Notice of Our Privacy Policy (Regulation P)

Elite International Bank (hereinafter, "the Bank") respects the right of confidentiality of your Account information and disclose such information only as permitted by law and by the Privacy Policy of the Bank, described below.

Annually, or as required by law, the Bank will notify you of our Privacy Policy. This notice also applies to individuals who have been our clients previously.

Some benefits that you can receive by allowing your personal information to be shared between the subsidiaries and affiliates of the Bank, in the strictest confidentiality, are discounts, direct marketing offers, combined account statements, information on new and improved products, and easy access to information about your accounts.

A. How and what information we collect

The Bank collects the following information about you from several sources:

1. Personal information may include name, address and phone number provided on credit applications, account openings or other forms.

2. Transaction information, such as balance, payment history or others.

3. Credit information, such as creditworthiness and credit history from consumer credit agencies. In addition, the information described above is shared to send you direct marketing. For these offers on products and services we consider criteria based on the information we collect.

B. Who we share your information

The Bank will not share your personal information with nonaffiliated third parties, except as permitted by law. Third parties are companies or organizations that are not part of the companies controlled by the Bank. An example would be the company that prints checks or issue credit cards for our customers. As an exception, the Bank shares the personal information of its customers with reputable institutions to carry out marketing initiatives by the Bank. Also the Bank makes marketing campaigns with other companies in order to provide a product or service. When carrying out joint marketing efforts, the Bank only shares the information necessary to achieve the above purposes. In addition, we require those companies, under contract, to maintain the confidentiality of the information and limit its use only for the purposes for which it was provided.

C. What security measures are in place to ensure the privacy of your information

The Bank limits the access of information only to those employees who need to provide services and products, or who need access in order to comply with federal and local regulations in the financial industry. The Bank makes the employees accountable to comply with the Privacy Policy and its principles, and take appropriate disciplinary measures to enforce employee responsibility, as specified by our Code of Ethics and Standards of Conduct of the Bank.

The Bank maintains physical security measures and electronic security measures to safeguard the confidentiality of customer information, as required by law and the Privacy Policy.

D. Privacy for Internet Users

Our commitment to safeguard your privacy also extends to the Internet. If you are just browsing our website, we do not request any personal information or collect information that may identify you unless you voluntarily and knowingly

provide us that information. For example, when you send us an email or fill out an application online, if you provide this information, it will be used.

What are Cookies?

A cookie is a small text file sent by a web server that is stored on the hard drive of your computer or your browser so that it can be read afterwards. Cookies cannot read information from you on your computer or be used to steal information about you and are not virus carriers.

The cookies are a basic way for a server to identify you (most cookies actually identify the computer you are using at the time, not you personally). Cookies are used for many things from personalizing their home pages to facilitating online purchases. Cookies help recognize repeat visitors who access Web pages and operate a very important function when you enter secure Internet banking. For your safety, the Bank does not store any of your personal information in our cookies.

Disclosure and Use of Information

The Bank does not disclose any nonpublic personal information about our customers, former customers or visitors to the site to anyone except as permitted by law. The Bank does not sell any of your personal information. The Bank does not disclose any medical information you provide, unless you specifically authorize us to disclose it.

E-Mail Policy

In the future, we may send email notices of certain disclosures or notices if you choose to accept notices, notifications, statements or disclosures electronically. We may also send an email to market products and services that may be of interest to you.

F. Which option offer

If you wish, you may request that the Bank does not share personal information with subsidiaries and affiliates for use in direct marketing offers products and services. For this purpose, you must complete the Request for Exclusion including in conjunction with this release, and send it to the Bank at the address provided on the bottom of this document. This Request for Exclusion will be in effect until you notify the removal to the Bank via a written request.

The Application shall enter in effect as soon as the Bank receives the communication and thus inform you. Remember that the Bank can continue to exchange information and credit transactions as permitted by law. If you have joint accounts, the secondary person in the account will not receive this notification separately, so you must apply separately, if desired. If you want the Bank to continue sharing your personal information with subsidiaries and affiliates, do not return the Request for Exclusion to continue to have access to benefits such as discounts, direct marketing offers, combined account statements, information on new and improved products and easy access to information about their accounts from any of its subsidiaries or affiliates of the Bank.