Privacy Statement - Citi Alumni Network

Citi collects and may use certain Personal Information about You in order to operate and provide you with access to the Website and provide the Services.

1. Required Information For Account Creation and Registration. 
   
   If you are eligible and decide to register to use the Website, You will be required to provide the following information in order to create an account:  name, address, time zone, email address, Citi Id and Citi employment information (last job at Citi), communications options/permission to contact, and password. Without this information, You will not be able to register or use the Website.
2. Use of the Services.  By using the Services, You agree that we may collect other Personal Information about You, including but not limited to, the following:
1. Personal Information that You may voluntarily provide if you complete your profile on the Website (including, without limitation, your email addresses, your telephone numbers, other contact details, the identity of your current employer and other biographical information)  or You submit material through the Website. Please do not include in your Submitted Materials or elsewhere on the Website any financial or sensitive information about You or any other person (including but not limited to social security numbers or other government issued identification numbers, information about Your or any other individual's religious, confessional or similar beliefs, racial or ethnic origin, physical, physiological or mental health or sexual life, sexual orientation, genetic code, addictions, political affiliation or political party membership, trade union membership or information about criminal offenses or any other categories of personal information defined as sensitive under applicable data protection laws);
2. information about Your usage of the Website (e.g., the pages You request and visit, the posts You submit, and Your interaction with other Users and the Website);
3. information obtained in the course of maintaining or supporting the Website; and information about your internet use, such as Your IP address, the URLs of sites from which You arrive or leave the Website, Your type of browser, Your operating system, Your internet service provider (ISP) and, if You access the Website via your mobile device, we may also collect information about Your mobile provider and type of mobile device.
3. Minors.  Children are not eligible to use the Services. We ask that minors (under the age of 18 or the age of majority in Your country if this is higher) do not submit any Personal Information to Us or use the Services.

Your Personal Information will be controlled by Citibank N.A. and/or the Citi entity which operates the Website You are accessing (and/or if You are Citigroup Personnel, the Citi entity which employs You or contracts with You). A list of certain Citi entities can be found at: http://www.sec.gov/Archives/edgar/data/831001/000083100115000043/citi-exhibit2101x12312014.htm. If You would like additional information regarding the applicable Citi entity or entities, please contact alumni@citi.com.

If You submit any Personal Information to the Website and it is posted, Your user name and any other Personal Information contained in Your Submitted Material will be visible and publicly available to authorized Citi Personnel who administer or maintain the Site ("Authorized Citigroup Personnel") and, if you grant access to such Personal Information, to other Users who are registered with the Website ("Registered Alumni Users"). Citi is not responsible for the Personal Information You choose to submit to this Website and, by providing such Personal Information, You are agreeing that it may be freely copied and used (or reused) by Citi and others. As such, You should not include any Personal Information in Your Submitted Materials (other than Your user name which will appear automatically) that You do not want to be used in this manner.

A cookie is a piece of data stored on Your hard drive containing information about You. We may use unique identifiers such as cookies and similar technologies to collect from you: browser, device information and browsing information such as time spent on the Website, pages visited, language preferences, and other traffic data. These cookies may contain or reflect segment or other interest-based data in a de-identified form including interests across other sites. We may also collect from you various attributes associated with your device (such as IP address, installed fonts, language and browser settings, and time zone) in order to create a device fingerprint or identifier so that we can recognize your device.

You have the ability to accept or decline cookies by modifying the settings in Your browser. However, You may not be able to use all the features of the Website if cookies are disabled.

We occasionally use third party companies to set cookies on our websites and gather cookie information on our behalf. In some cases, We will also use another company to operate web servers for our sites. We use the cookie information gathered by these companies in the same manner as stated above. Third parties are prohibited from using these cookies for their own purposes or sharing the information gathered in connection with the cookies with others.

In addition to Content, which is addressed in the Terms, Citi collects certain non-personally identifiable information in connection with Your use of the Website. For example, Citi may collect click stream data, data on how You navigate the Website, and anonymous demographic information. Some of these types of information are also described in Section 1, above. We may use non-personally identifiable information for website administration, analytics, market research, advertising and promotions or any other legitimate business use. We may share such information with various affiliated and unaffiliated entities for such purposes.

Any Personal Information that you submit that is designated by the Website as being accessible through the Directory of Registered Alumni Users' contact information on this Website ("Directory") will be available to Authorized Citigroup Personnel and, if you grant access to such Personal Information in the Directory, to other Registered Alumni Users and Other Citigroup Employees and may be used by any of them to contact you directly for any purpose not specifically prohibited by the Terms, including for any networking, social and business-related purposes.

Any Personal Information that you submit about Yourself for publication on the Website and that is designated by the Website as being accessible through the Directory will be available to all other Registered Alumni Users, Other Citigroup Employees, and Authorized Citigroup Personnel and may be used by any of them for any purpose not specifically prohibited by the Terms. Any Personal Information that You submit about You that is not for publication on the Website and is designated by the Website as not being accessible through the Directory will be available only to Authorized Citigroup Personnel.

We may share your Personal Information with certain Citi entities for their use in accordance with this Privacy Statement. A list of certain Citi entities who may access your Personal Information can be found at:

http://www.sec.gov/Archives/edgar/data/831001/000083100115000043/citi-exhibit2101x12312014.htm

In addition to other uses described herein, Citi will use your Personal Information with your consent and/or when we have a legal obligation or for legitimate business purposes, including:

1. Providing Services, including providing the functionality of the Website and fulfilling your requests.
2. To process your registration and facilitate your participation in the Website and provide you with related customer service.
3. To provide and maintain a Directory of Registered Alumni User contact information.
4. To enable You to communicate with other Registered Alumni Users as well as to enable other social and networking communications.
5. To send administrative information to you, such as changes to our Terms and policies.
6. To 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. You may be required to provide Your contact details to the third party in order to fulfill the incentive offer.)
7. To manage our contractual relationship with you and/or to comply with a legal obligation.
8. To provide you with marketing materials, and to enable communications with You, including providing You with invitations and/or information about:
1. Citi and Citi-sponsored and/or third party-sponsored social and/or business-related events, activities and opportunities;
2. The financial services industry and financial services industry events, activities and opportunities;
3. Citi products and services; and
4. Citi employment opportunities.
9. To offer You Citi services or products, including those that may be made available on or through this Website from time to time.
10. To aggregate, deidentify and/or anonymize Personal Information.  We may aggregate, deidentify and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
11. To accomplish our other business purposes.
12. For data analysis, such as to improve the efficiency of the Services;
13. For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
14. For fraud and security monitoring purposes, such as to detect and prevent cyberattacks or attempts to commit identity theft;
15. For developing new products and services;
16. For enhancing, improving or modifying our current products and services;
17. For identifying usage trends, such as understanding which parts of the Services are of most interest to users;
18. For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
19. For operating and expanding our business activities, such as understanding which parts of the Services are of most interest to our users so we can focus our energies on meeting our users' interests.

We use and disclose your Personal Information with your consent and/or when we have a legal obligation or legitimate interest to do so:

1. To comply with applicable law and regulations. ◦This can include laws outside your country of residence.
2. To cooperate with public and government authorities. ◦To respond to a request or to provide information we believe is important.
1. These can include authorities outside your country of residence.
3. To cooperate with law enforcement. ◦For example, when we respond to law enforcement requests and orders or provide information we believe is important.
4. For other legal reasons.
5. To monitor compliance with and enforce our Terms.
6. To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
7. To protect against fraud, crime, illegal activity, anti-money laundering, anti-terrorism, or for risk management purposes.
8. In connection with a sale or business transaction. ◦We have a legitimate interest in disclosing or transferring your Personal Information to a third party 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). Such third parties may include, for example, an acquiring entity and its advisors.

If Citi appoints third parties to host, maintain, manage, or to provide other services in relation to the Website or the Services, then your Personal Information may be accessed and used by these third parties to the extent necessary to fulfill their hosting, maintenance, managerial, and/or other functions.

The Site is controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. Information about you may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Site, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.

The Website may contain links to other websites. Please note that Citi 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 statements for any other websites to which you click through to via the Website. This Privacy Statement applies solely to Your Personal Information collected by this Website. 

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. 

You are responsible for maintaining the secrecy of Your password and other Website registration information, and for controlling access to Your email communications at all times. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at alumni@citi.com. 

From time to time, We may revise this Privacy Statement. Updates 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 Privacy Statement by checking the "Last Updated" legend at the beginning of the Privacy Statement. Any changes will become effective when we post the revised Privacy Statement on the Website. 

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:

1. The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Website);
2. 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
3. Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

If You no longer wish to participate in the Services, You may contact alumni@citi.com to request that Your profile on this Website be deemed inactive. Even if Your profile data is deemed inactive, Citi may retain your profile data in accordance with applicable law.

Citi will use reasonable efforts to notify You by email before deleting Your profile. If Your profile is deleted, other data and Information that You have included on the Website may still remain on the Website and be visible to other Users.

In certain countries, You may have certain rights with respect to the Personal Information which Citi holds about You, including the right to access or correct (and sometimes, object to or delete) the information.

1. Your California Privacy Rights
   If you are a California resident, you have the right to request and receive certain information about disclosure of your Personal Information to third parties for their direct marketing purposes.  Because it is our policy not to share your Personal Information with third parties for third-party direct marketing purposes without your consent, we are exempt from the requirement to respond to such requests.  If you have any questions related to our policy, please contact us at alumni@citi.com.
   
   For information regarding how to exercise your rights as a consumer under the California Consumer Privacy Act. Please see “Supplemental provisions for California residents” in the Appendix to this Privacy Statement.
2. General Inquiries
   If you are not a California resident and/or the above provisions otherwise do not apply to, please review the procedures in this section.  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), please contact alumni@citi.com. 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.
   
   If you no longer want to receive marketing-related emails from us on a going-forward basis, 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 from us, we may still send you administrative messages, from which you cannot opt out.
3. Do Not Track
   Some browsers have a do not track feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser do not track signals.

Supplemental provision regarding the EEA
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. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as binding corporate rules, to protect your Personal Information. You may obtain a copy of these measures by writing to Dharmisha Kapdee, Compliance Director, at dharmisha.kapdee@citi.com.
You may also:

• Contact our EMEA Chief Data Protection Officer by mail at Citigroup Centre, Canada Square, Canary Wharf, London, E14 5LB, or by email at dataprotectionofficer@citi.com. (DPO) responsible for your country or region, if applicable. For a list of DPOs, please write to Dharmisha Kapdee, Compliance Director, at dharmisha.kapdee@citi.com.
• Lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

Supplemental provision applicable to Users registering from the UAE
Your use of the Website signifies that you agree to waive your material privacy rights under the laws of the UAE. You also agree not to hold Citi 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 Website. Your use of the Website signifies Your consent allowing Citi to disclose any information that You may consider a secret to anybody at any time. You agree not to hold Citi liable for any disclosure of such information, that You may think to be a secret, to anyone. Please do not use the Website if you disagree with any part of this Privacy Statement.

Supplemental provision applicable to Users registering from Korea
Your consent of the Privacy Statement and Terms upon joining the Citi Alumni Site is deemed that you agreed that Your Personal Information will be controlled, not by Citibank Korea Inc. nor other subsidiaries and affiliates in Korea ("Citi Korea"), but by Citigroup Inc. NY, USA and/or Citi entity which operates the Website You are accessing. Citi Korea is solely responsible for the use of Your Personal Information within Korea, when it is used by Citi 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 Citi Korea but Citi Korea will not collect and use such personal information and material for any marketing purpose without your prior consent. When Citi Korea obtains Your Personal Information via the Website, the use will be controlled by and be bound to the necessary process and procedure following the applicable Korean laws.

Supplemental Provisions for California Residents

1. Requests. California residents have certain rights with respect to Personal Information under the California Consumer Privacy Act (“CCPA”). For purposes of this subsection, the terms “consumer,” “categories of personal information,” “business purpose,” “third party,” and “sell” have the meanings ascribed to them respectively in the CCPA. Terms defined under the CCPA may differ in meaning from the common usage of the same terms used elsewhere in this Privacy Statement.
1. You have the right to request, up to two times every 12 months, that Citi disclose to you the following: (i) the categories of Personal Information that Citi has collected about you; (ii) the categories of sources from which Citi has collected Personal Information about you; (iii) the business or commercial purpose for collecting or selling your Personal Information; (iv) the categories of Personal Information that Citi has sold about you in the last 12 months and the categories of Third Parties to whom the Personal Information was sold, by category or categories of Personal Information for each Third Party to whom the Personal Information was sold; (v) the categories of Personal Information that Citi has disclosed about you for our business purposes in the last 12 months and the categories of Third Parties to whom the Personal Information was disclosed, by category or categories of Personal Information for each Third Party to whom the Personal Information was disclosed; and (vi) the specific pieces of Personal Information that Citi has collected about you. Please note that Personal Information we have collected in connection with your personal account with us is not subject to the requirements of CCPA because it is already protected under existing federal and California state privacy laws, including the Graham Leach Bliley Act.
2. You have the right to request a portable copy of your Personal Information.
   
   In response to verified requests pursuant to #1 or #2 above, we will confirm receipt of the request within 10 business days of receipt of the request, and disclose and deliver the required information to you free of charge within 45 days of receiving a verifiable consumer request. We may extend this time period to provide once by an additional 45 days when reasonably necessary. We will provide notice of the extension within the first 45-day period.
3. You have the right to request that Citi delete Personal Information collected from you, subject to certain exceptions allowed under applicable law.
   
   In response to verified requests pursuant to #3 above, we will confirm receipt of the request within 10 business days of receipt of the request. Following verification of your request, we may require you to separately confirm that you want your Personal Information to be deleted.

4. You have the right to opt out of the sale of your Personal Information to Third Parties by clicking here to visit our Privacy Hub. CCPA defines sale very broadly, covering both monetary and other consideration. Citi does not sell personal information for money. However, we share some types of personal information. See our Privacy Hub.
5. Citi will not discriminate against you because you elect to exercise these rights, including by:
• Denying goods or services to you.
• Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
• Providing a different level or quality of goods or services to you.
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

None of the foregoing, however, prohibits Citi from charging you a different price or rate, or from providing a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to Citi by your data.

2. Submission of Requests. You may exercise these rights by managing this information through Citi’s Privacy Hub at https://online.citi.com/US/ag/dataprivacyhub/ or by calling us at (833) 971-1191. If you wish to submit a request to have your Personal Information deleted (see section A.3 in this Appendix) or wish to opt-out of the selling of your Personal Information, call us at (833) 981 0270.  If you wish to submit any type of CCPA request through an authorized agent, please follow the process in Section D below.
3. Requests From Households. Citi cannot take action in response to a request to know or request to delete as it pertains to household specific pieces of personal information unless all of the following conditions are satisfied:
1. All consumers of the household must jointly request access or deletion through the processes outlined in this Statement;
2. We are able to individually verify (i) all members of the household (see Section E below); and (ii) that all individuals making the request are still members of the household.
4. CCPA Authorized Agent. CCPA permits consumers to designate authorized agents to submit requests on their behalf.  Under CCPA, an “authorized agent” is a natural person or a business entity registered with the Secretary of State to conduct business in California that a consumer has authorized to act on their behalf subject to the requirements.  If you would like to designate an authorized agent to submit a request to know or a request to delete Personal Information on your behalf, please call us at (833) 981 0270.  Please be advised of the following additional information that will be required:
1. We require a written power of attorney, executed by you, confirming the authority of the authorized agent with respect to your CCPA request(s).  After you initiate a request with us by phone at the number above, we will provide you with a form of power of attorney.
2. Prior to responding to any request made on your behalf by an authorized agent, we may require you to provide written confirmation directly to us that you have provided the authorized agent permission to submit such request(s) on your behalf.
3. Once verified (see Section E below), your authorized agent may create a unique account for you through Citi’s Privacy Hub at online.citi.com/dataprivacyhub and manage your requests through that account.
5. Verification. Whether you submit a request directly on your own behalf, or through an authorized agent, we will take reasonable steps to verify your identity prior to responding to your requests under CCPA. Upon receiving a request pursuant to A.1 or A.2 above, we will confirm receipt within 10 days and provide you with information about how we will verify and process the request. In order to verify your request, we will require you to provide your social security number, tax ID number or passport number and issuing country, in addition to your first and last name, email address and mailing address.

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