Last Updated: September 1, 2015
This Privacy Statement (the “Statement”) governs how Citi uses Your Personal Information on the Website. By using this Website You are consenting to the collection, storing, transmission, disclosure and use of Your Personal Information as set out in this Statement. We advise you to read the Privacy Statement in its entirety, including the country-specific provisions in the appendix to this Privacy Statement which will apply to users in certain countries. As used herein, the term “Personal Information” means any information that relates to You and that could be used, either directly or indirectly, to identify You. Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Terms.
We invite You to click below to get answers to questions regarding this Privacy Statement.
1. What Personal Information is collected through the Website?
Citi collects and may use certain Personal Information about You in order to operate and provide access to the Website. If you decide to register, You will be required to provide a user name and email address. Without this information, You will not be able to use the Website. By using the Website, You agree that the Website may collect other Personal Information about You, including but not limited to, the following:
Children are not eligible to use the Website and 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 Website.
2. Which Citi entity controls my Personal Information?
Your Personal Information will be controlled by Citigroup Inc. of 388 Greenwich Street, New York, NY 10013, USA 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 firstname.lastname@example.org.
3. What happens if I include Personal Information within my Submitted Materials to the Website?
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”) and current Citi employees (“Other Citigroup Employees”). 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.
4. What are cookies, and how are they used to collect Information?
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.
5. Does Citi collect non-personally identifiable information, and what does Citi do with it?
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 which We may use 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.
6. How will my Personal Information be used?
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 Agreement. 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.
In addition to other uses described herein, Citi will have access to and may use Personal Information that you submit on, or otherwise provide in connection with, the Website for administering and managing and providing other services in relation to the Website, including but not limited to:
Citi may also disclose Personal Information in order to protect the legal rights, privacy, safety, security or legitimate interests of Citi, its affiliates, and each of their respective investors, directors, officers, employees, agents and suppliers. These instances may include, but are not limited to: protecting the safety and security of visitors to our websites or other properties; complying with Citi policies; enforcing the Terms; complying with the law or regulations, or responding to a subpoena or other process; responding to inquiries or requests from public authorities; permitting Citi to pursue available remedies or limit the damages that it may sustain; protecting against fraud, crime, illegal activity, anti-money laundering, anti-terrorism, or for risk management purposes; or otherwise in connection with legal, compliance, regulatory and investigative purposes.
If Citi appoints third parties to host, maintain, manage, or to provide other services in relation to the Website, then the Personal Information included in the Website may be accessed and used by these third parties to the extent necessary to fulfill their hosting, maintenance, managerial, and/or other functions. Where these third parties are located outside the European Economic Area, we will ensure that they provide an adequate level of protection for your Personal Information.
If We sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, We may transfer Your Personal Information to a third party as part of that transaction (and will seek your consent where required by applicable law).
We do not rent, sell or otherwise provide Your Personal Information to third parties for their marketing purposes without your prior consent.
You may be invited to participate in polls and surveys on the Website. Your selection may be at random or it may be based on Your non-personally identifiable information such as job title, geography, industry sector. Whether or not You participate is entirely up to You. We may use third parties to deliver incentives to You to participate in polls and surveys. You may be required to provide Your contact details to the third party in order to fulfill the incentive offer. It is up to You whether You provide this information to take advantage of the incentive.
You understand and agree that the Website and any Personal Information included on the Website may be hosted, maintained and accessed globally (including outside the EEA and in the US and including in countries that may not have data protection laws). 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
7. What about other websites?
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.
8. Is the Personal Information collected about me secure?
The Website uses reasonable physical, electronic, and procedural measures to safeguard information 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.
9. What happens when Citi changes this Privacy Statement for the Website?
From time to time, We may revise this Privacy Statement. 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 Website, 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. If your country requires you to reaccept any changes to this Privacy Statement in order for such changes to be enforceable, we will facilitate such approach. Otherwise, Your continued use of the Website will indicate Your agreement to the new Privacy Statement.
10. How long does Citi keep my Personal Information?
Personal Information that You include in Your user profile will be retained in accordance with applicable law.
If You no longer wish to participate in the Website, You may contact email@example.com to request that Your profile data 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.
11. Whom can I contact about accessing, amending or deleting my Personal Information?
In certain countries, consistent with applicable law, 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. If You would like to request deletion of Your profile information or have questions or requests, please contact firstname.lastname@example.org who will be able to guide you as to how to do this.
If You have any other questions concerning this Privacy Statement, You may submit them to email@example.com. Please do not send emails to us for other purposes.
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 User Agreement 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.
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