At First Niagara Financial Group, we make it our priority to protect the privacy of our customers' non-public personal information. We realize that we must earn and keep the trust of our customers every day, and doing so is a responsibility that we take very seriously. One of the many ways we earn that trust is by maintaining the privacy of our customers' non-public personal information. We recognize that our customers are concerned about the confidentiality and security of their non-public personal information and expect us to obtain, keep, use and protect that information in an appropriate and responsible fashion.

This notice is given on behalf of (and in this notice, the terms "we", "us" and "our" refer separately to) each of the following affiliated companies in the First Niagara Financial Group corporate family (the "First Niagara Family"):

• First Niagara Bank
• First Niagara Securities, Inc.
• First Niagara Risk Management, Inc

This privacy notice applies only to individuals as consumers and not as operators of a business, and it does not apply to corporations and other organizations. As required by federal law, we send our privacy notice to our current consumer customers on an annual basis. This privacy notice replaces all privacy notices previously issued by us and may be amended by us at any time. If we make a material change to our privacy policy, we will provide our current consumer customers with a revised privacy notice that explains our new policy. A copy of our privacy policy is available on request or by visiting our Web site at www.fnfg.com.

We collect non-public personal information about our customers from the following sources:

• Information that we receive from our customers on applications or other forms or in other ways, such as names, addresses and social security numbers.
• Information about our customers' transactions with us, with other companies in the First Niagara Family, or with others, such as account numbers and account balances.
• Information that we receive from consumer reporting agencies, such as credit scores and credit histories.

We do not disclose non-public personal information about our customers to parties outside the First Niagara Family except as allowed by and in accordance with applicable law, including as described in the section entitled "Information That We May Disclose to Service Providers and Joint Marketing Partners". However, we reserve the right to disclose non-public personal information about our customers to parties outside the First Niagara Family for marketing or promotional purposes. If you do not want us to disclose non-public personal information about you to parties outside the First Niagara Family for marketing or promotional purposes, please read the section entitled "How To Tell Us Not To Disclose Or Share Information About You Or Not To Contact You" for instructions.

We may disclose the following kinds of non-public personal information about our customers to companies that perform services on our behalf (for example, check printing and data processing companies) or to other financial institutions with which we have joint marketing agreements:

• Information that we receive from our customers on applications or other forms or in other ways, such as names, addresses and social security numbers.
• Information about our customers' transactions with us, with other companies in the First Niagara Family, or with others, such as account numbers and account balances.
• Information that we receive from consumer reporting agencies, such as credit scores and credit histories.

We disclose non-public personal information about our customers to service providers and joint marketing partners only to the extent necessary for them to perform services on our behalf, and we require them to keep and use that information only as we intend it to be kept and used, and to disclose it only as allowed by and in accordance with applicable law.

We believe that the sharing of non-public personal information about our customers with companies in the First Niagara Family for marketing or promotional purposes enables us to better serve our customers. For example, it allows us to determine our customers' eligibility for products and services offered by the First Niagara Family and to make our customers aware of those products and services. If a customer does not permit us to share his or her non-public personal information within the First Niagara Family for marketing or promotional purposes, it may limit our ability to offer our full array of products and services to that customer. Nevertheless, if you do not want us to share non-public personal information about you within the First Niagara Family for marketing or promotional purposes, please read the section entitled "How To Tell Us Not To Disclose Or Share Information About You Or Not To Contact You" for instructions.

From time to time, we may contact our customers by mail, e-mail or telephone with offers for products or services that we believe may be of interest to our customers. If you do not want us to contact you with offers for products or services (other than by materials included in mailings of account statements), please read the section entitled "How To Tell Us Not To Disclose Or Share Information About You Or Not To Contact You" for instructions.

We do not disclose non-public personal health information about our customers to parties outside the First Niagara Family (including a government agency) or share non-public personal health information about our customers within the First Niagara Family except as authorized by the customer or to perform insurance functions (for example, obtaining an insurance policy for a customer or administering an insurance claim by a customer) as allowed by and in accordance with applicable law.

If you do not want us to: (1) disclose non-public personal information about you to parties outside the First Niagara Family for marketing or promotional purposes; (2) share non-public personal information about you within the First Niagara Family for marketing or promotional purposes; or (3) contact you with offers for products or services (other than by materials included in mailings of account statements), you may direct us not to do so by calling 1-800-421-0004 and speaking to a customer service representative. If you have one or more joint accounts with us, you may request that your direction apply to any or all other persons named on those joint accounts. Please allow approximately 30 days for your direction to take effect. If you previously gave us your direction, you do not need to do so again. Your direction will continue to apply until you call us and change it.

We treat information about our former customers the same as we treat information about our current customers.

We restrict our employees' access to our customers' non-public personal information to employees who have a business reason for accessing that information and who have been trained in the proper handling of that information. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard our customers' non-public personal information.

One of the fastest growing white-collar crimes is identity theft, which occurs when an identity thief gains access to and uses an individual's personal identifying information without the individual's knowledge in order to commit fraud or theft. You can protect your privacy and minimize your risk of becoming a victim of identity theft by taking the following steps:

Personal Identifying Information

• Always protect your personal identifying information (for example, your date of birth, social security number, credit card numbers, bank account numbers, personal identification numbers ("PINs") and passwords).
• Do not give any of your personal identifying information to any person who is not permitted to have access to your accounts.
• Do not give any of your personal identifying information over the telephone, through the mail or online unless you have initiated the contact or know and trust the person or company to whom it is given

Credit, Debit and ATM Cards

• Limit the number of credit, debit and ATM cards that you carry.
• Cancel all cards that you do not use.
• Retain all receipts from card transactions.
• Sign new cards as soon as you receive them.
• Report lost or stolen cards immediately.

Mail

• Promptly remove mail from your mailbox.
• Deposit outgoing mail in a post office collection box, hand it to a postal carrier, or take it to a post office instead of leaving it in your doorway or home mailbox, where it can be stolen.

Credit Reports

• Order a copy of your credit report annually and review it for accuracy.
• Check your credit report for unauthorized bank accounts, credit cards and purchases.
• Look for anything suspicious in the section of your credit report that lists who has received a copy of your credit history.

Bank Account and Credit Card Statements

• Contact your financial institution immediately if a bank account or credit card statement does not arrive on time.
• Review your bank account and credit card statements promptly and immediately report any discrepancy or unauthorized transaction.

Telephone and Internet Solicitations

• Be suspicious of any offer made by telephone, on a Web site or in an e-mail that seems too good to be true.
• Before responding to a telephone or Internet offer, determine if the person or business making the offer is legitimate.
• Do not respond to an unsolicited e-mail that promises some benefit but requests personal identifying information.
• First Niagara never requests a customer's bank card number, account number, social security number, personal identification number or password through e-mail. If you should receive an e-mail requesting such information that appears to be from First Niagara, do not respond to the e-mail and contact First Niagara immediately at 1-800-421-0004.

Home Security

• Store extra checks, credit cards, documents that list your social security number, and similar items in a safe place.
• Shred all credit card receipts and solicitations, ATM receipts, bank account and credit card statements, canceled checks, and other financial documents before you throw them away.

PINs and Passwords

• Memorize your PINs and passwords and keep them confidential.
• Change your passwords periodically.
• Avoid selecting PINs and passwords that will be easy for an identity thief to figure out.
• Do not carry PINs and passwords in your wallet or purse or keep them near your checkbook, credit cards, debit cards or ATM cards.

Wallets and Purses

• Do not carry more checks, credit cards, debit cards, ATM cards and other bank items in your wallet or purse than you really expect to need.
• Do not carry your social security number in your wallet or purse.

Miscellaneous

• Use common sense and be suspicious when things do not seem right.
• Be suspicious of any proposed transaction that requires you to send an advance payment or deposit by wire transfer.
• Call us immediately at 1-800-421-0004 if you believe that you are a victim of identity theft involving one of your First Niagara accounts.