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.

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.

PRINTING INSTRUCTIONS

For a copy of this document, use the print command on your web browser.

Member FDIC

Equal Housing Lender