Privacy, Terms of Use, & Patriot Act

GUARDHILL FINANCIAL CORP.

Customer Privacy Policy

Introduction and Applicability

This policy is adopted pursuant to Title V of the Gramm Leach Bliley Act of 1999 and applicable federal laws and regulations. Asused in this policy, the terms "we", "us", and "our" refer to GuardHill Financial Corp.

This policy applies only to personally identifiable financial information (also known as nonpublic personal information) obtainedby us in connection with financial products and services primarily for personal, family or household purposes (and not businesspurposes). We do not provide information to companies for the purpose of independent telemarketing or direct mail marketing ofany products or services of those companies.

This policy takes precedence over any previous privacy policies issued by us. We reserve the right to change this policy at anytime with notice as may be required under applicable law. The standards contained in this policy do not constitute a contract orcreate legal rights.

Information we collect

We collect nonpublic personal information about our customers from the following sources:

• Information we receive from our customers on applications and other forms;
• Information about our customers¹ transactions with us or other persons who are not members of our corporate family ("non-affiliates");
• Information we receive from a consumer reporting agency (e.g., credit bureaus and others); and Information we receive from our customers by e-mail.

We may disclose the nonpublic personal information we collect about our customers to nonaffiliates, as permitted or required bylaw.

We may disclose nonpublic personal information received from our customers on applications and other forms, such as the customer¹sname and address, to nonaffiliated companies that perform marketing services on our behalf with regard to our own products orservices.

We also may disclose nonpublic information about our customers to nonaffiliated financial institutions with which we have jointmarketing arrangements or to companies with which we have outside service provider arrangements, as follows:

• Joint marketing providers: From time to time, we may carefully select joint marketing providers to offer our customers specialized financialservices, such as mortgage life insurance. If appropriate, we may disclose to these providers information received from ourcustomers on applications or other forms, such as the customer¹s name and address.
• Outside service providers: From time to time, we may enter into arrangements with companies or firms whose expertise is essential for our own services to function properly or to complete transactions. For example, we may work with specialized firms that generate disclosures and forms that we provide to our customers. As permitted by law, we disclose to these service providers the customer information that is necessary to perform these functions. These marketing companies and joint marketing and outside service providers are required by us to enter into written agreements with us to safeguard the confidentiality of our customers¹ nonpublic personal information and use it only for authorized purposes. We do not disclose any nonpublic personal information about our customers that otherwise would require us to notify our customers of their right to direct us not to share such information (i.e., opt out right).

Safeguards

We restrict access to our customers' nonpublic personal information to our employees, agents or other similar persons who need to know that information to provide products and services to our customers.

We have established security procedures with regard to physical, electronic and procedural safeguards that comply with federal standards to protect our customers' nonpublic personal information. We will continue to prudently enhance and manage information security standards and procedures to ensure the security and confidentiality of customer information; protect against any unanticipated threats or hazards to the security or integrity of such information; and, protect against unauthorized access or use of our customers' information.

Patriot Act Compliance

GuardHill Financial Corp. has created this Patriot Act compliance statement in order to demonstrate our firm commitment to the Patriot Act and homeland security. The following discloses our information gathering and dissemination practices for www.guardhill.com relative to this act.To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions obtain, verify, and record information that identifies each person who requests a loan. The Act requires all financial institutions to maintain records of the identification verification and periodically update this information. Confidentiality of the information obtained by GuardHill Financial Corp. will be maintained as required by this act.

The following information will be recorded as required by this act: your name, mailing and residence address, tax identification number, date of birth, copy of drivers license or other government issued photo ID.