Privacy
is one of the most important services we provide our
customers. The safeguarding of your information is a
priority to us. This is true whether we are working
with networks, paper files or computers. We look for
ways to increase the security of your information that
you entrust with us. Commerce National Bank respects
the privacy of its customers and is committed to protecting
their information on our Web site. If you have any questions,
please contact us at the phone number listed in our
Web site.
This Customer Privacy
Policy only applies to individuals and families. It
does not apply to any other type of client; for example,
businesses or corporations.
Our Collection,
Retention, and Use of Customer (Consumer) Information
We collect, retain, and use information about customers
only where we reasonably believe that it will help administer
our business or provide products, services, and other
opportunities to them. We only collect non-identifying
information about visitors to our Web site such as:
(1) date and time the site was accessed, (2) what pages
were visited, (3) what servers were used, and (4) the
city of the visitor as identified by the server address.
We use information to protect and administer customer
records, accounts, and funds; to comply with certain
laws and regulations; to help us design or improve our
products and services; and to understand customers financial
needs so that we can provide them with quality products
and superior services.
This information is
used as appropriate by employees of the Bank to respond
to a request submitted through the Web site, and may
be used to send you information, offers or special promotions
concerning Bank products or services. This information
is not otherwise disseminated outside the Bank and is
never sold to organizations.
For a full description
of our privacy policies please see Commerce National
Bank Customer Privacy Principles.
We train and require
our employees to protect the privacy of information
about our customers regardless of the medium used to
fulfill customer financial needs. To protect the privacy
of our customers, we use appropriate security standards
and procedures to control access to customer information.
Email
Email is not a secure way of communicating. Please
do not send us any sensitive personal information via
email.
Technical Safeguards
Used for the Internet Banking System
The Internet Banking System brings together a combination
of industry-approved technologies to protect data for
the Bank and for you, our customer. It features password-controlled
system entry, a VeriSign-issued Digital ID for the Bank's
server, Secured Socket Layer (SSL) protocol for data
encryption, and a router loaded with a firewall to regulate
the inflow and outflow of server traffic.
Secure Access
and Verifying User Authenticity
To begin a session with the Bank's server the user must
key in a Log-in ID and a password. Our system, the Internet
Banking System uses a "3 strikes and you're out"
lock-out mechanism to deter users from repeated login
attempts. After three unsuccessful login attempts, the
system locks the user out, requiring either a designated
wait period or a phone call to the Bank to verify the
password before re-entry into the system. Upon successful
login, the Digital ID from VeriSign, the experts in
digital identification certificates, authenticates the
user's identity and establishes a secure session with
that visitor.
Secure Data
Transfer
Once the server session is established, the user and
the server are in a secured environment. Because the
server has been certified as a 128-bit secure server
by VeriSign, data traveling between the user and the
server is encrypted with Secure Sockets Layer (SSL)
protocol. With SSL, data that travels between the bank
and customer is encrypted and can only be decrypted
with the public and private key pair. In short, the
Bank's server issues a public key to the end user's
browser and creates a temporary private key. These two
keys are the only combination possible for that session.
When the session is complete, the keys expire and the
whole process starts over when a new end user makes
a server session.
Router and
Firewall
Requests must filter through a router and firewall before
they are permitted to reach the server. A router, a
piece of hardware, works in conjunction with the firewall,
a piece of software, to block and direct traffic coming
to the server. The configuration begins by disallowing
ALL traffic and then opens holes only when necessary
to process acceptable data requests, such as retrieving
web pages or sending customer requests to the Bank.
Using the above technologies,
your Internet banking transactions are secure.
UNAUTHORIZED ATTEMPTS
TO UPLOAD OR CHANGE INFORMATION ON THE WEBSITE ARE STRICTLY
PROHIBITED AND ARE SUBJECT TO PROSECUTION UNDER THE
COMPUTER FRAUD AND ABUSE ACT OF 1986 AND TITLE SEC.
1001 AND 1030.
Commerce
National Bank - Customer Privacy Principles
At Commerce National Bank our customers are our highest
priority. As financial services professionals entrusted
with sensitive financial information, we respect the
privacy of our customers and are committed to treating
customer information responsibly. Our Customer Information
Privacy principles serve as standards for all Commerce
National Bank employees for collection, use, retention,
and security of all consumers' information.
We
use the eight Privacy Principles below to guide us in
dealing with consumer information.
Privacy
Principles
1. Recognition of Customers' Expectation of Privacy
We believe the confidentiality and protection of customer
information is one of our fundamental responsibilities.
And while information is critical to providing quality
service, we recognize that one of our most important
assets is our customers' trust. Thus, the safekeeping
of customer information is a priority with the Commerce
National Bank.
2.
Our Collection, Retention, and Use of Customer
(Consumer) Information
We collect, retain, and use information about
customers only where we reasonably believe that
it will help administer our business or provide
products, services, and other opportunities to
them. We collect and retain information about
customers only for specific business purposes
- and we tell customers why we are collecting
and retaining it upon their request. We use information
to protect and administer customer records, accounts,
and funds; to comply with certain laws and regulations;
to help us design or improve our products and
services; and to understand customers financial
needs so that we can provide them with quality
products and superior services.
3.
Maintenance of Accurate Information
We have established procedures to ensure that
customer financial information is accurate, current
and complete, in keeping with reasonable commercial
standards. If account information is found to
be incomplete, inaccurate or not current, a customer
can call us or write us at the telephone number
or address listed on their account statement.
We will investigate all concerns and correct any
inaccuracies in a timely manner.
4.
Limiting Employee Access to Information
Employee access to personally identifiable customer
information is limited to those with a business
reason to know such information. We educate our
employees about the importance of confidentiality
and customer privacy through standard operating
procedures, periodic training programs and these
Privacy Principles. Our employee's access information
about customers when needed to maintain their
accounts or otherwise meet specific needs. We
may also access information about customers when
considering a request for additional services
or when exercising our rights under the law or
any agreements with them. We take appropriate
disciplinary measures to enforce employee privacy
responsibilities.
5.
Security Procedures to Protect Information
We maintain security standards and procedures
to help prevent unauthorized access to confidential
information about customers. We safeguard information
according to established security standards and
procedures, and we continually assess new technology
for protecting information.
6.
Restrictions on the Disclosure of Account Information
We do not reveal specific information about accounts
or other personally identifiable data to parties outside
of Commerce National Bank for their independent use
unless: 1) it is requested or authorized; 2) the information
is provided to help complete a transaction initiated
by a customer; 3) the information is provided to a reputable
credit bureau or similar reporting agency; or 4) the
disclosure is required by or allowed by law (e.g., subpoena,
investigation of fraudulent activity, request by regulator,
etc.). We do not provide account or personal information
to non-affiliated Commerce National Bank companies for
the purpose of independent telemarketing or direct mail
marketing of any non-financial products or services.
7.
Maintaining Customer Privacy in Business Relationships
with Third Parties
Sometimes it is necessary to provide personally
identifiable information about customers to a
third party, such as a vendor or service company
that we hire to prepare account statements or
to provide support services for one or more of
our products. These vendors and service companies
agree to safeguard our confidential information
about customers and their products and services
with us must abide by applicable law.
8.
Disclosing Our Privacy Commitment to You
We want customers to understand how we use the information
they provide and our commitment to their personal privacy.
As a result of our commitment, we have developed these
Privacy Principles, which are made readily available
to our customers. If you have questions about how Commerce
National bank protects confidential information, please
call one of our branches or contact us using the e-mail
reply function located on our Web page.
Former
Customers
In the event you end your relationship with
us, or become an inactive customer, we will continue
to treat the information we have about you as if you
were still our customer and adhere to the policies and
practices descibed in this disclosure.
Changes
to Our Privacy Policy
These
Privacy Principles apply to individuals, and we reserve
the right to change them, along with related provisions,
at any time. Should we make changes to our Privacy Statement,
we will notify you in Bold Font on our Home page with
the new effective date of our Privacy Statement.
Effective Date: 01/14/2010
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