Commerce Bancshares, Inc. Privacy Policy Notice

Protecting your privacy is important to Commerce and to our employees. We want you to understand what information we collect and how we use it. In order to provide our customers with a broad range of financial products and services as effectively and conveniently as possible, we use technology to manage and maintain customer information. This policy serves as a standard for all Commerce employees for collection, use, retention, and security of nonpublic personal information.

WHAT INFORMATION WE COLLECT

We collect and use different types of information to service your accounts and to offer you better products and services that best meet your changing needs.

"Nonpublic personal information" is information about you and identified with you that we obtain in connection with providing a financial product or service to you. This is information which is unobtainable from a public source. For example, nonpublic personal information includes information regarding your account balance, payment history, and overdraft history.

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

• Information we receive from you on applications or other loan and account forms;
• Information about your transactions with us, our Affiliates, or others; and
• Information we receive from third parties such as credit bureaus.

REST ASSURED, WE DO NOT SELL YOUR NONPUBLIC PERSONAL INFORMATION TO OTHERS.

NOTE: Protecting the privacy and security of your confidential financial information is our top priority. The FBI has received complaints involving unsolicited e-mails directing consumers to a phony “customer service” Web site or directly asking for customer information. These scams may result in identity theft, credit card fraud, or other fraudulent financial schemes. Commerce Bank offers secure e-mail for personal questions, requests, and information through an Online Banking account. If you suspect that the security of your accounts has been compromised due to information you've disclosed, please contact our Customer Care Center at 1-800-453-2265.

HOW WE PROTECT YOUR INFORMATION

We restrict access to your nonpublic personal information to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and/or procedural safeguards that comply with federal standards to guard your nonpublic personal information.

WHAT INFORMATION WE DISCLOSE

We may disclose nonpublic personal information to companies that work for us and assist us in providing services to you. We may also disclose information as permitted or required by law. Disclosure of information in these circumstances is detailed below:

TO SERVICE PROVIDERS AND FOR JOINT MARKETING:

We may disclose the following information to third parties that provide services that assist us in servicing your loan or account with us, to companies that perform marketing services on our behalf, or to other financial institutions with whom we have joint marketing agreements:

• Information we receive from you on applications or other forms, such as your name, address, social security number, assets, and income;
• Information about transactions with us, our Affiliates, or others, such as your account balance, payment history, parties to transactions, and credit card usage; and
• Information we receive from credit bureaus, such as your creditworthiness and your payment history.

We have strict confidentiality agreements with all outside companies to ensure that they protect your information, and never use it for other purposes.

TO OTHER NON-AFFILIATED THIRD PARTIES:

In addition, in certain circumstances we disclose nonpublic personal information about you to "nonaffiliated third parties" (i.e., third parties that are not members of our corporate family) as permitted by law. For example, we may disclose nonpublic personal information about you to third parties as necessary to process transactions that you have requested or authorized, to government entities in response to subpoenas, and to credit bureaus. We do not disclose any nonpublic personal information about you to any other nonaffiliated third parties, except as permitted by law.

We are also permitted under law to share information about our experiences or transactions with you or your account (such as your account balance and your payment history with us) with our Affiliates. Our Affiliates include Commerce banks, mortgage bankers, broker/dealers and insurance agents. By sharing information about your accounts and relationships among our corporate family we can save you time and money and make it easier for you to do business with us.

INFORMATION ABOUT YOU WE CAN SHARE WITH AFFILIATES - UNLESS YOU TELL US NOT TO

Unless you tell us not to, we also may share the following information about you or your account with our Affiliates:

• Information we obtain from your application, such as your income or marital status;
• Information we obtain from a consumer report, such as your credit score or credit history;
• Information we obtain to verify representations made by you, such as your open lines of credit; and
• Information we obtain from a person regarding its employment, credit, or other relationship with you, such as your employment history.

HOW TO TELL US NOT TO SHARE THIS INFORMATION WITH OUR AFFILIATES

If you prefer you may direct us not to share this information with our Affiliates. If this is your choice, call us toll free at 1-800-543-4845.

Note: Your direction in this paragraph covers certain information about you that we might otherwise share with our corporate family. We may share other information about you with our corporate family as permitted by law.

WHO OUR AFFILIATES ARE

As used in this Privacy Policy Notice, "Commerce" means Commerce Bancshares, Inc. and the members of the Commerce corporate family. Examples of Affiliates include the following financial service providers:

Commerce Bank, N.A.

Commerce Trust Company, a division of Commerce Bank, N.A.

Commerce Brokerage Services, Inc.

Commerce Investment Advisors, Inc.

Commerce Mortgage Corp.

Commerce Insurance Services

CBI Insurance Company

CBI Leasing, Inc.

IF YOU CEASE TO BE OUR CUSTOMER

If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.