Federal Privacy Policy (Effective July 1, 2007)

Today's marketing strategies have increased the amount of customer information collected and shared among businesses. Consumers rightfully are concerned about the impact this has on their privacy. We understand these concerns at Rabobank, N.A. (the Bank).

Your relationship with us is treated with great confidentiality. We view the security and confidentiality of Customer Information as a top priority throughout the Bank. We do not sell or share Customer Information with outside companies for purposes of independent telemarketing, direct mail or other marketing, or selling of any non-financial products or services to you.

We are committed to bringing you the services you need to succeed financially. If we do not offer a financial service, such as some insurance or loan products or credit card services, we may establish a joint marketing program with an outside company, a “Marketing Associate,” to offer that service to you. These programs include confidentiality agreements to protect consumer information and prohibit the outside company from using customer information for any reason other than that for which they have been contracted, or as permitted by law.

The Bank maintains security standards and procedures designed to protect customer information. We will continue to test and update our technology to protect information about you.

This policy covers “Customer Information,” which means nonpublic, personally identifiable information about a consumer or a consumer's current or former relationship with the Bank and its affiliates. This statement is provided in accordance with the federal financial privacy laws.

We hope you will read through all the details of the Bank's official position on privacy. At the very least, we want you to know the Bank uses information we know about you responsibly to:

• Provide you with the services you have requested;
• Offer you other bank services;
• Alert you to financial-services products made available by carefully selected Marketing Associates.

This statement supersedes any previous privacy policies or statements issued by the Bank. If we change this statement, we will inform you.

TYPES OF INFORMATION WE COLLECT

We collect and use various types of information to respond to: your requests for financial services; service your existing accounts; save you time and money; and to gain a better understanding of your needs. And, we want to help you learn more about products and services that may be of interest to you.

Customer information we collect falls into the following types:

• Transaction and account experience information about you with our family of companies, such as your account balance, securities holdings and collateral, payment history, parties to transactions and credit card use or information about communications with you, such as requests for a loan history statement or a copy of a check and our response, or your response to a product offer. All of this is called “Experience Information.” The types below are called “Non-Experience Information.”
• Information you provide on applications and through other means, such as your income, monthly expenses, assets and debt;
• Information from credit bureaus (consumer reporting agencies), such as information regarding your credit worthiness or credit history;
• Information from other outside sources regarding their employment, credit or other relationship with you or substantiating representations made by you, such as your employment history, loan or line of credit balances or property insurance coverage;
• Because it is important to know what types of services may be most valuable to you, we also obtain household and demographic information about current and prospective customers from firms that provide this specialized marketing information.

USING THIS INFORMATION
Most of the information we collect is used for the purpose of helping us deliver the services you have requested, easily and efficiently. It may also permit us to design and offer specific products and services that we believe will be useful to you.

WHO HAS ACCESS TO THIS INFORMATION
Inside the Bank Family: Employees of the Bank and its affiliates are permitted access to the information they need to perform their jobs. We maintain strict internal policies against unauthorized use or disclosure of Customer Information. Further, we maintain physical, electronic and procedural safeguards that comply with federal standards to guard your information.

As financial services companies, the Bank affiliates offer a wide variety of services, such as checking, money market and savings accounts, certificates of deposit, mortgages, consumer loans and lines of credit, credit cards, and many others. As permitted by law, “Experience Information” held by any Bank affiliate is available to other members of the Bank corporate family for authorized purposes. “Non- Experience Information” also is available, unless a customer has specifically requested otherwise. (See “Opting Out of Having Information Disclosed.”)

Marketing Associates: From time to time, we carefully select business associates (other financial institutions and companies with whom we have joint marketing agreements) to provide our customers with specialized financial services, such as online mortgage applications or credit card services. Although these partners are not owned by, or affiliated with the Bank, they work closely with us to help us deliver products and services that meet your financial needs. If appropriate, we may disclose to these Associates certain information, such as:

• Information we received from you on applications or other forms, such as your name, address, or Social Security number;
• Experience Information about your transactions with The Bank affiliates, such as your account balance or payment history; and,
• Information obtained from specialized marketing firms, such as household demographics.

Our Marketing Associates must agree to safeguard the confidentiality of customer information, and they are not authorized to disclose this information to anyone else without our explicit permission, except as allowed by law.

Non-Associated Marketers: The Bank does not sell or share customer information with marketers outside the Bank family of companies or Marketing Associates as described above.

Service Providers: At times, we enter into arrangements with companies whose expertise is essential for our own services to function properly. We may share all five types of Customer Information with these companies to provide the products and services you have requested or already have with us. For example, we work with specialized firms to process credit and debit card transactions, generate account statements, process loan requests, service deposit and loan accounts, print checks, process data, and enable online banking for Bank customers. As permitted by law, we disclose to these service providers the Customer Information necessary to perform these functions and provide products and services to you, as well as a good customer experience. As with all our business partners, these companies are required, and contractually obligated, to safeguard your information and use it only to provide the services we have asked them to perform for you and us, or as allowed by law.

Credit Bureaus: In accordance with standard banking industry practice, and as allowed under federal and state law, the Bank routinely provides data about customer loan repayment and other transactions to credit bureaus (consumer reporting agencies). We will provide this information to other creditors or banks if you authorize it, or as necessary to complete a transaction you initiated.

Courts and Government Entities: Certain federal and state statutes may require us to disclose information about you. For example, if you are involved in litigation with a third party, we may be ordered to provide information to the court or the other litigant. In these circumstances, only specific information required by law, subpoena, or court order will be disclosed.

A comment about former customers' information: Although we generally do not solicit customers who have closed their accounts with us, we may share their information with Bank affiliates and Marketing Associates as described above. Former customers have the same opt-out right as active customers. If you opt out of information sharing as a Bank customer, this request will stand even if your relationship ends with us.

Making Sure Information is Accurate: Keeping your account information accurate and up to date is very important. We provide you with access to your account information through various means, such as account statements, telephone banking and online banking. If you ever find that your account information is incomplete, inaccurate or not current, please call or write to us at the telephone number or address listed on your account statement, bank records, or other documentation. We will promptly update or correct any information we reasonably conclude to be erroneous. If you have questions, or feel that we have not handled information about you properly, you may always contact us and we will promptly investigate your inquiry or complaint.

INTERNET PRIVACY PRACTICES

Protecting Your Privacy Online: The Bank is concerned about your comfort level when it comes to Internet security and safety issues. We want you to know how we will handle the information we learn about you from your visit to our Web site(s). This privacy statement applies to your visits to our Web site(s), with some additional details below.

Information We Collect Online: The information we receive about you depends upon what you do when visiting our Web site(s). We do not obtain personally identifying information about you when you visit our Web site(s) unless you choose to provide such information.

We use the above information to collect and measure the number of visitors to the different sections of our Web site(s), and to help us stay abreast of technical upgrades that can make our Web site(s) more accessible and innovative for our visitors.

Online Banking Security: To protect your information, we maintain physical, electronic and procedural safeguards that comply with federal regulations. When you submit private data to us over the Internet, our internal security standards guard it in several ways. Encryption helps protect it from interception by a third party. The passwords and other safety features we have installed also help ensure that the information you provide us remains safe and secure. 

Confidentiality: No one is permitted access to this information except employees and authorized outside service providers who provide services to you.

In addition, you should know about these online information management tools that may offer additional convenience:

“Cookies”: To simplify your online banking experience with us, we may place a "cookie" on your PC while conducting online banking sessions. (A cookie is a piece of information that our Web server stores on your computer's hard drive and retrieves later.) Per-session cookies are for Online Banking system security, used for time outs if your browser is left open. When you close your online banking session, the cookie is deleted when the session ends. We do not use cookies to record information that will enable anyone to contact you via telephone, e-mail, or regular mail.

Consolidation Sites: Online aggregation, or "screen-scraping" services, are available to consumers at little or no cost from a number of other firms. Here's how they work:

• You give the service provider the passwords or other access keys to your various accounts at banks, brokerage houses and other institutions;
• The service provider then collects statement information from these institutions' Web sites on your behalf, and aggregates all this information in a single online statement;
• Some services also allow you to initiate online payments or other transactions.

Please Use Caution When Using Consolidation Sites: Before you grant any company access to your account information, we recommend finding out how it will collect and safeguard your data. Consumer protections may vary depending on the nature and identity of the aggregator. In any event, if you allow third parties to access your personal information, the Bank and its subsidiaries can accept no responsibility for their actions or for any losses that may result.

WE RESPECT YOUR PRIVACY
As technology continues to advance, you can be sure the Bank will provide safeguards to keep your personal financial information confidential and secure. Your trust is important to us — and we are committed to protecting your privacy, whether you do business with us on the Internet, in person, via telephone or mail. Thank you for choosing us as your financial services provider.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT (AB68)
Our Web site does not currently collect any personally identifiable information above what is collected in writing when you sign-up for our eBanking service or when you submit a change to your personally identifiable information (address, phone number, etc.)

You may initiate changes directly via the online service. It is your sole responsibility to ensure that the contact information in your user profile is current and accurate. This includes, but is not limited to, name, address, and phone numbers and e-mail addresses. Changes can be made either within the application or by calling us at this toll-free number (800) 473-7788 or (805) 473-7788.  Any changes in your Payment Account should also be made in accordance with the procedures outlined within the application's Help files. All changes made are effective immediately for scheduled and future payments paid from the updated Payment Account information. The Service is not responsible for any payment processing errors or fees incurred if you do not provide accurate Payment Account or contact information.

WHERE TO FIND OUT MORE
If you have questions, concerns, or comments about our privacy practices, or the way your information is maintained and used, we would like to hear from you. Please visit your nearby branch, send an e-mail to info@midstatebank.com  or write us at:

Rabobank, N. A.
Attn: Privacy Officer
P.O. Box 6002
Arroyo Grande, CA 93421-6002

OPTING OUT OF HAVING INFORMATION DISCLOSED

By making Customer Information available to other companies owned by the Bank and to carefully selected third party Marketing Associates, we are able to provide better service and offer financial solutions we believe you will value. In fact, some non-credit products and services may be available only if you allow us to share your information.

If you would like, you may direct us not to disclose Non-Experience Information about you to members of the Bank Family. (See “Types of Information We Collect”). To do so, fill out and mail us the following Opt-Out Request or write to us at:  Rabobank, N.A., Attn: Privacy Officer, P.O. Box 6002,  Arroyo Grande, CA 93421-6002.

When you write to us, please include your name as it appears on your accounts with us, as well as your address, Social Security number, and account numbers. Any owner of a joint account may elect to opt out. In making that election, only information about the named electing customer will be covered, but each joint customer may opt out using the same form. An “Opt-Out Request” becomes effective within 30 days of receipt.

You should also know that even if you opt out of information disclosure, the Fair Credit Reporting Act and other laws allow us to share Experience Information with our affiliates and other companies (specific details about your transactions and experience with us, including information about your account balances or payment history).

"_______________________________________________________________________________________________________

OPT-OUT REQUEST

If you do not want us to share Non-Experience Information from your applications, consumer reports or from other outside sources among our family of companies, please tell us by printing, completing, cutting off and mailing this Opt-Out Request to Rabobank, N. A. at the address below. Joint consumers: If you jointly obtain a product or service from us with someone else, we will treat an Opt-Out Request by any one of you as applying only to you. Every joint customer who wishes to opt out must complete the information below.

Find Out More: Your direction in this paragraph covers certain information about you that we might otherwise share with our corporate family. We may share other information about you with our corporate family as permitted by law. If you have questions, concerns, or comments about our privacy practices or the way your information is maintained and used, we would like to hear from you. Please visit your nearby branch, send an e-mail to info@midstatebank.com or write us at the address below:

_______ I instruct you not to share “Non-Experience Information” about me with your corporate family.

Your name and address as it appears on your accounts___________________________________________________________

Your Signature__________________________________________________________________________________________

Your Social Security Number and Account Number: ____________________________________________________________

Joint Account Holder name as it appears on your accounts________________________________________________________

Joint Account Holder Signature_____________________________________________________________________________

Rabobank, N.A.
ATTN: Privacy Officer
P.O. Box 6002
Arroyo Grande, CA  93421-6002

____________________________________________________________________________________________________________________

CALIFORNIA PRIVACY NOTICE

IMPORTANT PRIVACY CHOICE FOR CONSUMERS

You have the right to control whether we share some of your personal information. Please read the following information carefully before you make your choice below.

Your Rights

You have the following rights to restrict the sharing of personal and financial information with outside companies that we do business with. Nothing in this form prohibits the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.

Your Choice

Restrict Information Sharing with Other Companies We Do Business with to Provide Financial Products and Services:

Unless you say "No," we may share personal and financial information about you with outside companies we contract with to provide financial products and services to you.

(    ) NO, please do not share personal and financial information with outside companies you contract with to provide financial products and services.

Time Sensitive Reply

You may make your privacy choice at any time. Your choice marked here will remain unless you state otherwise. However, if we do not hear from you we may share some of your information with companies with whom we have contracts to provide products and services.

Name:_______________________________________________ 

Account Number (s):____________________________________

Signature:____________________________________________

To exercise your choice, do one of the following:

1.       Print, fill out, sign, and send back this form to us at: Privacy Officer, Rabobank, N.A., P.O. Box 6002, Arroyo Grande, CA 93421-6002. (You may want to make a copy for your records.) OR

2.       Call this toll-free number (800) 473-7788, or (805) 473-7788 OR

3.       Reply electronically by e-mailing us at info@midstatebank.com  If you choose to e-mail us, please do not include any confidential information such as social security number or account number.

LINKS FOR MORE INFORMATION ON PRIVACY

• FDIC: Safe Internet Banking
• FDIC: Identity Theft
  

(Revised 09/07)