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PRIVACY STANDARDS AGREEMENT

Protecting your privacy is important to CodeFi Solutions, LLC and our employees. We want you to understand what information we collect and how we use it. In order to provide our customers with a broad range of risk mitigation products and services as effectively and conveniently as possible, we use technology to manage and maintain customer information. The following policy serves as a standard for all CodeFi Solutions employees for collection, use, retention, and security of nonpublic personal information.

Compliance

CodeFi Solutions, LLC acknowledges that all information and documents disclosed by your institution to CodeFi Solutions, or which come to CodeFi Solutions’ attention during the course of its performance of Services under this Agreement, constitute valuable assets of and are proprietary to your institution, and also acknowledges that your institution has a responsibility to its customers and employees to keep institutional records and information confidential and proprietary. Therefore, CodeFi Solutions agrees not to disclose, either directly or indirectly, to any person, firm or corporation information of any kind, nature or description concerning matters
affecting or relating to the business of your institution unless the information is already in the public domain. This provision shall survive termination of this Agreement.

What Information We Collect

CodeFi Solutions does not actively collect “nonpublic personal information”. The institution that has engaged in agreement with CodeFi Solutions for the use of Presidium Solutions Real Estate Loan Administration and Management Software is solely responsible for the review, collection, input, and management of data.

What Information We Disclose

CodeFi Solutions does not actively disclose “nonpublic personal information”. When required by law to furnish data, such as in response to a subpoena, we provide written notice. If you decide to terminate your agreement or become an inactive customer, we will continue to adhere to theprivacy policies and practices described in this notice.

Our Security Procedures

CodeFi Solutions takes steps to safeguard customer information. We restrict access to your institution’s and subsequent client’s personal and account information to those employees who need to know that information to provide products or services to you. Employees who violate these standards will be subject to disciplinary measures. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.