Santa Barbara Bank & Trust, First National Bank of Central California, South Valley National Bank, San Benito Bank, Pacific Capital Bank, First Bank of San Luis Obispo, and Santa Barbara Bank & Trust Private Wealth Management are divisions of Pacific Capital Bank, N.A. and are not separate, independent banks (the "banks"). All of these banks are bound by this Privacy Policy and share our commitment to safeguarding your financial privacy.

We are committed to protecting the Confidential Information you entrust to us. We carefully manage that information to provide you with high quality financial products and services. We never sell your customer information to non-affiliated third parties and we never share your customer information with non-affiliated third parties who may wish to market their products to you.

The federal financial privacy law requires us to provide you with this statement, and we welcome the opportunity to share with you the steps we take to ensure the confidentiality and security of your information.

In this Policy statement, Confidential Information means non-public personally identifiable information about a consumer and the consumer's current or former relationship with any of our banks.

Protecting Your Confidential Information

We take seriously our obligation to safeguard your Confidential Information. All our employees are bound by a formal Code of Ethics emphasizing their responsibility to maintain the privacy and confidentiality of your information. In addition, we provide training programs to educate our employees about their responsibilities under our Privacy Policy.

We also maintain physical, electronic, and procedural safeguards to ensure the confidentiality of your information. We monitor new technology and upgrade our systems as needed to best protect your information.

Protecting Disclosure of Information to Non-Affiliated Non-Financial Third Parties

We never sell Confidential Information to others. Except in limited circumstances permitted by law, we will never disclose Confidential Information to non-affiliated, non-financial third parties without securing your prior consent.

Using Confidential Information to Serve You

We gather and use Confidential Information in the course of providing you with financial products and services. For example, if you maintain a checking account with us, we keep a record of deposits and withdrawals from your account so that we can calculate your account balance, and we use your name and address to send you a monthly account statement.

Collecting Information

We may gather Confidential Information from the following sources:

• Information you provide on applications and through other forms, such as your name, address, social security number, and income.
• Information based on your transactions and account experience with our other banks (explained below), such as account balances, and payment or overdraft history.
• Information from a consumer report, such as your creditworthiness and credit history.

Sharing Information Within Our Banks And With Our Subsidiary Investment Advisers

In order to better provide you with the products and services you may need, our banks may share Confidential Information with each other. This may include consumer lenders and mortgage lenders. All of our banks are bound by this Privacy Policy and committed to protecting your Confidential Information.

In addition, our banks may share Confidential Information regarding our transactions or experiences with you (e.g., account balances, payment or overdraft history) with Morton Capital Management ("MCM") and R.E. Wacker Associates, Inc. ("REWA"), wholly owned subsidiaries of our banks and SEC registered investment advisers.

We also may share other Confidential Information we obtain about you with MCM and REWA (e.g., information from applications and consumer reports), which is referred to as "other information" in this Policy, unless you notify us before the other information is initially communicated to them that you do not want us to share that information. In addition, you may limit MCM and REWA from using your transaction, experience or other information that we share with them to market their products and services to you. Your choice to limit marketing offers from MCM and REWA will apply until you tell us to change your choice.

You can tell us not to share other information with MCM and REWA, and you can limit MCM and REWA from making marketing offers using transaction, experience or other information, by calling us at:

Santa Barbara Bank & Trust or Pacific Capital Wealth Management Services
1-888-400-7228

First National Bank, South Valley National Bank, or San Benito Bank
1-800-495-7100

First Bank of San Luis Obispo
1-866-733-2756

MCM and REWA likewise have adopted their own Privacy Policies covering your Confidential Information they receive from you.

Sharing Information With Companies Working For Us

We may disclose Confidential Information to other companies that work for us or perform services for us. These companies help us deliver our financial products and services to you. For example, these companies may assist us in processing your transactions, printing checks for your accounts, or mailing account statements. We require these companies to adhere to strict privacy and confidentiality standards through their contracts with us. We never share information with nonaffiliated third parties to market their products.

Sharing Information with Companies Under a Joint Marketing or Servicing Agreement

We may partner with other companies under a joint marketing or servicing agreement to offer you expanded products and services, such as securities, credit cards or life insurance. Before we share Confidential Information with any of these companies, we require that they agree in writing to adhere to strict privacy and confidentiality standards to protect your information and limit its use to the business purpose of our agreement with them. California state law provides additional privacy protections for California residents with regard to sharing information with other companies for marketing purposes. A separate Consumer Rights Notice will be provided to California residents regarding their privacy options.

Disclosing Information as Permitted by Law

We may also disclose Confidential Information with your consent or as otherwise permitted by law. For example, this may include disclosure to a credit-reporting agency or in response to a subpoena or other legal process. It may also include disclosure to protect against fraud, as part of an audit or examination.

We do not share Confidential Information about former customers, except as permitted by law.

Fiduciary Information

When we act as fiduciary or trustee, your fiduciary information is subject to even more stringent limits on information sharing, both within and outside our banks. Please contact your Personal Trust Officer if you have any questions about the protection of your fiduciary information.

Let Us Answer Your Questions

We hope the information in this Privacy Policy is helpful to you. As long as you are a customer with any of our banks, you will receive an updated copy of our Privacy Policy on an annual basis. In the meantime, if you have any questions or concerns about our Policy and practices please feel free to call or visit us at any of our branches.