Privacy Policy

Privacy Statement

Privacy Statement - Citi Alumni Network

Last Updated and Effective Date: 7 June 2023   

This Privacy Statement (the "Statement") governs how Citigroup Inc. and our subsidiaries and affiliated companies (collectively, “Citi,” “we,” or “us”) collect, use and disclose Personal Information (as defined below) from and about Users of this Citi Alumni website (the “Website”) and the other services of the Citi Alumni Network (collectively with the Website, the “Services”). We advise You to read the Statement in its entirety, including the jurisdiction-specific provisions in the Appendix to this Statement which will apply to Users in certain jurisdictions.

Your Personal Information (defined below) will be controlled by Citibank N.A. and/or the Citi entity which operates the Website You are accessing (and/or if You are a Citi Global Workforce Member, the Citi entity which employs You or through which you are engaged to provide services to Citi). 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 alumni@citi.com.

Please note that if You are a Citi customer or use any other services of Citi, additional privacy policies and statements may apply to You, and this Statement does not replace or revise any other privacy policy or statement that may be applicable to Personal Information collected or used by Citi through Your relationship with Citi.

Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the  Terms & Conditions   (“Terms”).

1. NOTICE AT COLLECTION
2. TRANSFER OF PERSONAL INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES 
3. LINKS TO OTHER WEBSITES
4. SECURITY
5. YOUR CHOICES
6. CHILDREN 
7. CHANGES TO THIS NOTICE
8. CONTACT US
9. APPENDIX
10. Supplemental Provisions Regarding Individuals in the EEA
11. Supplemental Provision Applicable to Users registering from the UAE
12. Supplemental Provision Applicable to Users registering from Korea
13. Supplemental Provision Applicable to California Residents

 1. Notice At Collection 

Collection of Personal Information

Citi collects and may use certain Personal Information about You in order to operate and provide You with access to the Services. This includes Personal Information that You provide to us and Personal Information that we collect automatically when You visit or interact with the Services. “Personal Information” as used in this Notice is sometimes also referred to as personal data, personally identifiable information or other like terms to mean any information that directly or indirectly identifies You or is reasonably capable of being associated with You or Your household.

Personal Information That You Provide To Us

If You are eligible and decide to register to use the Website, You will be required to provide the following information in order to create an online account for the Citi Alumni Network: Your full name, address, time zone, email address, Citi ID and Citi employment information (last job at Citi), communications options/permission to contact, and login information. Without this information, You will not be able to register or use the Website.

We collect Personal Information that You may voluntarily provide when You complete Your profile on the Website, including, without limitation, Your email address, telephone number, mailing address, professional or employment-related information, photograph, and dietary requirements.

Personal Information That We Collect About Your Use of the Services

We and others on our behalf may collect Personal Information about Your use of the Services and about the device You use to access the Services, including: the pages You request and visit, the posts You submit, information on Your interaction with other Users and the Services; information obtained in the course of maintaining or supporting the Services; information about Your internet use, such as Your IP address, Your type of browser, Your operating system, Your internet service provider; and, if You access the Services via Your mobile device, we may also collect information about Your mobile provider and type of mobile device.

We (and others that control collection of Personal Information) use different technologies to collect this information, including cookies and web beacons. Cookies are small data files stored on Your hard drive or in device memory that help us improve our Services and Your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage.

This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand Your use of the Website.

How Personal Information Is 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 ("Alumni Directory") will be available to Authorized Citi Global Workforce Members and, if You grant access to such Personal Information in the Alumni Directory, to other Registered Alumni Users and other Citi Global Workforce Members with a need to know 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 Alumni Directory will be available to all other Registered Alumni Users, and Authorized Citi Global Workforce Members and may be used by any of them for any purpose not specifically prohibited by the Terms. 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 Alumni Directory will be available only to Authorized Citi Global Workforce Members. 

In addition to other uses described herein, Citi may use Your Personal Information with Your consent and/or when we have a legal obligation or for legitimate business purposes, including:

• Providing Services, including providing the functionality of the Website and fulfilling Your requests.
• To process Your registration and facilitate Your participation on the Website and provide You with customer service related to use of the Services.
• To provide and maintain a Directory of Registered Alumni User contact information.
• To enable You to communicate with other Registered Alumni Users as well as to enable other social and networking communications.
• To respond to Your comments, questions, and customer service requests related to use of the Services.
• To send administrative information to You, such as changes to this Statement or our Terms.
• To permit You to participate in voluntary polls and surveys. We may use third parties to deliver incentives to You to participate in such polls and surveys. You may be required to provide Your contact details to the third party in order to fulfill the incentive offer.
• To manage our contractual relationship with You and/or to comply with a legal obligation.
• To enable communications with You, including providing You with invitations and/or information about:
  1. Citi and Citi-sponsored and/or third party-sponsored social and/or business-related events, activities and opportunities;
  2. The financial services industry and financial services industry events, activities and opportunities;
  3. Citi products and services related to the Services and this Statement (e.g., educational seminars); and
  4. Citi employment opportunities.
• To offer You Citi services or products, including those that may be made available on or through this Website from time to time.
• To aggregate, deidentify and/or anonymize Personal Information. We may aggregate, deidentify and/or anonymize Personal Information so that it will no longer be considered Personal Information.
• To accomplish our other business purposes.
• For data analysis, such as to improve the efficiency of the Services.
• For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
• For fraud and security monitoring purposes, such as to detect and prevent cyberattacks or attempts to commit identity theft.
• For developing new products and services.
• For enhancing, improving or modifying our current products and services.
• For identifying usage trends, such as understanding which parts of the Services are of most interest to Users.
• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our Users.
• For operating and expanding our business activities, such as understanding which parts of the Services are of most interest to our Users so we can focus our energies on meeting our users’ interests.
• To debug to identify and repair errors in our Services.
• To comply with our legal and financial obligations.
• To carry out any other purpose described to You at the time the information was collected.

How Personal Information Is Disclosed

We use and disclose Your Personal Information with Your consent, when we have a legal obligation or legitimate interest to do so, or as otherwise described in this Statement:

• To comply with applicable law and regulations. This can include laws outside Your country of residence.
• To cooperate with public and government authorities. To respond to a request or to provide information we believe is important. These can include authorities outside Your country of residence.
• To cooperate with law enforcement. For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons, such as to monitor compliance with and enforce our Terms; to protect our rights, privacy, safety, or property, and/or that of our affiliates, You or others; to protect against fraud, crime, illegal activity, anti-money laundering, or anti-terrorism, and for risk management purposes.
• In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring Your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
• To certain Citi entities for their use in accordance with this Statement. 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 .
• With our service providers or contractors, who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.

We may also disclose aggregated or de-identified information that cannot reasonably be used to identify You for website administration, analytics, market research, advertising and promotions or any other legitimate business use.

Retention of Personal Information

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with You and provide the Services to You (for example, for as long as You have a Citi Alumni Network account with us or keep using the Website); Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your usage and interaction with our Services for a certain period of time before we can delete them); or

Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

 2. Transfer of Personal Information to the United States and Other Countries 

The Website is controlled and operated by us from the United States. Information about You may be stored and processed in any country where we or our services providers have facilities or operations. By using the Website, 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.

 3. Links To Other Websites 

The Website may contain links to other websites. 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 and site terms for any other websites to which You click through to via the Website. 

 4. Security 

We seek to use reasonable physical, electronic, and procedural measures to safeguard Personal Information within our organization 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 login credentials and other Website registration information, and for controlling access to your email communications at all times. If You have reason to believe that Your interaction with us in connection with the Citi Alumni Network is no longer secure, please immediately notify us at  alumni@citi.com.

 5. Your Choices 

  Account Information

You may update and correct certain Citi Alumni Network online account information at any time by logging into Your Citi Alumni Network online account or emailing us at alumni@citi.com. If You wish to delete Your Citi Alumni Network online account, please email alumni@citi.com, but note that we may retain certain information as required by law or for our legitimate business purposes.

 Communications Preferences

If You no longer want to receive marketing-related emails from us on a going-forward basis, You may opt out by following the instructions contained within each such email or through the communications center in Your Citi Alumni Network online account profile. We will try to comply with Your request as soon as reasonably practicable. Please note that if You opt out of receiving marketing-related emails from us, we may still send You administrative messages, from which You cannot opt out.

 Cookies

Most web browsers are set to accept cookies by default. If You prefer, You can usually adjust Your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

We occasionally use third party companies to set cookies on our Website and gather cookie information on our behalf. In some cases, we will also use another company to operate web servers for our Website. 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.

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.

 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.

 Other Rights

You may be entitled to certain rights depending on Your jurisdiction. To learn more, please see the Appendix in Section IX below. Other than as noted in the Appendix in Section IX below, You may have the right to request to review, correct, update, suppress, restrict or delete Personal Information that You have provided to us, object to the processing of Personal Information, or if You would like to receive an electronic copy of Your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to You by applicable law). Please Contact Us as described in Section VIII below to exercise these rights. We will respond to Your request consistent with applicable laws, rules and regulations (applicable “Law”). 

 For Your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that You use to send us Your request, and we may need to verify Your identity before implementing Your request. We will try to comply with Your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that You began prior to requesting a change or deletion.

  6. Children 

 Our Services are not intended for or directed at children under the age of 18. In addition, we do not knowingly collect Personal Information from children under the age of 18. We also do not knowingly sell, share, use for targeted advertising or disclose the Personal Information of children under the age of 18.

  7. Changes To This Notice 

From time to time, we may revise this Statement. Updates may be made for any number of reasons, including to reflect industry initiatives, changes in applicable Law, and changes to the scope of the Services, among other reasons. You can tell when we last updated the Statement by checking the "Last Updated and Effective Date" at the beginning of the Statement. Any changes will become effective when we post the revised Statement on the Website.

 8. Contact Us 

If You have any other questions concerning this Statement, You may submit them to alumni@citi.com. 

 9. Appendix 

Supplemental Provisions Regarding Individuals in the EEA

Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available  here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as binding corporate rules, to protect Your Personal Information. 

You may also:

Contact our EMEA Chief Data Protection Officer by mail at Citigroup Centre, Canada Square, Canary Wharf, London, E14 5LB, or by email at  dataprotectionofficer@citi.com or the Data Protection Officer (DPO) responsible for Your country or region, if applicable. 

Lodge a complaint with a data protection authority for Your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

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 Statement.

Supplemental Provision Applicable to Users Registering from Korea

Your consent of the Statement and Terms 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.

Supplemental Provision Applicable to California Residents

This California Supplemental Provision (the “California Supplement”) supplements the information contained in the Statement above and applies solely to residents in California who have rights under the California Privacy Rights Act (“CPRA”) (“consumer” or “You”). Unless otherwise defined in the Privacy Policy, any terms defined in this California Supplement have the meaning used in the CPRA.

Sensitive Personal Information

Under the CPRA, certain types of Personal Information are considered “sensitive” Personal Information or data and require additional data privacy rights and obligations. As described in the Collection of Personal Information section in Section I.A of the Statement, in connection with Your use of the Services, we collect account login information and information regarding dietary restrictions that may reveal Your racial or ethnic origin, religious or philosophical beliefs and health information. These types of information may be considered sensitive Personal Information under the CPRA. To the extent we collect any information that would be considered sensitive Personal Information under the CPRA, we will only use this sensitive Personal Information to provide the goods or services You requested, prevent, detect, and investigate security incidents, resist malicious, deceptive, fraudulent, or illegal actions directed at us and prosecute those responsible for those actions, ensure Your physical safety, and verify or maintain the quality or safety of our products and services (“Permitted Uses”). Because we use this sensitive Personal Information for Permitted Uses under the CPRA, we do not need to provide a Limit Use and Disclosure of Sensitive Personal Information right under the CPRA. 

Summary of Personal Information Handling Practices

We provide in the chart below a summary of our prior 12-month Personal Information handling practices, which is consistent with our current practices described in the Notice at Collection in Section 1 of the Statement.

Selling or Sharing of Personal Information

We do not sell Your Personal Information or share Your Personal Information for cross-context behavioral advertising and have not done so in the prior 12 months. We also do not knowingly sell or share the Personal Information of children under the age of 16 and have not done so in the prior 12 months.

  Your Rights and Choices

The CPRA affords consumers residing in California certain rights with respect to their Personal Information, subject to certain exceptions. Subject to certain limitations, You have the following rights in California:

• Right to Delete. You have the right to request us to delete the Personal Information we have collected about You.
• Right to Correct. You have the right to request us to correct inaccurate Personal Information we maintain about You.
• Right to Know and Access. You have the right to know and access the Personal Information we have collected about You, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about You.
• Right to Data Portability. You have the right to receive the information under right (3) in a format, to the extent technically feasible, that is portable, usable, and allows You to transmit the Personal Information to a person without impediment, where the processing is carried out by automated means.
• Rights Related to Sharing for Cross-Context Behavioral Advertising or Sale.  We do not share Your Personal Information for cross-context behavioral advertising or sell Your Personal Information. Please contact us by using the information in Contact Us in Section VIII of the Statement above if You have any questions.
• Right to No Discrimination. You have the right not to be discriminated against for exercising any of Your privacy rights. This includes us not: (a) denying You goods or services; (b) charging You different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing You a different level or quality of goods or services; (d) suggesting to You that You will receive a different price or rate for goods or services or a different level or quality of goods or services; and (e) retaliating against You for exercising Your privacy rights.

  Instructions on How to Exercise Your Privacy Rights

To exercise Your rights described above, please submit a verifiable consumer request to us by either: Visiting Citi’s California Privacy Hub at https://online.citi.com/dataprivacyhub; or calling us at (833) 981-0270 (TTY: 711).

 In some instances, we will need to verify Your identity before honoring Your privacy right request. We will verify Your identity by asking You to provide Personal Information we may have previously collected about You. Subject to certain limitations, we will honor Your privacy rights request within 45 calendar days of receipt, unless we request an extension under the CPRA. 

 Authorized Agents

You may exercise Your privacy rights through an authorized agent. If we receive Your request from an authorized agent, we may ask for evidence that You have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on Your behalf. If You are an authorized agent seeking to make a request, please contact us by either:

 Visiting Citi’s California Privacy Hub at https://online.citi.com/dataprivacyhub; or calling us at (833) 981-0270 (TTY: 711).

Additional Disclosure for California Residents

If You are a California resident, You have the right to request and receive certain information about disclosure of Your Personal Information to third parties for their direct marketing purposes. Because it is our policy not to share Your Personal Information with third parties for third-party direct marketing purposes without Your consent, we are exempt from the requirement to respond to such requests. If You have any questions related to our policy, please contact us using the information provided in Contact Us in Section VIII of the Statement.