Information held by any Bank affiliate or subsidiary is available to all other Bank affiliates or subsidiaries unless otherwise specifically instructed ,in writing, by you, by using the opt out "card" included with this notice. We are permitted by law to disclose nonpublic personal information about our transactions or experiences with you to Bank affiliates. We may also disclose other nonpublic personal information to our affiliates (that is, nonpublic personal information beyond our transactions and experiences with you), unless you tell us not to disclose this other nonpublic personal information. If you choose to opt out of the sharing of nonpublic personal information with companies and organizations outside the Bank family group, we will not share nonpublic personal information about you for accounts, loans or other consumer related transactions that you may have with us. For any accounts, loans or other consumer related transactions that you hold jointly with another person, your opt-out shall be effective as to all information regarding that account, loan and/or other consumer related transaction. We share information with our affiliates in order to provide you a broad range of the highest quality services. We share only the information that is appropriate and necessary under the circumstances. If you opt out, you may not receive an opportunity for services, which could be of great value to you.

Information Sharing Permitted By Law

In addition to the third party service providers mentioned above, we also may share customer information with certain nonaffiliated third parties as permitted by law.

Our Former Customers

After you are no longer a customer of the Bank, we will continue to treat the customer information we collected about you as if you were still our customer.

Confidentiality and Security

We restrict access to nonpublic personal information about you to those Bank employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards and security measures that comply with federal regulations to guard your nonpublic personal information. The Bank requires each third-party service provider to execute a Confidentiality Agreement and to organize and implement a privacy-training program for its employees. The Bank's Board of Directors has adopted a Privacy Policy. The Bank has a privacy-training program for its employees in order to ensure compliance with its Privacy Policy. For questions or comments please contact your account officer or any customer service representative.