Protecting Your Privacy
Harris SBSB recognizes that safeguarding personal and financial information about our clients is an essential commitment we make and trust we hold. In this regard, we have adopted certain policies and procedures concerning the use of personal and financial information about our clients. These policies and procedures govern the activities of our officers, directors and employees and strictly limit our ability to use or distribute personal and financial information about you. This Privacy Policy Notice outlines those policies and procedures.

Collection of Information
We may receive personal and financial information about you from the following sources:

• Information you provide us on applications or other forms or which may be publicly available (this includes your name, address, social security number, assets and income);
• Information to verify the information you provide us at the time you open an account
• Information you direct or authorize us to obtain from third-parties such as advisers or custodians (including investment, legal, insurance or other financial advisers, or brokerage houses, banks or asset custodians);
• Information you give us orally; and
• Information about your financial transactions with us (such as your account balance, usage or loan history) or others.

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT: To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

Sharing Information With Affiliate Financial Services Companies
We may share information about you with our affiliated financial service companies, such as our affiliated banks, our affiliated brokerage company and other affiliated financial services companies, as reasonably needed to provide you with the investment, tax, insurance and other financial services that you have engaged us to perform, or to otherwise to identify services which may serve your financial, investment or planning objectives. However, in all such instances, we restrict access to your personal and financial information to those employees who have a reasonable need to know that information to provide or identify such services to you.

Opt Out of Sharing Certain Information with Affiliated Financial Services Companies
As an individual you have the right to instruct us not to share among our affiliated financial service companies certain information from your account applications or information received from third parties (other than information about your transactions or experiences with us). Please call us at 1-888-727-2443 or notify your Financial Advisor at Harris SBSB if you would like us to limit the sharing of this other information.

If you are a resident of Vermont we will not share this other information among our affiliated financial service companies without your authorization. Please call us at 1-888-727-2443 or notify your Financial Advisor at Harris SBSB if you authorize the sharing of this other information.

If you have previously contacted us regarding your request, you do not need to contact us again. Your request not to share this information will apply to all of your accounts with us including any new account you open after your original request. If two or more customers jointly own an account or obtain a service, the request not to share information will apply only to the customer making the request unless otherwise directed by you.

Limiting Marketing from Affiliated Financial Services Companies
Federal law gives you the right to limit some but not all marketing from our affiliated financial services companies. Federal law also requires us to give you this notice to tell you about your choice to limit marketing from the Harris family of companies.

You may limit our affiliated financial services companies, such as our banks, brokerage, insurance or investment advisory affiliates, from marketing their products or services to you based on personal information about you that they may receive from us. This information includes your income and your account history. Your choice to limit marketing will apply until you tell us to change your choice.

To limit marketing offers, please contact us at 1-888-727-2443 or contact your Financial Advisor, so that we may process this request for you.

Please note that this does not prohibit our affiliated financial services companies with whom you have an established business relationship from marketing their products and services to you unless you have requested that your name, address, email address and phone number be excluded from marketing lists.

Your request to limit marketing from affiliate financial services companies will apply to all of your accounts with us including any new account you open after your original request. If two or more customers jointly own an account or obtain a service, the request not to share information for marketing will apply only to the customer making the request unless otherwise directed by you.

Information Sharing With Unaffiliated Third Parties Is Permitted By Law
From time to time, we may also provide information to unaffiliated third parties (such as brokers, other financial, legal, insurance or investment advisers, or custodians) to complete a transaction you have requested, to help us service your account or as specifically authorized or requested by you or your agent. However, any such disclosure not specifically authorized or requested by you will only be as permitted by law and only as reasonably necessary for Harris SBSB or such third parties to provide the agreed services to you. All companies with whom we do business are contractually obligated to comply with strict standards regarding security and confidentiality, and the information can be used for the sole purpose of providing the service we have requested the company to perform.

Sharing Information In Other Situations
We may also disclose information about you as required by law, or regulatory or government authorities, such as when we respond to a subpoena or other legal process. When responding to a subpoena or other legal process, we will provide you with any required notice and, whenever practicable, we will discuss our response with you.

Keeping Information Safe and Accurate
We limit access to information we have about you to those employees who have a reasonable need to know to provide you with services to help you meet your financial needs. We maintain physical, electronic and procedural internal safeguards that comply with federal laws and regulations to guard the information we have about you.

An Ongoing Commitment To Your Privacy
We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to end your relationship with us, you will continue to be protected by the privacy policies and principles described in this policy or any future amendments to this policy.

Other Ways to Protect Your Privacy
There are several things you can do to protect yourself and your family from identity theft and related crimes. Helpful tips can be found on the Federal Trade Commission’s Identity Theft website at www.consumer.gov/idtheft/ or by calling 1-877-IDTHEFT. This website also provides you with important information on what you should do if you believe you are a victim of identity theft. If you have been a victim of identity theft, please contact us so that we can assist you with any issues related to your accounts with Harris.

This Notice Does Not Expand Legal Obligations.

This Notice is not intended to create any liability other than that already found in law.

This Policy is effective as of July 1, 2008. To review the most current version of our privacy policy, please visit our website at www.harris-sbsbinc.com and click on the link for "Privacy".

Harris SBSB™ is a trade name used by Sullivan, Bruyette, Speros & Blayney, Inc., and SEC-registered investment advisor.