Privacy Policy

Online Privacy Statement – Citi Alumni Network

Effective: 31 December 2024

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

Your Personal Information will be received and controlled by Citibank N.A. and processed by the Citi entity which operates the Website you are accessing.

This Privacy Statement applies solely to information collected by Citi in the context of your interactions with this site, and does not apply to other websites or to any financial product or service provided by Citi and its affiliates.

California Residents please review the below Notice at Collection and the Additional Information for California Residents for a description of your rights under the California Privacy Rights Act (“CPRA”) and its implementing regulations.

Persons in other geographies please read the supplemental information to your territory at the end of this Privacy Statement.

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

1. NOTICE AT COLLECTION
2. LAWFUL BASIS OF DATA PROCESSING
3. TRANSFER OF PERSONAL INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES 
4. LINKS TO OTHER WEBSITES
5. SECURITY
6. YOUR CHOICES
7. CHILDREN 
8. CHANGES TO THIS NOTICE
9. CONTACT US
10. APPENDIX
    1. Supplemental Provisions Regarding Individuals in the EEA
    2. Supplemental Provision Applicable to Users registering from the UAE
    3. Supplemental Provision Applicable to Users registering from Korea
    4. 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 access to the Services. This includes Personal Information that you provide to us in contact forms, and Personal Information that we collect automatically, usually through cookies or online trackers, when you visit or interact with the Services.

The term “Personal Information” as used in this Notice, also referred to as personal data, personally identifiable information or similar terms, means 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 

If you are eligible and decide to register as a user to this Website, you will be required to provide certain personal 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 may also collect additional Personal Information that you voluntarily provide when you complete your profile, including, without limitation, your email address, telephone number, mailing address, professional or employment-related information, photograph, and dietary requirements.

Personal Information that we collect automatically 

We collect directly or through service providers, 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 linked to our site, posts and comments you submit, information on your interaction with other Users and with the Services; We collect information in the course of maintaining or supporting the Website and Services; such as your MAC address, IP address, type of browser, operating system, internet service provider; and, if you access the Services via a mobile device, we may also collect information about mobile provider and type and Operating System in your mobile device.

Citi and others that collect data on our website use tracking technologies such as cookies and web beacons. Cookies are small data files stored on your browser memory that help us secure our website and ensure it displays and functions properly (necessary cookies). We may also deploy cookies that obtain insights from your use, and count visits (analytics) or improve our Services by remembering your selections (functionalities). We may also introduce at a later date marketing or advertising cookies or beacons. If we do add such cookies, we will also offer Cookie Preferences, to choose whether you wish to receive any optional cookies, or select “Do Not Share my personal information”.

How we use your Personal Information 

Any Personal Information that you submit that is designated as being accessible through the Directory of Registered Alumni Users' contact information ("Alumni Directory") will be available to authorized employees of Citi and, if you grant access to others in the Alumni Directory, to other Registered Alumni Users and other Citi employees for the purposes of providing the services, and may be used by any of them to contact you directly for any purpose under by the Terms, including for networking, social and business-related invitations.

Any Personal Information that you submit for publication on the Website will be available to all other Registered Alumni Users, and authorized Citi employees.

Any Personal Information not submitted for publication will be available only to Authorized Citi Global Workforce Members.

In addition, Citi may use Your Personal Information for the following purposes:

1. Providing the Services, including providing the functionality of the Website and fulfilling Your requests.
2. To process your registration and facilitate your participation on the Website, and provide you with customer services related to its use.
3. To provide and maintain a Directory of Registered Alumni Users with contact information.
4. To enable you to communicate with other Registered Alumni Users as well as to enable other social and networking communications.
5. To respond to your comments, questions, and customer service requests related to use of the Services.
6. To send you administrative information, such as changes to this Privacy Statement or our Terms.
7. To permit you to participate in voluntary polls and surveys. We may use third parties to deliver incentives to participate in such polls and surveys, and where we do so, you may need to provide Your contact details to the third party in order to fulfill the incentive offer.
8. To enable communications with you, including providing you with invitations and/or information about:
   • Citi and Citi-sponsored and/or third party-sponsored social and/or business-related events, activities, and opportunities.
   • financial industry and financial services events, activities, and opportunities.
   • Citi products and services related to the Services and this Privacy Statement (e.g., educational seminars); and
   • Citi re-employment opportunities.
9. To offer You Citi services or products made available on or through this Website from time to time.
10. For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
11. For fraud and security monitoring purposes, such as to detect and prevent cyberattacks or attempts to commit identity theft.
12. To develop new products and services, and for enhancing, improving or modifying our current products and services.
13. For data analysis identifying usage trends, such as understanding which parts of the Services are of most interest to Users, determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our Users.
14. 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.
15. To debug to identify and repair errors in our Services.
16. To carry out any other purpose described to you at the time the information is collected.

Who we share your Personal Information with

We disclose your Personal Information:

• To comply with applicable law and regulations. This can include laws outside your country of residence.
• To cooperate with public and government authorities, and cooperate with law enforcement. To respond to a request or to provide information we believe is important. These can include authorities outside your country of residence.
• To protect our rights, privacy, safety, or property, and/or that of our affiliates, and you or others; against fraud, crime, illegal activity, anti-money laundering, or anti-terrorism, and for risk management purposes.
• Subject to your consent, in each case with third parties for the offering of associated services such as webinars and social events.
• 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 affiliates in accordance with your former role history, for uses solely in accordance with this Statement. A list of Citi entities can be found at: https://www.citibank.com/icg/docs/Affiliates.pdf
• With service providers or contractors who provide technology services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, digital 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 while we have an alumni relationship with you. The majority of Website information will be deleted where no longer necessary (for example if you join the Alumni Directory) and kept without further processing for a period of 12 months at the end of the year you cease to be a member of Citi Alumni.

We may retain certain information for longer periods 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:

• 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).

II. LAWFUL BASIS OF DATA PROCESSING

The lawful basis that we rely on for data processing will vary, depending on the applicable law in the location where we provide our services.

These include:

• Consent: We use consent as a lawful basis, subject to conditions applicable in the country where consent is collected, only where:
  • We are required by law to obtain consent or
  • Where your consent can be assumed or inferred from your conduct (for example by registering and using the services)
• Legitimate interests
  • We will use this lawful basis for processing if:
    • We have a legitimate business purpose for processing your personal information; and
    • Processing your personal information is necessary to achieve this purpose; and
    • Our legitimate business interest is not overridden by your individual interests, rights and freedoms.
• Compliance with a legal obligation
  • We will use this lawful basis for processing if we need to process your personal information to comply with a legal obligation. This may include without limitation:
    • Providing information on request to government and regulatory bodies securities and commodities markets, securities brokers, and our intermediaries or counterparties

When we collect and process sensitive personal information, or Special Categories of Personal Information, we will do so by obtaining your explicit consent unless the law allows us to rely on prescribed exceptions:

• If the processing of personal information is clearly needed for your benefit, and your consent for its collection, use or disclosure cannot be obtained in a timely manner, or where you would not be reasonably expected to withhold consent.

III. INTERNATIONAL DATA TRANSFERS TO THE UNITED STATES AND OTHER COUNTRIES

The Website is controlled operated and hosted by Citi in the United States. Information about you may also be stored and processed in any country where have information technology facilities.

You understand that such transfer of information to countries outside of your country of residence, including the United States, have different data protection rules. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in the United States may be entitled to request access your Personal Information.

In countries where consent is required to transfer your personal data, you agree that your use of this website and its facilities in accordance with the Terms of Use contains such consent

IV. LINKS TO OTHER WEBSITES

The Website may have links to other websites. Citi is not responsible for the privacy or information security practices of those 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.

V. SECURITY

We seek to use reasonable physical, electronic, and procedural measures as required by applicable law to safeguard your Personal Information 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 interactions with us in connection with the Citi Alumni Network is no longer secure, please immediately notify us at alumni@citi.com.

VI. 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 aim to comply with your request as soon as practicable. Please note that if you opt out of receiving marketing-related emails from us, you may receive only administrative messages, from which may only opt out upon leaving the Alumni network.

Online Trackers Cookies

Our websites have essential or strictly necessary cookies. If in the future we add any other cookies (optional cookies, whether functional, analytics or marketing cookies) we will provide Cookie Options for you to accept or reject them, and to restrict sharing or selling internet tracking information with third parties.

You can also adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting all cookies could affect the availability and functionality of our Services.

We occasionally use third party companies to set cookies on our website and gather technical information.

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 data 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.

VII. CHILDREN

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

VIII. CHANGES TO THIS NOTICE

From time to time, we may revise and update this Statement, for any number of reasons, including to reflect industry initiatives, changes in applicable law, and changes to the scope of our Services. Any changes will become effective when we post the revised Statement on the Website.

IX. CONTACT US

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

X. APPENDIX

1. Additional Information for Individuals in the EEA, the European Union, the United Kingdom, Jersey and Switzerland

Some countries are recognized by the European Union, and data protection authorities in the UK, Jersey and Switzerland as providing an adequate level of data protection according (the full list of these countries is available here. For transfers from those countries not considered adequate by the European Commission, we have put in place adequate measures, such as binding corporate rules, and transfer risk assessments to protect your personal information.
 You may also:

• Contact our GDPR Data Protection Officer by post at Citigroup Centre, 25 Canada Square, Canary Wharf, London, E14 5LB, or by email at gdprdpo@citi.com .
• Lodge a complaint with a data protection authority for your country or where an alleged infringement of applicable data protection law occurs. A list of European data protection authorities is available here.

B. Additional information for 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.

C. Additional Information for 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.

D. Additional Information for California Residents

This California Supplemental Provision (the “California Supplement”) supplements the information contained in the Privacy 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 I 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:

1. Right to Delete. You have the right to request us to delete the Personal Information we have collected about You.
2. Right to Correct. You have the right to request us to correct inaccurate Personal Information we maintain about You.
3. 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.
4. 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.
5. 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.
6. 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.