Privacy Policy

The following privacy policy and disclosure outlines Silvergate Bank’s practice regarding personally identifiable financial information for consumers and those consumers that become our customers.

The Bank will provide this policy to customers when they open an account or become a customer of the Bank, and at least annually thereafter.  This notice will be provided in the form of a written notice prepared in compliance with applicable regulatory requirements.

Privacy Policy

At Silvergate Bank, the privacy and security of your non-public personal information is very important to us.  This policy discusses how we manage your non-public personal information.  This policy applies to all Silvergate Capital Corporation companies, including Silvergate Bank, a wholly-owned subsidiary.

We collect non-public personal information about you from the following sources:

·  Information we receive from you on applications and other forms;

·  Information about your transactions with us, our affiliates, or others; and

·  Information we receive from consumer reporting agencies.

As required by the USA PATRIOT Act, we also collect information and take actions necessary to verify your identity.

We do not disclose any non-public personal information about our customers to anyone, including our affiliates, except as permitted by law.  You do not need to take any action to receive this benefit.

Internally, we restrict access to non-public personal information about you to our employees who need to know that information to provide you with products and services or to maintain your accounts.  Our internal policies and code of ethics clearly define the manner in which an employee may access, use, or disseminate non-public personal information.  We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information.

If you decide to close your account(s) or become an inactive customer, we will adhere to the policies and practices described in this notice. 

We will disclose information to third parties about your account or the transfers you make as follows:

·  Where it is necessary for completing transfers, or

·  In order to verify the existence or condition or your account for a third party, such as a credit bureau or merchant, or

·  In order to comply with government agency or court orders, or

·  To account information services, such as ChexSystems, Inc., or

·  In connection with collection of indebtedness or to report losses incurred by us, or

·  In compliance with any agreement between us and a professional, regulatory, or disciplinary body, or

·  In connection with potential sales of businesses, or

·  If you give us written permission.

Online Privacy and Security Policy and Disclosure

Silvergate Bank respects the privacy of its customers and visitors to its Website and is committed to protecting their information on our Website.  We collect only non-identifying information about visitors to our Website such as the date and time the site was accessed, what pages were visited, what servers were used, and the city of the visitor as identified by the server address.  Website visitors are invited to submit personal information by email, by submitted applications, or by requests for information.  This information is used as appropriate by employees of Silvergate Bank to complete the request submitted through the Website.  This information s never disseminated outside of Silvergate Bank or sold to other organizations.  Silvergate Bank trains and requires 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.  This was our policy before the arrival of electronic means of accessing information and it is the policy that is followed regarding all electronic customer transactions. 

Online Privacy

When you use Online Banking to apply for one our products or services, or sign up for an online service, such as bill payment, we will request information, such as your email address or your account number.  This information allows you to perform certain tasks (e.g., correspond with us or review your accounts) and it allows us to provide the information you requested.  In these cases, we collect only the information necessary to interact with you.  We also gather data to track Website usage, such as the number of hits, pages visited, and the length of user sessions, in order to evaluate the usefulness of our sites.  This information is not specific to your personally identifiable financial information.

Cookies

A cookie is an element of data that a website can send to your browser, which may then be stored on your system.  A cookie does not retrieve any data from your hard drive, carry computer viruses, or capture your email address.  Cookies help websites keep track of user preferences and to recognize return visitors.  So, when you return to a website you’ve visited before, your browser gives this data back to the server.

We use cookies to make your online experience with us a more focused one based on the products and services you have with us.  We also use cookies for various purposes, such as maintaining continuity during an online session, gathering data about the use our Website, or monitoring our online promotions.  This information helps us inform you about additional products, services, or promotions that may be of interest to you.

You can set your browser to reject cookies.  However, if you choose to reject cookies, you cannot bank online with us. 

Online Security

We are committed to protecting the confidentiality of your information and online transactions.  We use the highest industry standard for online security to secure your online sessions.  This process safeguards your banking sessions from intruders.

Links on our Website

We may provide links to sites outside of our website to alert you to products, information, and services offered by third parties.  These links are provided as a courtesy to give you access to information that may be of interest to you, and may be to both the private and public sector websites.  Although we will only provide links to sites we believe are reputable, we do not make any representations concerning the linked sites’ contents or availability.  Please note that linked sites may have different privacy and information security policies than Silvergate Bank.  You should review each site’s privacy and information security policies carefully before you enter confidential information onto the site.

External Financial Services

Please use caution when using external financial aggregation or consolidation services. These are companies that collect personal information from a variety of sources and place them on one Website.  They are able to do this by having you give them your identification information and password for each individual Website, and then use these passwords to access each account. You must provide your permission and information to allow these services to collect this data.  We recommend extreme caution when using these services and encourage you not to provide any account or password to a site that is not familiar to you.

Preventing Identity Theft and Record Accuracy

Silvergate Bank is committed to protecting your personal information and to maintaining accurate and complete records of all of your financial information.  We are equally committed to resolving any reported inaccuracies or discrepancies. Strict policies and procedures have been implemented to ensure that your personal information is kept confidential. This would include any possible unauthorized access to or use of your account information. Only authorized signers can access account information.  Every effort is made to protect our customers from fraud.  We will never initiate a request for sensitive information from you via email (e.g., social security number, personal ID, password, PIN, or account number). If you receive an email that requests this type of sensitive information, you should be suspicious of it.  We strongly suggest that you do not share your personal ID, password, PIN, or account number with anyone, under any circumstances.  If you receive a suspicious looking email or if you believe our records contain inaccurate or incomplete information, please notify us at once. You should contact us at:

Silvergate Bank

4275 Executive Square, Ste. 800

La Jolla, CA 92037

(800) 595-5856

Revisions to our Privacy Policy

Silvergate Bank reserves the right to change our Online Privacy and Security Policy.  If we make a change, we will revise our Privacy Policy to reflect such changes and revise the Policy’s effective date.  Checking the effective date allows you to determine whether there have been changes since the last time you reviewed the policy.

Effective Date of Policy

This Online Privacy and Security Policy is effective as of March 1, 2008.

Kathleen M. Fraher

Vice President, Compliance/BSA Officer

Ph. 858-362-2653

Fax 858-362-6323

Silvergate Bank

4275 Executive Square, Ste. 800

La Jolla, CA 92037