CUSTOMER INFORMATION & PRIVACY POLICY

West Alabama Bank & Trust is committed to protecting the privacy of its customers' information. As part of our commitment to protecting our customers' privacy we have adopted the following privacy principles endorsed by the Banking industry and have implemented them at all levels of our organization.

Our Customers Expect Privacy
At West Alabama Bank & Trust, we believe the confidentiality and protection of customer information is one of our fundamental responsibilities. Your personal and financial affairs will be held in the strictest confidence. While information is critical to providing quality service, we recognize that one of our most important assets is ours customers' trust. We take this responsibility seriously and we will strive to maintain standards to ensure that your information is private and secure at all times. If you have any questions about how West Alabama Bank & Trust protects your confidential information, please call the Privacy Officer at (205) 375-9551, ext. 229.

Why We Collect, Retain, and Use Customer Information
We collect, retain, and use information about you only where we believe it will help administer our business or provide products, services and opportunities to you.

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications and other forms;
• Information about your transactions with us, our affiliates, or others; and
• Information we receive from a consumer-reporting agency.

We collect and retain information about you only for specific business purposes, and we will tell you why we are collecting and retaining it upon your request. We use information:

• To protect and administer your records, accounts and funds;
• To comply with certain laws and regulations;
• To help us design and improve our products and services; and
• To understand your financial needs in order to provide you the best quality products and superior service.

We Will Maintain Accurate Information
West Alabama Bank & Trust has established procedures to ensure that your financial information is accurate, current and complete in keeping with reasonable commercial standards. Should you find inaccurate or incomplete information about you in our records, please notify us. We will investigate your concerns and correct any inaccuracies in a timely manner.

We Limit Employee Access To Your Information
At West Alabama Bank & Trust access to personally identifiable information about you is limited to those employees who have a specific business reason to know such information. Our employees are educated and trained on the importance of maintaining the confidentiality of customer information and on this Privacy Policy. Because of the importance of these issues, all West Alabama Bank & Trust employees are responsible for maintaining the confidentiality of customer information, and employees who violate this Privacy Policy will be subject to disciplinary measures.

Security Procedures Protect Your Information.
West Alabama Bank & Trust is committed to the security of your financial and personal information. All of our operational and data processing systems are in a secure environment that protects your account information from being accessed by third parties. We restrict access to nonpublic information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic information.

The bank has appointed an Information Security Officer to oversee the safeguarding of our customer information and has developed an Information Privacy Program.

We have identified and ranked sensitive customer information sources and performed a risk assessment process to identify those sources.

We have identified and established internal controls to limit threats to customer information. We continually monitor the banks information security system to identify any weaknesses or breaches and have assigned the Security Officer the responsibility for this monitoring. The Information Security Officer shall report periodically to the Board of Directors concerning the effectiveness of the bank's Information Security Program.

Annual audits will be conducted and bank personnel will be provided periodic training in the banks efforts to continually safeguard customer information.

We Restrict Disclosure of Account Information
When it comes to sharing customer and former customer information with nonaffiliated companies, West Alabama Bank & Trust places strict limits on who receives specific information about customer accounts or other personally identifiable data.

We may disclose the following kind of nonpublic personal information about you:

• Information about your transactions with us, our affiliates or others, such as your account balance, payment history, parties to transactions and credit card usage; and

We may disclose nonpublic personal information about you, our customer or former customer to the following types of third parties:

• Financial service providers, such as mortgage bankers, securities broker-dealers and insurance agents;

We may disclose all of the information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.

West Alabama Bank & Trust may share nonpublic personal information with unaffiliated third parties if:

• The information is provided to help complete a customer-initiated transaction;
• The customer requests or permits it;
• The disclosure is required by or allowed by law (i.e., subpoena, investigation of fraudulent activity, request by regulator, credit bureau, etc.); and
• The customer has been informed about the possibility of disclosure for marketing or similar purposes through a prior communication and has been given the opportunity to decline (opt out).

We Will Not Share Your Information Outside Our Organization
Our standard procedures are designed to protect your confidential information. It is our practice not to share confidential customer information outside our organization, other than what is permitted by law. You do not need to request this Confidentiality - it is our standard practice.

Fair Credit Reporting Act
West Alabama Bank & Trust complies with the Fair Credit Reporting Act Regulation, which applies to the disclosure of consumer reports to affiliates and nonaffiliated third parties. We will not share information with affiliates and nonaffiliated third parties except as permitted by law.

Internet Information
The above policy applies to information gathered over the Internet and disclosure of any information gathered over the Internet will be treated in the same manner as set out in this policy.

Reviewed and Approved 1/2011