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Our Pledge Regarding the Responsible Use and
Protection of Customer Information
Effective October 1, 2004
At Citizens one of our most important responsibilities to you, our customer, is
the safekeeping of the nonpublic personal ("confidential") information you have
entrusted to us and using this information in a responsible manner. Appropriate
use of the confidential information you provide us is also at the heart of our
ability to provide you with exceptional personal service whenever you contact
us.
We are providing you with this important notice to inform you of how Citizens
uses and protects your confidential information. We encourage you to read and
retain this notice, and to call or visit us if you have any questions. You do
not have to respond to this notice in any way. By maintaining a customer
relationship with us, you consent to our use of your confidential information in
accordance with our pledge.
Citizens pledge protects customers who have opened an account or obtained a
financial service from us for personal, family or household purposes. This
pledge also applies to former customers, and to consumers who have provided
confidential information to us but have not entered into a customer
relationship. This pledge does not apply to business or commercial customers.
The following is our continuing commitment to the responsible use and protection
of your confidential information:
A. Collection, Use and Retention of Confidential Information
We limit the collection, use and retention of confidential information to what
we believe is necessary to administer our business, to provide you with
exceptional quality service, to comply with regulatory retention of information
requirements, and to make available to you other accounts, services, and
opportunities that may be of benefit or interest to you. For example, your
information may be used to evaluate your eligibility for a loan or other
service, to improve our accounts and services or the way we are able to deliver
them to you, or to protect you from fraud.
Our online services use a feature of your Internet browser called a "cookie".
Cookies are files that are placed in your computer's browser memory or placed on
your hard drive. We may use cookies on our web site to verify your identity,
remember personal settings including your preferences, to offer you additional
options or enhance your online experience, and to improve our products and
services. We also use them for marketing site personalization, and tracking of
online applications and programs. Our server recognizes and records the domain
name from which visitors to our site accessed the Internet and the names of the
pages visited while at our site. It does not, however, collect and store your
electronic mail address or other nonpublic personal information, unless you
provide it to us. Finally, we also may use "cookies" to track the effectiveness
of advertisements for Citizens products and services, referred to as banner ads,
that we may place on Citizens and non-Citizens web sites. Cookies used for
tracking advertising effectiveness do not collect nonpublic personal, or
confidential information.
The Citizens Bank web site may contain links to third party sites. Citizens Bank
does not have access to the information you may provide to these third parties.
You should review their privacy policy before you share any nonpublic personal
information.
Citizens Bank respects the privacy of children (persons under the age of 13)
online. We do not knowingly collect, use, or disclose any personally
identifiable information from children. We do not knowingly market to children.
B. Information Collection
We may collect information about you from the following sources:
- Information we receive from you on applications, forms, or other information
that you provide to us-for example, your identification information, your
income, where you work, the accounts you have with other financial institutions,
the names of your beneficiaries on your insurance policy;
- Information we obtain at your request-for example, your fax number, or
information that we need to complete a transaction that you authorized;
- Information about your transactions and experiences with us-such as account
balances, the current value of your investments, account usage;
- Information we receive from external sources, including from a consumer
reporting agency-such as your creditworthiness, your employment verification, or
your payment history; and
- Information we receive from others, including public sources-for example, your
driving history from a state registry of motor vehicles for your automobile
insurance, real estate records, telephone numbers.
C. Our Protection of Confidential Information
We will safeguard, according to prudent security standards, your confidential
information. A fundamental element of safeguarding your confidential information
is to provide protection against unauthorized access or use of this information.
We maintain physical, electronic and procedural safeguards that comply with
federal guidelines to guard your confidential information against unauthorized
access or use. Our employees are limited in the access they have to information
about you to what is reasonably necessary to complete their responsibilities, to
maintain your accounts, to complete a transaction that you authorized, to notify
you of new products and services, or otherwise meet your needs. They are subject
to a corporate code of ethics and other policies that require maintaining the
confidentiality of customer information.
Citizens will continue to enhance and maintain prudent security standards and
procedures to protect against unauthorized access or use of your confidential
information and records. These security procedures also protect former customers
and consumers who have applied for an account or service at Citizens for as long
as the information is retained.
Citizens encourages you to help us protect your information and to keep your
information accurate. Please do not disclose your social security number, your
account numbers, your access codes, or personal identification number (PIN) to
your accounts to anyone with whom you are not familiar or would not trust with
this information. We also ask that you review your statements promptly. If you
suspect someone has made unauthorized transactions on your Citizens accounts, or
if you believe that any information about you is not accurate, please call us
anytime at 1-800-922-9999 (New England customers) or 1-888-910-4100 (PA, NJ, NY
or DE customers).
D. Sharing Information within Citizens' Family of Companies
We will not share any information about you within our corporate family, except
as permitted by law or as expressly authorized by you and then in accordance
with prudent security procedures. Specifically, we may share with the Citizens
family of companies:
- Information that relates to our experiences or transactions with you or your
accounts, such as account balances, payment history and account usage;
- Information that facilitates our proper identification of you when we share
information about you or to protect against fraud, such as your name and
address; and
- Information we receive from you on applications and other forms or from third
parties, such as your income, credit references and credit history, only:
- if the application or form discloses that we will share it, and we either give
you an opportunity to tell us not to share this information or you expressly
authorize us to do so, or
- as otherwise permitted by applicable law (such as to make credit decisions,
service your account, process transactions that you request or prepare
statements).
If you have given confidential medical information to us, such as for an
insurance application or for other permissible reasons, we will not share your
confidential medical information either within or outside the Citizens family of
companies except in a manner disclosed to you when the information was
collected, or to which you have agreed.
Certain information, such as trust and fiduciary information, is subject to
additional limitations regarding the sharing of information, both within the
Citizens family of companies and externally.
E. Sharing Information with Third Parties Outside Citizens' Family of Companies
We will not share your confidential information with any company or third party
outside the Citizens family of companies except as required or permitted by law.
This means, for example, that we can disclose your confidential information:
- To third parties that help us provide products or services to you, such as
companies that print your checks, data processors that work for Citizens, mail
companies, or software vendors;
- To third parties that assist us in marketing accounts and services;
- To other financial institutions with which we have joint marketing agreements to
enhance our financial product or service offerings;
- To insurance companies that underwrite insurance we arrange for our customers;
- To investors or other financial institutions that purchase loans from Citizens;
- To consumer reporting agencies;
- To third parties that process or service a financial product, service or
transaction that you requested or authorized;
- To respond to a subpoena, court order or judicial process;
- To pursue a sale, merger, or transfer of all or a portion of a business or
operating unit;
- To our regulators and auditors;
- To protect against or prevent fraud, manage risk, or resolve customer disputes;
or,
- A third party to whom you specifically authorize us to share the information.
Whenever other companies or third parties provide services for us or on our
behalf, we require them by contract to maintain the appropriate safeguards to
ensure the security and the confidentiality of the information that we provide
them.
Because certain disclosures of confidential information are specifically
required or permitted by law, we can make these disclosures even if you prefer
we do not do so. Therefore, you do not have to respond to this notice in any
way.
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SPECIAL NOTICE TO VERMONT AND CALIFORNIA CUSTOMERS:
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If you have a Vermont or California mailing address, we will automatically limit
the disclosure of your confidential information within and outside the Citizens
family of companies to what is permitted by applicable law or regulation. You do
not have to respond to this notice in any way.
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This pledge applies to the following companies within the Citizens Financial
Group family of companies, with the exception of RBS National Bank (a credit
card bank) which has a separate privacy notice, such as Citizens Bank of
Connecticut, Citizens Bank (a Delaware bank), Citizens Bank of Massachusetts,
Citizens Bank New Hampshire, Citizens Bank of Pennsylvania, Citizens Bank of
Rhode Island, Citizens Automobile Finance, Inc., Citizens Investment Services
Corp. (a securities brokerage and insurance agency), Citizens Mortgage
Corporation, doing business in many states as CMC Funding Company, Citizens
Financial Services Insurance Agency, Inc., Brewer & Lord LLC (an insurance
agency), Clair Odell Insurance Agency, LLC, doing business in many states as
Clair Odell Group, The Feitelberg Company LLC (an insurance agency), and other
banks or companies that we may acquire or establish from time to time. In
addition, the family of companies includes the Charter One family of companies,
such as Charter One Bank, N.A., Charter One Mortgage Corp., Charter One Auto
Finance Corp., Charter One Insurance Agency, Inc., Charter One Securities Inc.,
and Real Estate Appraisal Services, Inc.
This pledge supercedes all previously issued Citizens confidentiality and
information sharing disclosures. We reserve the right to change this pledge at
any time upon proper notice to you. We also are committed to the responsible use
and protection of customer information on our website. Our website privacy
policy can be found at citizensbank.com.
At Citizens we are dedicated to providing you with exceptional service and to
ensuring your trust. If you have any questions regarding this notice, please
call us toll-free anytime at 1-877-229-6430 and a Citizens customer service
specialist would be pleased to discuss our pledge with you. Thank you for your
business.
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Member FDIC
Equal Housing Lender
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