Privacy Statement

Updated January 2011

This privacy statement discloses the privacy practices for services provided by BankServ. BankServ is in compliance with the all applicable laws and regulations including, but not limited to, the Gramm-Leach-Bliley Act (GLBA), the US-EU Safe Harbor privacy principles (also referred to as the European Union Data Protection Directive), and any other applicable state and federal regulations.

Goal
Our customers' information, which includes but is not limited to account numbers, customer name, address and other items, is important to BankServ. We are committed to maintaining professional standards of confidentiality. Our privacy policy below discusses the types of information we collect, how we use it, and under what circumstances, if any, that we might disclose it.

Information Collection and Use
BankServ collects only the information needed to administer our business and to provide customers with our products and services. BankServ's information is processed within the United States. We will not give, sell, share or rent this information to others, except as disclosed in this statement. Sensitive information such as race, health conditions, or religious items is never shared with a third party.

Client Profile Information
For some services, a client may choose to provide the information requested on an application form that may be electronic or paper. A customer will be asked to provide client profile information, which may include information on contacts, business name, principal's name, expected transaction volumes, business financial data, bank accounts, addresses, URLs, telephone numbers, and email addresses. This information is used to contact the customer about the services and to set the customer up for the requested services.

BankServ will not give, sell, share or rent this information to others. BankServ, may however, validate this information, or request additional information from credit bureaus or other third parties, to assist us in underwriting the client. Information obtained from third parties is kept confidential under the terms of the agreements with those third parties.

Data Retention
Federal and state agencies require that BankServ provide aggregated demographic information about our customer and employment applications and our approval/hiring history. We maintain electronic and hardcopy information for all of our documents for a period of 7 years in accordance with federal and state laws.

Dispute Resolution
In situations where BankServ and a customer cannot resolve a complaint, BankServ participates in the dispute resolution in cooperation with the Data Protection Authorities to resolve disputes with regards to the Safe Harbor Policy. Please contact BankServ's privacy officer with any complaints.

Privacy Officer
BankServ
8350 S Durango Drive, Suite 140
Las Vegas, NV 89113
415-277-9900
privacy -at- bankserv.com

Accuracy of Information
BankServ provides access to your account information through several areas such as account statements, online viewing and other utilities. If BankServ has any incorrect or incomplete information, notify us via telephone or email or postal. If you wish to know if we have information about you or you require a copy of the information can make a formal request by contacting:

Privacy Officer
BankServ
8350 S Durango Drive, Suite 140
Las Vegas, NV 89113
415-277-9900
privacy -at- bankserv.com

Data Access
All data access is based on a need to know basis. Only employees who need information to perform a specific job (such as our customer service representatives) are granted access to personally identifiable information. BankServ employees are trained and required to acknowledge at least annually and/or reminded about the importance we place on privacy, and the steps they should take to protect our customers' information.

Data Protection
BankServ uses a variety of security safeguards to protect your information from loss, misuse, alteration or destruction. We provide access to your personal information to BankServ employees and other authorized parties on a "need to know" basis. The secure protected area of our Web services site(s) may allow our customers, using a unique username and password, to access account information and transaction reporting, and to initiate or process transactions directly from the Web site, depending on their entitlements and account setup.

BankServ also uses Secure Sockets Layer (SSL) technology supporting up to 256-bit encryption to prevent unauthorized parties from viewing any personal information transmitted to or from BankServ during a web session. BankServ utilizes both encrypted databases and encrypted backups to ensure customer data is secure in transit and while at rest.

Sharing
When we partner with another party to provide specific services, and a customer signs up for those services, we share only the contact information that is necessary for the third party to provide such services. Third parties are not authorized to use personally identifiable information except for the purpose of providing those services.

Supplementation of Information
BankServ is committed to using state-of-the-art technology, methodology, and services to protect customers, consumers and BankServ itself from credit risks, fraud and operational compromise. In addition to collecting and archiving application and transaction data from customers and consumers, BankServ also retrieves supplemental data from third parties to facilitate credit and operational decisions and monitoring. These third parties may include national and regional consumer and business credit bureaus, check verification services, address verification services and other third party transaction processors. Once the information is retrieved from third parties, it is archived in a secure environment. This data may be used to build proprietary databases or to develop statistically based credit, fraud or marketing models.

Access to customer information by employees is for business purposes only. Employees are required to treat customer information in a confidential manner. Employees failing to adequately handle customer data face disciplinary action. Notification of Changes

BankServ reserves the right to change the Privacy Policy at any time in accordance with applicable laws and regulations.