ARDEN FINANCIAL SERVICES, INC.
INSURANCE BROKERAGE AND CONSULTING

Under the legislative requirement requiring financial institution Privacy Policy and Procedure disclosure, we are pleased to advise all past, present and future clients of our policies for maintenance of privacy of non-public consumer information.

Your privacy is important to us. At Arden Financial Services, Inc., we are committed to maintaining your privacy and to retaining your trust. We respect your right to keep your information private and to avoid unwanted solicitation.

TYPES OF INFORMATION WE COLLECT:

We collect non-public information about you, your company & your employees that is provided by you or obtained by us with your authorization to prepare insurance advice and coverage for your company.

EXAMPLES OF SOURCES OF INFORMATION FROM WHICH WE COLLECT INFORMATION:

CLIENT INTERVIEWS, INTERNAL (CONFIDENTIAL) FINANCIAL STATEMENTS & BUSINESS PLANS, PRIVATE PLACEMENT MEMORANDA AND SIMILAR OFFERING CIRCULARS, INSURANCE COVERAGE APPLICATIONS AND ATTACHEMENTS.

To properly review your exposures and advise you regarding the purchase of insurance coverage, we receive information from you to complete our review and marketing of your account. This information is collected from you in writen form, by phone, on line, by mail, by electronic mail, and in personal interviews and consultations conducted by us as well as by information we collect from others with your authorization.

TRANSACTION INFORMATION

This is information about your transactions with us and includes information necessary for billing and payment for our services, as well as all correspondence between you and us. Transaction information would also include your payment history with us, billing records and any collection effort engaged in by us for payment of services rendered to you.

PARTIES TO WHOM WE DISCLOSE INFORMATION

We do not disclose any non-public information about our clients to our affiliates or to any nonaffiliated third parties except as permitted by law and authorized by you. Non-Public information about you and your company may be disclosed to both our affiliates and nonaffiliated third parties as permitted by law under the following circumstances:

1. Complying with a validly issued and enforceable subpoena or summons.

2. In the course of a review of our firms practices by a Local, State or Federal Insurance Regulatory Commission.

3. A review of a professional practice in conjunction with a prospective purchase, sale or merger of all or part of our organization, provided we take the following precautions (for example, through a written confidentiality agreement) so the prospective purchaser does not disclose information obtained in the course of the review.

4. Participating in actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated against us, provided we disclose only the information necessary to file, pursue or defend against the lawsuit, and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.

5. Providing information to affiliates of the firm and nonaffiliated third parties who perform services or functions for us pursuant to contractual agreement which prohibits the third party or affiliate from disclosing or using the information other than for the purposes for which the information was disclosed: for example, using an outside service organization to complete an insurance purchase or audit transaction, or using a records retention agency to store client records.

CONFIDENTIALITY AND SECURITY OF NON-PUBLIC INFORMATION:

We restrict access to Non-Public Information about you and your company to those employees and other parties who must use that information to provide services to you. Their right to further disclose and use the information is limited by our Employee Code of Conduct, applicable law, and our Code of Professional Conduct and non-disclosure agreements where appropriate. We also maintain physical, electronic, and procedural safeguards in compliance with applicable laws and regulations to guard you Non-Public Personal Information.

Sincerely,

Arden Financial Services, Inc.