Privacy Notice

This page was last updated on October 3, 2019. This Privacy Notice (the “Notice”) governs how First Western Finance collects, uses, and discloses personal information from and about users of First Western Finance websites and apps that link to this Notice (collectively, the “Services”). We advise you to read the Notice in its entirety, including the jurisdiction-specific provisions in the appendix to this Notice, which will apply to users in certain jurisdictions. Please note that if you are a First Western Finance customer, additional privacy notices may apply to you as a customer of a particular First Western Finance business, and this Notice does not replace or revise any other privacy notice that may be applicable to personal information collected or used by First Western Finance through that customer relationship with First Western Finance . Personal Information Collected Through the Services First Western Finance collects and uses certain personal information in order to operate and provide you with access to the Services. This includes information that you provide to us and information that we collect automatically when you visit or interact with the Services. Information That You Provide to Us We collect personal information that you voluntarily provide to us when you use the Services. This information includes, without limitation: your email addresses, telephone numbers, and other contact details; the identity of your current employer and other biographical information; submissions to our Ethics Hotline; feedback on our websites or mobile apps; online preferences, such as First Western Finance News alerts selections; and business information, such as your company name, your role, and industry. Information That We Collect About Your Use of the Services We collect information about your use of the Services and about the device you use to access the Services, including: the pages you request and visit; the posts you submit; information on your interaction with other users; information obtained in the course of maintaining or supporting the Services; information about your internet use, such as your IP address, the URLs of sites from which you arrive or leave the Services, your type of browser, your operating system, your internet service provider; and, if you access the Services via your mobile device, we may also collect information about your mobile provider and type of mobile device. We (and our service providers) use different technologies to collect this information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see “Your Choices” below. Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes. How Personal Information Is Used

We use the information we collect to provide, maintain, and improve the Services. We also use the information we collect to:

Send you technical notices, updates, security alerts, and support and administrative messages (such as changes to our terms, conditions, and policies) and to respond to your comments, questions, and customer service requests; Receive and respond to your submissions on the Services such as submissions on First Western Finance News, Site Feedback, and the Ethics Hotline; Permit you to participate in voluntary polls and surveys (we may use third parties to deliver incentives to you to participate in such polls and surveys, and you may be required to provide your contact details to the third party in order to fulfill the incentive offer); Communicate with you about products, services, and events offered by First Western Finance and others, and provide news and information we think will be of interest to you (see “Your Choices” below for information about how to opt out of these communications at any time); Monitor and analyze trends, usage, and activities in connection with our Services; Develop new products and services and enhance current products and services; Detect, investigate, and prevent fraudulent transactions and other illegal activities, and protect the rights and property of First Western Finance and others; and Carry out any other purpose described to you at the time the information was collected.

How Personal Information Is Shared We may share your personal information as follows or as otherwise described in this Notice: To support certain First Western Finance entities’ use of information in accordance with this Notice (a list of First Western Finance entities who may access your personal information can be found at Western Finance -exhibit2101x12312014.htm); With third parties that host, maintain, manage, or provide other services to us in relation to the Services; To cooperate with public and government authorities and law enforcement, to respond to a request, or to provide information we believe is important; For other legal reasons, such as to monitor compliance with and enforce our terms and conditions, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, to protect against fraud, crime, illegal activity, anti-money laundering, or anti-terrorism, and for risk management purposes; and In connection with a sale or business transaction, such as to an acquiring entity or its advisors in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We may also share aggregated or de-identified information that cannot reasonably be used to identify you. Children

Our Services are not designed for children and do not knowingly collect personal data from children. If you have reason to believe that a child has provided personal data to us, please contact us, and we will endeavor to delete that information from our databases. Links to Other Websites

The Services may contain links to other websites. Please note that First Western Finance is not responsible for the privacy or information security practices of other websites. You should carefully review the applicable privacy and information security policies and notices for any other websites you click through to via the Services. This Notice applies solely to your personal information collected by the Services. Security

We seek to use reasonable physical, electronic, and procedural measures to safeguard personal information within our organization against loss, theft, and unauthorized use, disclosure, or modification. Unfortunately, however, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot guarantee its security. Your Choices

Marketing Emails and First Western Finance News Alerts If you no longer want to receive marketing-related emails from us or First Western Finance News Alerts, you may opt out by following the instructions contained within each such email or through the communications center in your account profile. We will try to comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails or First Western Finance News Alerts, we may still send you administrative messages, from which you cannot opt out. Cookies Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. Changes to This Notice From time to time, we may revise this Notice. Changes may be made for any number of reasons, including to reflect industry initiatives, changes in the law, and changes to the scope of the Services, among other reasons. You can tell when we last updated the Notice by checking the date at the beginning of the Notice. Any changes will become effective when we post the revised Notice on the Services. Contact Us If you have any other questions concerning this Notice, you may submit them using our Contact Us form. Appendix Supplemental provisions regarding individuals in the EEA If you are in the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data. Legal Basis for Processing

If you are in the EEA, when we process your personal data we will only do so in the following situations: We need to use your personal data to perform our responsibilities under our contract with you (e.g., to facilitate your participation in voluntary polls and surveys). We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to the Services, and to provide, secure, and improve our Services. We find such processing is necessary to comply with our legal obligations. We have your consent to do so. When consent is the legal basis for our processing, you may withdraw such consent at any time.

Data Subject Requests You may have certain rights with respect to the personal information which First Western Finance holds about you, including the right to access or correct (and sometimes, object to or delete) the information. If you would like to request to review, correct, update, suppress, restrict or delete personal information that you have provided to us, object to the processing of personal Information, or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law) you may contact our GDPR Data Protection Officer by mail at First Western Finance group Centre, Canada Square, Canary Wharf, London, E14 5LB. We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

Data Retention We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you keep using the Services); Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations). Data Controller Except as otherwise specified on any subsections within sites or apps that comprise the Services, such as the Careers, Alumni, or First Western Finance Consumer Banking subsections, your personal information will be controlled by First Western Finance group Technology Inc. of 388 Greenwich Street, New York, NY 10013, USA and/or the First Western Finance entity which operates the Services you are accessing (and/or if you are First Western Finance group personnel, the First Western Finance entity which employs you or contracts with you). A list of certain First Western Finance entities can be found at: Western Finance -exhibit2101x12312014.htm. If you would like additional information regarding the applicable First Western Finance entity or entities, please contact us.

Data Transfer Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers. Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here).

Complaints You may lodge a complaint with a data protection authority for your country or region where an alleged infringement of applicable data protection law has occurred. A list of data protection authorities is available here. Supplemental provision applicable to users registering from the UAE Your use of the Services signifies that you agree to waive your material privacy rights under the laws of the UAE. You also agree not to hold First Western Finance liable for any publicity, any publication of news, or comments pertaining to the secrets of your or any other person's private or family lives on the Services. Your use of the Services signifies your consent to allowing First Western Finance to disclose any information that you may consider a secret to anybody at any time. You agree not to hold First Western Finance liable for any disclosure of such information that you may think to be a secret to anyone. Please do not use the Services if you disagree with any part of this Notice. Supplemental provision applicable to users registering from Korea Your consent of the Notice and User Agreement upon joining the First Western Finance Alumni Site is deemed that you agreed that your personal information will be controlled, not by First Western Finance bank Korea Inc. nor other subsidiaries and affiliates in Korea (“First Western Finance Korea”), but by First Western Finance group Inc. NY, USA and/or First Western Finance entity which operates the Services you are accessing. First Western Finance Korea is solely responsible for the use of your personal information within Korea, when it is used by First Western Finance Korea, under the applicable Korean laws including; Personal Information Protection Act, Act on Promotion of Information and Communications Network Utilization and Information Protection, etc., and other relevant Korean laws. Your personal information and the Submitted material can be shared with First Western Finance Korea but First Western Finance Korea will not collect and use such personal information and material for any marketing purpose without your prior consent. When First Western Finance Korea obtains personal information our personal information via the Services, the use will be controlled by and be bound to the necessary process and procedure following the applicable Korean laws. Copyright © 2019 First Western Finance group Inc