Bank of Guam Privacy Policy
Protecting your privacy is important to BANK OF GUAM, our affiliates* and our employees. We want you to understand what information we collect and how we use it. In order to provide our customers with a broad range of financial products and services as effectively and conveniently as possible, we use technology to manage and maintain customer information. The following policy serves as a standard for all BANK OF GUAM employees for collection, use, retention, and security of nonpublic personal information.

What Information We Collect
We may collect “nonpublic personal information” about you from the following sources:
• Information we receive from you on applications or other loan and account forms;
• Information about your transactions with us, our affiliates or others; and
• Information we receive from third parties, such as credit bureaus.

“Nonpublic personal information” is nonpublic information about you that we obtain or develop in connection with providing a financial product or service to you. For example, nonpublic personal information includes information regarding your account balance, payment history, overdraft history and account transactions initiated through our Pacific Express® On-Line service.

What Information We Disclose and Your Opt Out Rights
We may share all of the nonpublic personal information we collect, as described above, with companies related to us by common control or ownership (our “affiliates”). While we currently have only one active affiliate, BankGuam Insurance Underwriters, Inc., our affiliates may in the future include:
• Financial service providers, such as mortgage bankers, securities broker-dealers and insurance agents;
• Non-financial companies, such as retailers, direct marketers, airlines and publishers; and
• Others, such as non-profit organizations.

You may direct us not to share with our affiliates any information about you that does not relate solely to our experiences or transactions with you by submitting an “Opt Out Request Form” to the address provided below. The type of information that we may collect about you and which is not related solely to our experiences or transactions with you includes information we receive through applications or in credit reports from credit bureaus.

We may also share all of the nonpublic personal information we collect, as described above, with “nonaffiliated third parties” (i.e., third parties that are not members of our corporate family) as permitted by law, such as to government entities in response to subpoenas and to credit bureaus.

Information We Provide to Our Service Providers and Pursuant to Joint Marketing Arrangements
We may share all of the nonpublic personal information we collect, as described above, with:
• Companies that perform services on our behalf, such as third parties we hire to assist us in servicing your loans or accounts;
• Companies we hire to provide us with marketing services; and
• Other financial institutions with whom we have joint marketing agreements. For example, when you purchase an investment product such as a mutual fund or annuity through PrimeVest® Financial Services, you may be dealing with one of our em-ployees who also works for the company that sells the investment products. When you provide information in connection with your purchase of the investment product, you provide it both to us and to the other company involved in offering these products.

Information About Former Customers
If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this privacy statement.

Our Security Procedures
We also take steps to safeguard customer information. We restrict access to your nonpublic personal and account information to those employees who need to know that information to provide products or services to you. We maintain physical, electrical, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Medical or Health Information
We do not disclose any personal medical or health information to third parties unless authorized by you or as required by law.

Our Web Site
When you visit our Web site at www.bankofguam.com, we want you to feel secure that we are respecting your privacy. The only private information we collect about you is the information you choose to give us (such as providing feedback or filling out various applications online) or information we collect through “cookies” (which are described below). Any nonpublic personal information we gather through our Web site is treated in the same manner and subject to the policies described in this privacy statement.

A “cookie” is a small element of data that a Web site can send to your browser, which may then be stored on your computer system. We may use “cookies” on some pages of our Web site for the purpose of serving you better when you return to that page. Data collected from cookies helps us determine how many people visit certain pages, ultimately enabling us to improve our Web site design and content. These cookies do not collect personal information about you. If you prefer, your Web browser can be set to provide you a notice before you accept a cookie.

Pacific Express® OnLine
We may receive or develop nonpublic personal information about our customers when they use the services available through Pacific Express® OnLine. Any nonpublic personal information we gather through this service is treated in the same manner and subject to the policies described in this privacy statement.

Every customer that has requested and been approved for our Online Services has been provided an authorized access code, password, personal identification number, and assigned communication telephone number. We use these combined security controls and special communication lines to not only protect our online customers, but also limit the risk to unauthorized data access or security problems. If someone wants to use this service, they must submit an application (listed at our Web site) and be notified of approved authorization and security codes.

E-Mail
When you send us an e-mail that is general in nature and we respond, your e-mail to us and our response are generally not secure.

Children’s Privacy
Protecting the privacy of our children is essential. For that reason, our Web site is not structured to attract children under the age of 13. Parental consent is required for children under 13 to provide personally identifiable information via our Web site.

How to Contact Us
If you would like additional information, or have questions regarding Bank of Guam’s Privacy Policy, please telephone us at
671-472-5300 or send us e-mail at customerservice@bankofguam.com. You may also write us at Bank of Guam, P. O. Box BW, Hagåtña, Guam 96932, or stop by one of our many branches and discuss your questions with one of our staff.

(*This Privacy Policy Statement is being provided to you by Bank of Guam and its affiliate, BankGuam Insurance Underwriters, Inc., and applies to both companies. The terms “we,” “us,” “our,” or “ours” refers to Bank of Guam and BankGuam Insurance Underwriters, Inc.)