Privacy and Security Statement

This privacy statement describes the privacy policy and practices of Commercial Bank of Texas, N.A.(CBTx). Click here to view our latest Privacy Notice.  In the normal course of business CBTx receives information from and about its customers that is necessary to meet our customers' needs and expectations for superior financial products and services. This policy applies equally to customers of CBTx and consumers.

CBTx endeavors to protect the privacy and the confidentiality of customer information, including nonpublic personal information.

Recognition of a customers' expectation of privacy.

Commercial Bank of Texas, N.A. recognizes our current and former customers' right of privacy and the importance of safeguarding nonpublic personal information ("Private Information"). Private Information is vital to our ability to provide customers with quality service. We collect, use and retain Private Information regarding our customers and former customers for purposes we believe beneficial in developing and providing services and products, or to meet the requirements of law. We think it is important for you to be informed of the policies we have in place to safeguard your privacy:

We do not sell customer information.

We collect Private Information about you from the following sources:

• Information we receive from applications or when you visit us in person, over the phone, through our website or correspond with us by mail;
• Information we receive from your Internet browser when you visit our website;
• Information about your transactions with us, our affiliates, or others;
• Information we receive from consumer-reporting agencies and other non-affiliated third parties.

We may disclose the Private Information we collect on customers and former customers, as described above, to:

• Companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements;
• Companies that perform services on our behalf that have contractually agreed use the information only for its intended purpose and to keep such information confidential; and
• Other non-affiliated third parties as permitted by law.

Restriction on the disclosure of Private Information to parties other than Commercial Bank of Texas, N.A. or its affiliated companies:

Except as authorized by law, CBTx will not disclose or share customer information, including Private Information, to any other organization or third party that is not an affiliate of CBTx, unless we have previously informed the customer in disclosure agreements, have been authorized by the customer to release information, or are authorized or required by the law to release the information.

Maintaining customer privacy in business relationships with other companies:

From time to time, CBTx may contract with outside vendors and other businesses to perform specific services in support of the Bank's products. An example of this is the printing of customer checks. We will ask that the vendors and other businesses adhere to strict privacy guidelines that provide for keeping such information confidential.

Maintenance of accurate customer information:

CBTx has procedures in place designed to maintain the accuracy of customer information and to respond timely to requests regarding inaccurate information. Inaccurate information should be reported to CBTx Customer Service immediately (800) 723-7601, 936-715-4100, or e-mail us at support@cbtx.com. Should CBTx become aware of any inaccuracies in our records, we will take prompt steps to make the appropriate corrections.

Employees access to information and use of customer information.

Generally, CBTx policies and procedures restrict employee access to customer information to those employees to have a business reason to know. CBTx employees are trained in procedures designed to protect and maintain the confidentiality of customer information.

Internet Privacy Policy

When you visit our website to view pages, read product information, or use our online calculators and tools, you may do so without telling us who you are and without revealing any personal information. CBTx may use software to collect non-identifying information for the purpose of tracking activity on our site. This allows us to better understand how many people use our site and which pages and features are most popular. The information we normally collect and store is:

• Date and time the web site was accessed.
• Your Internet protocol (IP) address or the proxy address of your Internet service provider. (For example, AOL, CompuServe, etc.)
• The name and IP address of the CBTx server that received and logged the request
• The resource on the CBTx server accessed as a result of the request, such as the WebPages, image, etc.
• The name and version of your web browser (For example, Microsoft Internet Explorer 5.0).
• The content of any sent or received cookie.
• The uniform resource locator (URL) that was accessed before the user made a request for CBTx's web server. The URL may be an outside address that is not related to the CBTx server.
• Other status codes and values resulting from the web server responding to the request received: such as; http status code, windows NT code, number of bites sent, number of bites received, duration (in seconds) to fulfill the request, server port number addressed, and protocol version.

CBTx uses this information to create summary statistics and to determine the level of interest in information available on our site. Some areas of our web site may use "cookies" temporarily stored in your computer memory, (RAM), to allow the web server to log the pages used within the site and to determine if you have visited the site before. The CBTx web server uses this information to provide certain features during your visit to our web site. You can set their browsers to warn when placement of a cookie is requested, and to decide whether or not to accept it. Some of the features normally available on our site may not function properly if a cookie is not accepted.

CBTx uses the information we collect for internal administrative purposes, to measure the volume of requests for specific web site pages, to assist in maintaining web site security, and to continually improve the CBTx Internet site so that it is responsive to the needs of the users. Your choice to use the CBTx web site or to send electronic mail to CBTx will be considered the consent of the user for CBTx to use the information collected.

CBTx may share non-experience information about consumers with CBTx's affiliates, usually for marketing or cross selling purposes. "Non-experience information" includes information beyond specific transactions or experience the bank has had with the consumer, such as information furnished on applications for a loans, deposit or investment accounts, or information obtained from a credit report. If you prefer CBTx not share such information with our affiliates, you may opt out of such disclosures by calling us toll free at (800) 723-7601, attention Customer Service. Your choice will apply to any joint account holders.

Our website is not targeted or marketed to children.

Protection of information via established security procedures:

CBTx maintains physical, electronic and procedural safeguards designed to prevent unauthorized access to confidential information about your accounts, loans, and other business.

CBTx uses a combination of security technologies to protect customer's data from unauthorized access on our website. Technologies include a password-controlled system entry, a VeriSign issued Digital ID loaded onto the CBTx internet server, a Secure Sockets Layer (SSL) protocol for data encryption, and a router loaded with a firewall to regulate the inflow and outflow of data from the CBTx web server.

To begin the communication with the CBTx web server, the user must key in his/her login ID and a password. The CBTx Internet banking system uses a "lockout" mechanism to deter users from repeated login attempts. After three unsuccessful login attempts, the system locks the user out, requiring either a designated waiting period or a phone call to CBTx customer service to verify the password before reentry into the system. After a successful login, VeriSign's Digital ID authenticates the user's identity and establishes a secure session with that visitor.

The Digital ID from VeriSign, a recognized leader in Digital Identification certificates, provides a standard of authentication to confirm the identity of the user prior to access to the CBTx internet banking system, CBTxchange. The CBTx web server is secured with a Digital ID to assure visitors of the authenticity of the site and allows the data exchanged with you to be encrypted. Essentially, it provides "third party evidence" that end users who are seeking and receiving data are indeed who the server understands them to be, and vice-versa.

Once the server connection is established, the user and the CBTx server communicate in a secured environment. Because the CBTx server is a 128-bit secure server, data exchanged between you and the CBTx server is encrypted with Secure Sockets Layer (SSL) protocol and, therefore, data can only be decrypted with the public and private key pair. The CBTx server issues a public key to your browser and creates a temporary private key. These two keys are the only combination possible for that session. When the session is complete, the private keys expire, and the whole process starts over when a new user begins a session with the CBTx server. The encryption and decryption happens in the background and therefore requires no special knowledge.

Customer requests for data are filtered through a router and firewall before they are permitted to reach the CBTx server. The router, a piece of hardware, works in conjunction with the firewall, a piece of software, to block and direct traffic coming to the CBTx server. Generally, the configuration of the hardware and software initially disallow all traffic attempting to reach the CBTx server and then opens access only when necessary to process an acceptable data request, such as retrieving web pages or sending a customer request to CBTx.

The router and the CBTx server are physically located in a restricted area at a CBTx Branch. Only authorized personnel may enter this area. CBTx periodically evaluates its security architecture and may make changes to security systems and architecture without prior notice to insure that it provides a high level of privacy and safety for both the Bank and the customers of the Bank. CBTx endeavors to make sure that the user's online experience is safe and secure. While CBTx believes that we have taken the necessary steps to put in place a sound and reliable security infrastructure; the users also play an important role in protecting their accounts and personal information. CBTx recommends the following safeguards to keep your personal information safe and secure:

• After the enrollment process, we will assign you a user identification (your login ID) and a temporary password. The first time you login, you will be prompted to change the password. Once you have changed the temporary password, only you will know your password. Your online password is designed to protect the privacy of your banking information, but it will only work if you keep it to yourself. Do not write it down and never discuss it with anyone. It is a good practice to change your password regularly. The internet banking system will prompt you to change your password every 60 days. If you think your online password has been compromised, change it immediately online.
• Don't walk away from your computer and leave it unattended if you are in the middle of a session. In order to provide the best performance for you when using our web site, we do not send a "no cache" command to browsers, which means the "back button" on your browser will work. CBTx will automatically drop your connection and sign you off after ten minutes of no activity, but if you leave your computer signed on, someone else could step in and push the "back" key and view account information.
• Once you have finished conducting your banking using CBTxchange, always sign off before visiting other Internet sites.
• If anyone else is likely to use your computer, always clear your cache or turn off and re-initiate in order to eliminate copies of web pages that have been stored on your hard drive. How you clear your cache will depend on the browser and version you use. You should follow your browser instructions to "clear cache", which are generally found in your preference menu.
• Maximize the security of your browser. CBTx strongly recommends that you use a browser with 128-bit encryption to conduct secure financial transactions over the Internet. Review the security options on your browser.
• Use virus protection software. Always insure that your computer is clear and free from computer viruses.

Although information is an important requirement of our ability to provide superior service to you, CBTx recognizes our customer's trust is one of our most important assets. CBTx's privacy policy applies to individuals and we may make changes to this statement at any time upon notice as required by law.

CBTx may share information about a business and the business' relationship with us in accordance with the code of ethics and statement of principals established by the Robert Morris.