Berkshire Bank
Asset Management/Trust Group

Berkshire Bank recognizes the importance of protecting your personal and financial information. We are providing you with this important notice to inform you of how Berkshire Bank's Asset Management/Trust Group uses and protects the confidential information of our fiduciary and investment clients. As a Fiduciary, we need to protect you given our duty of loyalty, the prudent administration of your financial affairs and the relationship we hold as your fiduciary.

TYPES OF INFORMATION WE COLLECT

The type of nonpublic personal information we collect depends on the type of product or service you obtain from us. "Nonpublic personal information" is information about you, which is not available from public sources, and is obtained in connection with providing you with a financial product or service. For example, nonpublic personal information includes information regarding your account balance, payment history, and deposit account activity. We may collect this personal information from the following sources:

• Information we receive from you on applications, trade instructions, or other forms you may complete and provide to us, such as your name, address, social security number, assets, income and, in the case of applications for insurance, your health and medical information.
• Information about your transactions with us, with members of other Berkshire Bank companies or others, such as your account balance, payment history, and products and services used.
• Information we obtain from your tax returns, securities trading, estate and trust planning documents and other sources used in administering your account.
• Information we may receive from firms, such as accountants, attorneys, mutual fund companies, securities firms and brokerage firms that assist us in administering your account and processing transactions on your behalf.

HOW WE USE YOUR NONPUBLIC PERSONAL INFORMATION

We do not disclose nonpublic person information about our clients, former clients or prospective clients except as permitted by law. As described below, we disclose nonpublic personal information when needed to complete transactions at your request or to make you aware of related financial products and services that we offer. Here are the details:

• In order to complete certain transactions or account changes that you direct, it may be necessary to provide identifying information to companies, individuals, or groups that are not affiliated with Berkshire Bank. For example, we may disclose some or all of the information we collect if you ask us to process a securities transaction, provide tax services or other banking transactions
• In order to alert you to other financial products and services that Berkshire Bank offers or sponsors, we may share your information within the Berkshire Bank affiliated companies. This would include, for example, sharing your information within Berkshire Bank to make you aware of new products and services being offered.
• In certain instances, we may contract with "nonaffiliated third parties" to perform services for us. For example, we will disclose information we have about you to third parties in order to provide you with custodial, fund accounting, administrative and other related services. We may share your nonpublic personal information with nonaffiliated third parties to improve our services, to make our procedures more efficient or to implement security measures. In all such cases, we provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose. And, we require these third parties to treat your private information with the same high degree of confidentiality that we do.
• On occasion, we may disclose all of the information we collect as described above, except health information, to government entities as required by law, to our regulators and auditors, or to anyone in response to subpoenas. We will not disclose any nonpublic personal information about you to any other third parties, except as permitted by law.

We will also provide nonpublic personal information to affiliates and other parties if you request us to do so or you give us your permission. If you decide to close your accounts(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.

SAFEGUARDING YOUR PERSONAL INFORMATION

We restrict access to our client's nonpublic personal information to those employees who have a need to know that information as part of their job to service your account or to provide products and services to you. To protect the security and confidentiality of your personal information, we maintain physical, electronic and/or procedural safeguards that meet or exceed the standards of applicable laws and regulations that are reasonably designed to guard your nonpublic personal information.

ACCURACY OF CUSTOMER INFORMATION

We recognize that the accuracy of your personal and account information is critical to you and to that end we have internal controls to keep customer information as accurate and complete as we can. If you believe that any information about you is not accurate, please let us know. Contact us at

Berkshire Bank Asset Management/Trust Group
PO Box 1308
Pittsfield, MA 01202-1308

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