U.S. Citi Commercial Bank Privacy Notice

Your trust and confidence in how we collect, use, and share information about you and the business entity with which you are associated (the “Business”) is a priority. This U.S. Citi Commercial Bank Privacy Notice (“Notice”) applies to all users, whether or not clients of the U.S. Citi Commercial Bank (“CCB”), of CCB websites, mobile applications, e-mail, and Citi- branded U.S. social media sites or pages, and other Citi U.S. online, mobile or retail services that link to or from or expressly reference this Notice (collectively, the “Sites/Services”). To the extent that any Citi website that you visit includes its own privacy notice, that notice rather than this Notice governs such site.

This Notice explains how we collect, share, use, and protect information when you, in your capacity as an individual customer, or as an officer, director, employee or other individual associated with the Business, visit or use the Sites/Services. By using the Sites/Services, you agree to this Notice.

As you review this Notice, here are a few important things to keep in mind:

  • If you have a financial product or service with Citi for personal, family or household use with one of our U.S. businesses, the applicable Citi line of business would have delivered to you a U.S. Customer Privacy Notice (“Customer Privacy Notice”) that explains how that Citi business collects, uses and shares information about you and offers you certain choices with respect to the use and sharing of your personal information.
  • Wireless service providers, Internet service providers, device manufacturers and/or social media platforms may have their own privacy notices that differ from this Notice and govern the information they may access through your use of the Sites/Services. We encourage you to read their privacy notices as the collection, uses and sharing of information by those third parties may differ from Citi’s.
  1. Information We Collect Through the Sites/Services
  2. Use of Information
  3. Sharing of Your Personal Information
  4. Other Information We Collect
  5. Do Not Track
  6. Security of Personal Information
  7. Other Important Information

1. Information We Collect Through the Sites/Services

We collect personal information that identifies you, either as a customer or with respect to your relationship to the Business, as an individual or otherwise relates to identifying information about you, such as your name, address, phone number, and e-mail. Depending upon the services the Business requests, we may collect additional personal information such as date of birth, Social Security number, driver's license number, bank account and/or payment card information and employment information, biometric information and personal identification numbers. We may also collect information about our customers’ mobile phone usage and status (but not the content of their communications) and behavioral information in order to better authenticate them in certain channels, to prevent fraud and protect our customers’ assets.

We, or companies we work with, collect other information such as browser and device information, app usage data, information collected through cookies, web beacons and other technologies, demographic and other information, behavioral information and aggregated information about your visits to, or use of our sites, and other services. While that information alone may not reveal your specific individual identity, we may associate this usage and other information we collect with personal information about you. This other information is described in more detail below in Section 4.

We may share anonymized, pseudonymized or de-identified aggregated information with third parties to help deliver products, services, and content that are tailored to the users of our Sites /Services and for other purposes.

2. Use of Information

We may use the personal and other information we collect from and about you and the Business to:

  • Authenticate you so that you can access the Sites Services and conduct account transactions on the Sites/Services;
  • Recognize you, your device or your browser when you use the Sites /Services so that we can facilitate navigation, display information more effectively, store your preferences and otherwise personalize your experience and enhance the use of the Sites/Services;
  • Process applications and transactions for the Business;
  • Respond to your inquiries, fulfill requests and request your feedback;
  • To track responses to our e-mails and advertisements and to measure the success of our marketing campaigns;
  • Manage our business, such as for data analysis, audits, fraud monitoring and prevention, information security, improving the Sites/Services, developing new products and services, identifying usage trends, and expanding our business activities;
  • Review statistical information about use of the Sites /Services in order to improve their design and functionality, to understand how they are used, and to assist us with resolving questions about the Sites/Services; and
  • Ensure that the Sites /Services function properly and otherwise administer the Sites/Services..

3. Sharing of Personal Information.

Your personal information may be shared:

  • with our affiliates to the extent permissible under applicable law;
  • with our third party service providers, who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, processing your transactions, e-mail delivery, auditing, and other services;
  • with individuals you associate with your social media account and to your social media account provider, in connection with your social sharing activity; and

We also may use and disclose your personal information and information about you and the Business as we believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.

We may transfer information to Citi affiliated companies or third parties throughout the world, for example to process transactions and provide you with products and services. Regardless of where we process your information, we still treat it in accordance with this Notice and applicable law.

4. Other Information We Collect

In addition to personal information you provide directly to us, we and our service providers may collect other information about you, which is collected in a variety of ways, including:

  • Through your use of your browser or device: Certain information is collected by internet browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, device identifier, language, and Internet browser type and version. We may also collect your IP address, along with the time of your visit and the page(s) visited. We may also collect behavioral data about the way you use your devices or our mobile apps and website.
  • Through your use of our mobile apps: When you download and use one of our mobile apps, we may collect and/or track app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to or presented through the app.
  • Using cookies, pixel tags, device profiling, and similar technologies: We may use cookies, pixel tags, and similar technologies to collect browser, device and other information, such as time spent on the Site, 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 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. Other similar tracking technologies may be introduced and used by us in the future in connection with the Site.
  • Physical location when using your mobile device: We may collect the physical location of your device by, for example, using satellite, cell phone tower, or wireless local area network signals, as well as through the use of beacons in our branches.
  • You can choose whether to accept cookies through your browser settings. For example, most browsers allow you to automatically decline cookies or decline or accept a particular cookie (or cookies) from a particular site when browsing. If you decide not to accept cookies, some features of the Site may not work properly because we may not be able to recognize your device and associate you with your Citi account(s). In addition, the offers or content we provide when you visit our site or on third party sites may not be as relevant to you or tailored to your interests.

In some instances, we may combine other information with personal information where permissible by law and applicable industry guidelines.

5. 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.

6. Security of Personal Information

The security of personal information about you is a priority. We seek to protect this information by maintaining physical, electronic, and procedural safeguards designed to protect personal information within our organization. We provide employee training in the proper handling of personal information. When we use other companies to provide services for us, we require them to protect the confidentiality of personal information they receive from us. Although we take extensive measures to protect your personal information, and to anticipate and mitigate new threats to personal information, unfortunately, no data transmission over the Internet or wireless network or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately contact us.

7. Other Important Information

Notice of Changes

We may change this Notice from time to time. When we do, we will let you know by appropriate means, such as posting the revised Notice on this page with a new effective date. Any changes will become effective when we post the revised Notice on the Site. Your use of the Sites /Services following these changes means that you accept the revised Notice.

Third-Party Sites and Services

This Notice does not address, and we are not responsible for, the privacy, security, or other practices of any third parties, including any third party operating any site or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, usage, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other third-party app provider, social media platform provider, operating system provider, device manufacturer, or wireless service provider, including with respect to any personal information you disclose to other organizations through or in connection with the Site.

Jurisdictional Issues

The Sites/Services are 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 Sites/Services, 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 or information about the Business.

Contact Us

If you have any questions about this Notice, please contact us. European Union residents may contact us at: dataprotectionofficer@citi.com. California residents have certain rights with respect to “personal information” under the California Consumer Privacy Act (“CCPA”). If you have a trust or personal account with Citi, and you would like to submit a request pursuant to the California Consumer Privacy Act (“CCPA”), please visit Citi’s Global Privacy Hub at https://online.citi.com/US/ag/dataprivacyhub/home or call us at (833) 971-1191.