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California Consumer Privacy Act Disclosure

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Commercial Bank of California (“CBC,” the “Bank,” “we,” or “our”) respects your privacy and is committed to the proper handling of the
personal information collected or processed in connection with your relationship with the Bank.

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”) requires that we
disclose categories of personal information we may collect about California residents, the categories of sources from which we collect it, and the business or commercial purpose for its collection.

Collection and Use of Your Personal Information

In the past 12 months, CBC may have collected the following personal information about you for the following stated business and
commercial purpose:

Category Examples Business & Commercial Purpose For Collection
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security Number, driver’s license number, passport number, or other similar identifiers. To open or decline your deposit and/or loan requests, and/or maintain your account(s)/products and services you have with us, respond to your request(s), or to secure your account(s). Information may also include email providers for sending bank promotional content. Your information may also be shared with regulatory agencies and law enforcement requests (when required) as well as for use by our external auditors, governmental regulatory examiners and external vendors who assist in providing bank products and services.
Personal information categories listed in California Customer Records law Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, such as name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information or health insurance. To open or decline your deposit and/or loan requests, and/or to maintain your account(s)/products and services you have with us, respond to your request(s), or to secure your account(s). Information may also include email providers for sending bank promotional content. Your information may also be shared with regulatory agencies and law enforcement requests (when required) as well as for use by our external auditors, governmental regulatory examiners and external vendors who assist in providing bank products and services.
Protected classification characteristics under California or federal law Age (40 and older), race, color, national origin, citizenship, marital status, gender, sex, military or veteran status. To service your account, respond to your request, and other legal requirements.
Commercial Information Records of personal property. To open or decline your deposit and/or loan requests, and/or to maintain your account(s)/products and services you have with us, respond to your request(s), or to secure your account(s). Information may also include email providers for sending bank promotional content. Your information may also be shared with regulatory agencies and law enforcement requests (when required) as well as for use by our external auditors, governmental regulatory examiners and external vendors who assist in providing bank products and services.
Internet or other electronic network activity information Browsing history, search history, last login, information on a consumer’s interaction with a website, application, or advertisement. To assist us in identifying potential Bank products and/or services of interest. To support internal operations of our website or mobile applications. Data may also be used to investigate malware/hacking attempts, conducting external audits or to comply with regulatory requirements. Information may also include email providers for sending bank promotional content.
Geolocation data Physical location, device location from usage of the company’s devices. For identification purposes in order to service your bank accounts and limit losses due to fraud.
Sensory data Audio recording (for recorded phone lines only pursuant to regulatory requirement), electronic, visual information, or similar information. For identification purposes in order to service your bank accounts and limit losses due to fraud.
Professional or employment-related information Current or past employment history, title, salary, employment files, references. For identification purposes in order to service your bank accounts and limit losses due to fraud.
Sensitive Personal Information Social security numbers, account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to account content of the mail, email, and text messages. Limited use of sensitive information. For identification purposes in order to service your bank accounts and limit losses due to fraud.

Sources for Your Personal Information

We collect and obtain your personal information from:

  • You. We collect information directly from you when you use our website, online banking services, and in branch banking services and communicate with us.
  • Third-Parties. We may collect information about you from third-party sources, including but not limited to service providers, government agencies, credit reporting agencies, law enforcement personnel, insurers, and other financial institutions. The third parties assist us to review and intake new customers, provide banking services to prospective and existing customers, monitor and prevent fraud, perform our day-to-day business, conduct advertising, and comply with applicable laws and regulations.
  • Cookies and Similar Technologies. When you visit our website, use our online services, and communicate with us via email, we may use technologies such as cookies and web beacons to collect certain information about you, such as your IP address, browser type and operating system, viewed web pages, links that are clicked, sites visited before coming to our website, etc.

No Sale or Sharing of Personal Information

We do not sell or share of your personal information, as those terms are defined by the CCPA. Thus, there is no need for you to opt- out of any sale or sharing of your personal information. As stated in CBC’s Consumer Privacy Notice and as permitted by the CCPA and state and federal law, we do disclose your personal information to third parties for a variety of permitted and lawful reasons.

No Unauthorized Use or Disclosure of Sensitive Personal Information

We limit our use and disclosure of your sensitive personal information to purposes which are authorized by the CCPA. As such, there is no opportunity for you to opt out of our use or disclosure of your sensitive personal information.

CCPA Rights

If you are a California resident, the CCPA provides you with the following rights:

  • Right to know your collected personal information. You may request that we identify (i) the categories of personal information we collected; (ii) the categories of sources used to collect your personal information; (iii) the business or commercial purposes for collecting your personal information; (iv) the categories of third parties with whom we share your personal information; and
    (v) the specific pieces of personal information we collected about you.
  • Right to know your disclosed personal information. You may request that we state (i) whether we have disclosed any of your personal information to third parties for a business or commercial purpose; (ii) list the categories of personal information that we have disclosed, if any, to third parties for a business or commercial purpose.
  • Right to request deletion of personal information. Subject to legal exceptions, you may request that we delete your personal information.
  • Right to correct inaccurate personal information. Subject to legal exceptions, you may request that we correct inaccurate personal information.
  • Right not to be discriminated against for exercising any of these rights.

Legal Exceptions for Right to Delete

Our obligation to delete your personal information is subject to certain legal exceptions. Please note that we are not required to comply with your request to delete your personal information if it is necessary for us or our service provider(s) to maintain the information to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act pursuant to California Penal Code Section 1546.
  • Comply with a legal obligation.
  • Engage in public or peer‐reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

If we have been able to verify your identify, and to the extent the exceptions do not apply, then we will delete your personal information and direct any service providers, contractors, and third parties to delete your personal information from their records.

How to Exercise Your CCPA Rights

If you are a California resident and want to exercise any right under the CCPA, you or your authorized agent may do so by contacting us as follows:
(i) By using the online California Consumer Privacy Act Contact Form which may be access here or
(ii) By calling our toll-free number 1-877-206-9167 and selecting Option 7.

Please be advised that before you can exercise any of your rights, we will first need to verify your identity using the information you input into the web form or provide to us by telephone. This information may include your name, contact information, and information related to your relationship with CBC, but the specific information requested may differ depending on the nature of your request, in order to protect your privacy and for your security.

You may also exercise any right under the CCPA through an authorized agent. We will need documentation verifying that your designated agent is authorized to act on your behalf. We may not be able to fulfill your request if we are unable to verify that the agent is, in fact, authorized to act on your behalf.

Under California law, we are only required to respond to a request to exercise CCPA rights from the same individual no more than twice in a 12-month period.

Limitations to Your CCPA Rights

Your requests under the CCPA are subject to certain legal exceptions, including:

  1. We are not required to disclose information about accounts or transactions that are used for personal, family or household purposes. The federal Gramm Leach Bliley Act gives consumers certain privacy rights in connection with their accounts and transactions used for personal, family or household purposes. The CCPA and the rights discussed in this Disclosure do not apply to those accounts or transactions.
  2. We are not permitted to disclose information collected in connection with our internal bank security procedures or federal reporting responsibilities. As a federally‐regulated bank, we are required to maintain adequate security measures to protect you, our customer, and to protect the Bank, and we need to collect certain information about our customers and their accounts and transactions in connection with those security measures. Disclosing that information to anyone could compromise our security measures. We are also required to collect and report certain information to the government about accounts and transactions, and we are not permitted under federal law to disclose the information we collect or report in connection with these responsibilities.

No Discrimination for Exercising CCPA Rights

We will not discriminate against you if you exercise any of your rights under the CCPA. This means, for example, that we will not:

  • Deny you any goods or services because you exercised your rights;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, because you exercised your rights;
  • Provide a different level or quality of goods or services to you because you exercised your rights;
  • Suggest that you receive a higher price or rate for goods or services or a lower level or quality of goods or services because you exercised your rights

Questions

If you have any questions regarding this Disclosure, any of CBC’s privacy practices, your personal information or how to access this Disclosure in an alternative format, you may (i) call us toll-free at 1-877-206-9167 Option 7, (ii) contact your branch of account or (iii) write to us at: Commercial Bank of California, Attn: Compliance Department, 19752 MacArthur Blvd., Suite 100, Irvine, CA 92612.

Update to This Disclosure

From time to time, CBC may update this Disclosure. Please note that the most recent date that this Disclosure was updated is shown at the end of this Disclosure. We encourage you to review this Disclosure periodically so that you are informed of our current practices. By continuing to use any of the Bank’s services after we post a new, updated Disclosure on our website, you consent to any and all changes we make to this Disclosure.

Please click here to review CBC’s complete Privacy Policy.