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Our Notice to You Regarding the Responsible Use and Protection of Your Information

Effective September 1, 2008

At Citizens, one of our most important responsibilities to you is the safekeeping of your nonpublic personal information (information). Appropriate use of your information is also at the heart of our ability to provide you with exceptional personal service whenever you contact us. We want you to understand how we manage your information to serve you and the choices you have.

This notice tells you:

  • What information we may collect about you
  • How we protect your information and what you can do to help us protect your information
  • How we may share your information within and outside our family of companies
  • How you can limit our use of your information for marketing within our family of companies
  • How to contact us.

If you want to limit our use of information about you for marketing within our family of companies, please see the Marketing Form at the end of this notice.

We encourage you to read and retain this notice, and to call or visit us if you have any questions.

This notice applies to customers who have opened an account or obtained a financial product or service from us for personal, family or household purposes. This notice also applies to former customers, and to consumers who have provided information to us but have not entered into a customer relationship, for as long as information is retained. This notice does not apply to business or commercial customers.

Collection, Use and Retention of Your Information

We limit the collection, use and retention of your information to what we believe is necessary to provide you with exceptional quality service, comply with regulatory requirements, and make available to you other products, services, and opportunities that may be of interest to you. For example, your information may be used to evaluate your eligibility for a loan or other service, to improve our products and services or the way we deliver them to you, or to protect you from fraud.

Information Collection

We may collect information about you from the following sources-

  • information we receive from you on applications or forms, or other information that you provide to us--such as your identification information, your income, where you work or the accounts you have with other financial institutions;
  • information about your transactions and experiences with us--such as account balances, the current value of your investments, or account usage; and
  • information we receive from third parties, including from consumer reporting agencies--such as your creditworthiness, your employment verification, or your payment history.


Protection of Your Information

We will safeguard your information according to prudent security standards. We maintain physical, electronic and procedural safeguards designed to comply with federal guidelines to guard your information against unauthorized access or use. We limit the access by our employees and agents to information that we believe is reasonably necessary to maintain your accounts, to complete a transaction that you authorized, or otherwise meet your needs. Our employees are subject to a corporate code of ethics and other policies that require maintaining the confidentiality of information. You have a role in helping us by safeguarding your information from others and by reviewing your statements promptly.

How to contact us: 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 1-877-229-6430.

Sharing Information within our Family of Companies

We may share information about you within our family of companies as permitted by law or as expressly authorized by you. Specifically, we may share within our 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 we disclose that we may 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 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 medical information to us, such as for an insurance application, we will not share your medical information except as permitted or required by law or with your permission.

Certain information, such as trust and fiduciary information, may be subject to additional limitations regarding the sharing of information, both within our family of companies and with third parties.

Limiting Use of Your Information for Marketing within our Family of Companies

You have the right to limit some, but not all marketing within our family of companies. Federal law also requires us to give you this notice to tell you about your choice to limit marketing from our affiliates. Your choice to limit the use of this information within our family of companies does not apply to any Citizens company that has an existing business relationship with you, where the use is otherwise permitted by law or to information collected prior to October 1, 2008. You may limit our affiliates, such as our affiliated insurance agencies, securities broker-dealer and banks, from marketing their products or services to you based on your information that we collect and share with them. This information may include, among other things, your income, account history and credit score.

Your choice to limit marketing offers from our family of companies will apply for at least five years from when you tell us your choice. Once that period expires, you will receive a renewal notice that will allow you to continue to limit marketing offers from our family of companies for at least another five years.

You may instruct us not to use this information within our family of companies for marketing purposes by completing our Marketing Form or contacting us in the ways that we have outlined in our Marketing Form.

Sharing Information with Third Parties Outside Our Family of Companies

We may share your information with any third party outside our family of companies as permitted or required by law or as expressly authorized by you. For example, we may share your information with:

  • third parties that help us provide products or services to you--such as companies that print your checks, data processors that work for us, mail companies, or software vendors;
  • third parties that assist us in marketing products and services or other financial institutions with which we have joint marketing agreements to enhance our financial product or service offerings;
  • consumer reporting agencies;
  • third parties to respond to a subpoena, court order or judicial process;
  • third parties to pursue a sale, merger, or transfer of all or a portion of a business or operating unit;
  • our regulators and auditors; and
  • third parties to protect against or prevent fraud, manage risk, or resolve customer disputes.

Whenever third parties provide products or services for us or on our behalf, we require them by contract to maintain appropriate safeguards designed to ensure the security and the confidentiality of the information that we provide them.

For Vermont and California residents only

The information practices we have described above comply with federal law. Vermont and California law place additional limits on sharing information about their residents. If you are a Vermont or California resident, we will automatically limit the disclosure of your information within and outside our family of companies as permitted or required by applicable law or regulation.

For Nevada residents only

Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 West Washington Street, Suite 3900, Las Vegas, NV 89101; telephone number: 1-702-486-3132; email BCPINFO@ag.state.nv.us. Citizens Bank, PO Box 42020,Providence, RI 02940-2020

Amendments

This notice is accurate as of the date it is sent to you and supersedes all previously issued confidentiality and information-sharing disclosures. We reserve the right to change this notice, and any of the practices described in the notice, at any time upon proper notice to you.

Companies to Which this Notice Applies

This notice applies to Citizens Bank of Pennsylvania and to RBS Citizens, N.A., which does business through its divisions, including Citizens Bank, Charter One and CCO Mortgage. It excludes RBS Card Services, a division of RBS Citizens, N.A., which has a separate policy. This notice also applies to the following companies within the Citizens Financial Group family: Charter One Mortgage of Delaware, LLC, First Chesapeake Mortgage, LLC, KPF Mortgage, LLC, Southeast Mortgage Group, LLC, Complete Mortgage, LLC, First Choice Mortgage, LLC, First NH Mortgage Corp., Citizens Automobile Finance, Inc., Citizens Automobile Finance Corp., CCO Investment Services Corp., Citizens Financial Services Insurance Agency, Inc., Citizens Insurance Agency of New York, Inc., RI Realty Trust, Inc., Citizens Auto Receivables, LLC and other banks or companies that we may acquire or establish from time to time.

We are also committed to the responsible use and protection of your information on our website. Our website privacy notice can be found at www.citizensbank.com.

If You Have Any Questions:

If you have any questions regarding this notice, please call us toll-free at 1-877-229-6430.

At Citizens, we are dedicated to providing you with exceptional service and to ensuring your trust.

Thank you for your business.

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