Privacy Policy

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

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

• Information we receive from you on applications or 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 associates who need to know that information to provide you with products and services or to maintain your accounts. Our internal policies and code of conduct clearly define the manner in which an associate 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 as 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 and condition of 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
• If you give us written permission.