PRIVACY POLICY

It is and shall remain the policy of The Peoples Bank of Georgia (the “Institution”) to protect a consumer’s nonpublic personal information and all personally identifiable financial information in accordance with Regulation P and the Fair Credit Reporting Act. This information specifically includes any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available. Additionally, the Institution will protect any information:

• The consumer provides to it to obtain a financial product or service;

• Of a consumer resulting from any transaction involving a financial product or service between the Institution and a consumer; or

• The Institution otherwise obtains about a consumer in connection with providing a financial product or service to that consumer. The Institution shall provide a clear and conspicuous notice that accurately reflects the privacy policies and practices as they relate to:

• The Institution’s customers; and

• consumers who may inquire or apply for the Institution’s services but do not become customers.

The Institution’s Privacy Notice shall be given to the individual when that individual enters into a continuing relationship with the Institution and then once annually during the customer relationship. The Privacy notice shall inform the customer of the following information:

• The categories of nonpublic personal information that the Institution collects;

• The categories of nonpublic personal information that the Institution discloses;

• The categories of affiliates and nonaffiliated third parties to whom the Institution discloses nonpublic personal information;

• The categories of nonpublic personal information about the Institution’s former customers that the Institution discloses and the categories of affiliates and nonaffiliated third parties to whom the Institution discloses nonpublic personal information about the Institution’s former customers;

• An explanation of the consumer's right to opt out of the disclosure of nonpublic personal information to nonaffiliated third parties and the ability to opt out of disclosures of information among affiliates;

• The Institution’s policies and practices with respect to protecting the confidentiality and security of nonpublic personal information;

• Any exceptions to the opt out requirements.

Additionally, the Institution shall develop, implement, and maintain a written Identity Theft Prevention Program that is designed to detect, prevent, and mitigate identity theft in connection with the opening of or any existing account that the Institution offers or maintains, primarily for

THE PEOPLES BANK OF GEORGIA

personal, family, or household purposes, that involves or is designed to permit multiple payments or transactions, such as a credit card account, mortgage loan, automobile loan, margin account, checking account, or a savings account. The Institution shall adopt the rules set forth in the Interagency Guidelines on Identity Theft Detection, Prevention, and Mitigation.

The Compliance Officer shall be responsible for maintaining the Institution’s Privacy Policy and shall develop and train personnel on the Privacy Policy. The Compliance Officer shall conduct training for the Board of Directors at least annually.

ENFORCEMENT & OVERSIGHT

The Board of Directors has the authority to approve and enforce this policy. Changes to this policy require approval by the Institution’s Board of Directors; however, senior management is responsible for ensuring that the policy is implemented and administered in compliance with this policy.

Changes to any corresponding operating procedures may be approved by the Compliance Officer and/or appropriate senior manager over the impacted area.

It is the responsibility of each employee and director to comply with this policy and any applicable laws, rules, regulations, and, if appropriate, regulatory issued guidance.

AUDIT AND MONITORING

Periodically, the Institution's Compliance Officer shall audit the Institutions' compliance with this policy and report the results of such audit to the Board of Directors.

TRAINING

The Institution’s Compliance Officer shall coordinate with senior management to ensure appropriate training to new and existing employees.

RECORD RETENTION

The Institution will comply with the retention requirements set forth in the applicable regulations.