It is Ocean Systems’ formal policy to adhere to the requirements and guidelines of federal Regulation P, Privacy of Consumer Financial Information, as part of the Gramm-Leach-Bliley Act of the U.S. Legislature as it relates to maintaining the confidentiality of customer records, when and if, its staff and/or contract personnel are exposed to such records during the course of:

• Software installation
• System upgrades or enhancements
• Employee/user training at a financial institution
• Problem resolution

Ocean Systems’ employees or contractors will not share, copy or print customer information records unless specifically requested by a client or financial institution. In such instances, the bank will maintain all customer records. Ocean Systems personnel will not remove such customer information from the client’s premises.