privacy

2009 Annual Privacy Notice

Smithfield Trust Company is required to issue an “Annual Privacy Disclosure”; however, we feel it is redundant in light of our strict adherence to confidentiality which we discussed with you when you became our customer. In any event, listed below are a few privacy issues which are important to our relationship with you:

All information about you, your family and your financial affairs is maintained in strictest confidence and used internally only by those individuals providing service to your accounts.

Certain third parties which assist Smithfield in the management of your accounts are provided information necessary to their specific roles. An example of such third parties is SunGard Trust Systems, which provides our trust accounting software and prepares our customer statements and tax information, and the various independent investment managers we may use for your accounts from time to time.

Smithfield Trust Company never has and never will sell, share or otherwise disclose information about you to unrelated third parties for their use in selling products or services to you.

We will provide information about you to unrelated third parties only as you direct us in order to assist you in obtaining a product or service (such as a mortgage or line of credit) not available at Smithfield.

We will disclose information about you if legally required to do so by court order, subpoena or federal, state or local laws. If so mandated, however, we will advise you of that action and the legal necessity for the disclosure.