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• Internet Privacy Policy & Statement
• Privacy Notice for Citi Private Bank Clients
• How we protect your online security
• How can you protect your online security?
• What is encryption? What is it used for?
• How secure is encryption? How secure is the Private Bank's Internet site?
• What are some good security practices that I can use?
• What is the process for reporting and handling suspected security incidents?
• How do I clear my browser's cache?

Internet Privacy Policy & Statement Citi will not disclose or provide information about you, your accounts, your relationship with the Private Bank or your usage of the Web site to any third party for any purpose without your written consent, except as set forth herein. We know, however, that most Private Bank clients want their private banker to give them access to products and services available from our affiliates. The Private Bank will, therefore, use data from your usage of the Web site (including information compiled using "cookie" or other "data mining" technology or otherwise) about your potential interest in products or services for the Private Bank's own marketing or development purposes, and in order to provide the Services and Information to you via the Web site. Please also read below under the heading Citi Private Bank Privacy Notice for Consumers for more information about how we collect and disclose personal information. Use of "Cookies" In order to provide you with better service and to enhance security within the Web site, we will occasionally use a "cookie". A "cookie" is a small piece of information that a Web site stores on your Web browser on your PC and can later retrieve. We use cookies for a number of administrative purposes, including to store your preferences for certain kinds of information. No cookie set by the Web site on your Web browser will contain information that could enable any third party to contact you via telephone, e-mail or postal mail. Cross Border Data Transfer; Secrecy Waiver We currently provide the Services to you through our New York branch. By accessing this Web site and using the Services, therefore, information about you, your accounts and your relationship with us may be transferred cross-border. Such information may be subject to supervision by the regulatory authorities in each jurisdiction where services are performed or information resides, as well as in New York and in the jurisdiction of your residence or citizenship. If you are a resident of the European Union, such other countries may not offer 'adequate protection' for the purposes of directive 95/46/EC of the European Union (as amended). Disclosures to Third Parties Information about you that is available to you via the Web site, including your account information, can become subject to the legal systems and laws in force in each state or country (a) where it is held, received or stored by you or us, (b) from where it is accessed by you or us, or (c) through which it passes. Such information can become subject to disclosure pursuant to the laws of those states or countries. In addition, because your account(s) may include information about more than one individual (e.g., where you maintain a joint account) and about your business relations with the Private Bank and its affiliates, statements released to comply with legal process may contain information regarding your relationship with these individuals and with us and our affiliates. We may disclose your name and other personal and other financial information about you (1) at the request of a bank or other regulatory agency or in connection with an examination of us by bank or other examiners; (2) pursuant to subpoena or other legal process; (3) at the express direction of any other authorized government agency; (4) to our internal or external attorneys or auditors; (5) to others to whom we are required to make such disclosure by law; or (6) to an Internet Service Provider or any other third party agent or service provider for the any purpose related to offering, providing, administering or maintaining the Services. Data Protection on the Internet This Web site is a private, restricted-access Internet based service. We use encryption technology to protect the transmission of account data to or from you via this Web site. For security reasons and to safeguard the security of your data, access to this Web site is limited to browsers that can support a minimum of 128-bit encryption technology. Nevertheless, because information about you, your accounts and your relationship with us can be accessed through a public network, the Internet, there can be no assurance that your account information will remain secure and you accept the risk that unauthorized persons may view such information. If you believe that an unauthorized person has accessed your information, please contact a member of your Private Bank team immediately. Please read the Terms and Conditions, which also govern your use of this Web site. This statement is effective as of July 1, 2004. Citi may change this statement at any time. Any changes or updates will be effective immediately upon posting to this Web site. The effective date of this statement indicates the last time this statement was changed or updated. Checking the effective date allows you to determine whether there have been changes or updates since the last time you reviewed this statement. ^ back to top

Privacy Notice for Citi Private Bank Client (for Consumers) Our goal is to maintain your trust and confidence when handling personal information about you. Choosing the Private Bank By choosing the Citi Private Bank you have made a choice that enables us to provide you with products and services to help you meet your financial needs and objectives. Through this Notice, the Citi Private Bank, a business of Citigroup Inc. providing banking, investment and other products and services through various Citigroup affiliates, including the Citigroup affiliates listed in the “Note” below, describes what privacy means for you as a client of the Private Bank and such Citigroup affiliates when they provide products and services to you through the Private Bank. Security of Personal Information The security of personal information about you is our priority. We protect this information by maintaining physical, electronic and procedural safeguards that meet applicable law. We train our employees 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. A Citi Private Bank Relationship You probably chose the Citi Private Bank for its global reach and its ability to offer you the wide range of products and services available through Citigroup affiliates. While information is essential to our ability to provide superior service and appropriate product offerings to you, we also believe your trust in our handling of that information is one of our most important assets. About this Notice We prepared this notice to let you know what privacy means for you as a client of the Citi Private Bank and the Citigroup affiliates listed below when they provide products and services through the Private Bank, and to help you understand what information is collected, how it is protected and the circumstances under which it may be disclosed. This notice replaces our prior notice. We may change this notice from time to time. If we do, we will notify you as required by applicable law. Please note that if you establish or maintain an account, credit, product or service with any Citigroup affiliate listed below other than through a Private Bank relationship, with any other Citigroup affiliate through a Private Bank referral, or directly with any other Citigroup affiliate, you may receive a notice from that Citigroup affiliate regarding its privacy practices. The practices described in that notice and not the practices described here will apply to that relationship. Your Private Bank Team can assist you with obtaining the information needed to contact that affiliate if you wish to discuss their privacy notice. Information We Collect and UseClients expect us to know who they are when they call us for service. We collect and use information in order to help us meet those expectations and to serve their individual needs. What’s more, we use that information to tailor Citi product and service offerings to different client needs and to enable us to extend those offers at appropriate times in their lives.   At the same time, by maintaining information, we eliminate the inconvenience of requiring clients to supply us with the same data over and over again. In addition, we collect and use information to meet legal and regulatory standards (e.g., “Know Your Customer” requirements) and to operate prudently (e.g., managing credit risk).   We collect nonpublic personal information about clients from applications, other forms or documentation, clients’ transactions or communications with us, and from Citigroup affiliates or nonaffiliated third-parties, such as credit bureaus and personal references. Information We Disclose We do not disclose nonpublic personal information about Private Bank clients or former clients, except to bring them products and services available through the Citi Private Bank, to help serve their individual needs, to companies that perform marketing, research and services on our behalf, or as permitted or required by law. Inquiries If you have any questions about any of the above information, please call your Private Bank Team. Note: “Citi Private Bank” is a business of Citigroup Inc. providing products and services to private banking clients through various Citigroup affiliates, including Citibank, N.A., Citicorp North America, Inc., Citicorp Trust, N.A., Citigroup Trust - Delaware, N.A., Citicorp Trust South Dakota, Citigroup Institutional Trust Company, Citicorp USA, Inc. and Citigroup Global Markets Inc. ^ back to top

Your online security is of utmost importance to us. We believe that good security covers all the bases—sophisticated technology, as well as the most stringent principles of privacy. Much of our work takes place behind the scenes, but occasionally we’ll ask you to provide a new password or perhaps added questions to help us identify you. Below we outline a few of the ways we safeguard your online experience and offer a few suggestions to help you ensure your online security. How we protect your online security Strong Encryption - To ensure security while accessing our password-protected client Web site, Citi Private Bank employs 128-bit encryption and Secure Sockets Layer. 128-bit encryption, the strongest level of encryption generally available today, means there are 2128 possible combinations of keys but only one that will unlock the information. Secure User Name and Password – You select your preferred user name and password for the client Web site, and these items must be entered every time you sign-in to the Private Bank’s Internet site. For information security reasons, you will be instructed to change your password periodically. Automatic Time Out - When there is no activity for 15 minutes, your session will be terminated to help protect against unauthorized access. Client-Driven Authentication Questions – When you call Global Web Services and Support with questions about the Web site, we must confirm your identity on the phone before discussing your account information. The questions and answers you select when logging into the Web site for the first time are used for this identification process. How can you protect your online security Along with the security measures used by the Citi Private Bank Web site, there are measures you can take to ensure the security of your computerized personal information: Use anti-virus, anti-spy ware, and pop up blocker software Keep your Operating System updated with the latest security updates and patches. Review your Internet security settings Be wary of emails from addresses or people you do not know Watch out for phishing email scams Avoid using “public” computers or network connections, especially when reviewing financial information Protect your laptop and other portable electronic devices Clear your browser’s cache Back up your personal data and store backups in a secure location Keep your password confidential and avoid using the same password for different Web sites ^ back to top

What is encryption? What is it used for? Encryption technology allows information to travel securely on the Internet. Using a mathematical formula, information is encoded, or "scrambled", by the sender. The receiver must decode, or "de-scramble" the information by using the corresponding "decoder". Without the corresponding "decoder", the information would be unusable. Encryption technology can be used for a host of applications, including electronic commerce (sending credit card numbers for orders or transmitting account information), e-mail messages, and sensitive documents. ^ back to top

How secure is encryption? How secure is the Private Bank's Internet site? The effectiveness (or level of security) for encryption is measured in terms of how long the key is -- the longer the key, the longer it would take for someone without the correct "decoder" to break the code. The length of the key is measured in bits. The level of encryption used with many ordinary browsers is 40-bit, while the level of encryption required to use the Private Bank's Internet site is 128-bit. For a 40-bit key, there are 240 possible different combinations. For a 128-bit key, there are 2128 possible different combinations. All transmission of customer information through the Private Bank's Internet site is encrypted using 128-bit encryption technology, which is currently the strongest encryption level that is generally available. Your browser is probably 40-bit if you haven't specifically downloaded 128-bit. ^ back to top

What are some good security practices that I can use? When using any Web site that contains your personal data, be aware of the following to help keep your information secure and private. Also, remember to check your information frequently. If you spot any discrepancies, report them immediately to a member of your Private Bank team. Public Access Computers Using an Internet cafe, airport Internet kiosk, or any other shared computer to access your personal data may be convenient, but you must be aware of the potential risk involved. If you do not clear the browser's cache on the computer you use, someone else might be able to access your personal data. Also, be wary of people that may look over your shoulder - they could potentially see your login ID, password, or personal data as you use a Web site. Web Site Authenticity One way to determine the authenticity of the Web site is to compare the URL, found in your browser’s Location or Address window, with the bank name found in the digital certificate. If you’re accessing Citi Private Bank’s Web site, you should see a URL that starts with any of the following: https://www.privatebank.citibank.com https://www1.privatebank.citibank.com https://www2.privatebank.citibank.com https://www3.privatebank.citibank.com https://www4.privatebank.citibank.com Cached Data As you use any Web site, pages, images and files that you browse or download may be stored on your computer to enhance performance. Clearing your browser's cache ensures that these local copies are removed. Your Password Keep your password confidential and change it frequently. You can change your password in the Preferences section of the private client Web site, after you sign in. Avoid using the same password for different Web sites, applications, or services, particularly when they relate to different entities. We would advise you, for your own security, not to use common information such as your birthday, telephone number or a recognizable part of your name as your password. We also advise that you do not use the same or similar user name or passwords for accessing other services (such as your user name and password for connection to the internet or to access other Web sites). For your protection, please do not access the Citi Private Bank client Web site through hyperlinks embedded in e-mails. This will avoid the possibility of being directed to fake Web sites, which may seek to obtain financial information about you, for example, by asking you to disclose confidential information such as account numbers. ^ back to top

What is the process for reporting and handling suspected security incidents? Citi Private Bank is committed to offering our customers the highest level of support possible. If you suspect that there has been any un-authorized breach of your account(s) online, or that an online transaction has taken place that you did not initiate, you should notify Citi Private Bank immediately. If the circumstances require, security incidents will be escalated to our technical support staff for evaluation. If any breach of security appears to have occurred, Citi Private Bank will investigate it further. If necessary, Citi Private Bank will provide you an interim update of our investigations and the status of your case. Final resolution of any such incident, though, will depend on the nature and complexity of the incident, as well as the details surrounding the case. ^ back to top

How do I clear my browser's cache? After you sign off from the private client Web site, you may want to clear your browser's cache to ensure your privacy, especially if you are using a computer that other people have access to. As you use any Web site, pages, images and files that you browse or download may be stored on your computer to enhance performance. Clearing your browser's cache ensures that these local copies are removed. Instructions for clearing your browser's cache are listed below. If you're running a browser other than those listed below and would like more information on how to clear your browser's cache, please refer to your browser's help file. Internet Explorer 5.x or 6.x for Windows Choose "Internet Options..." from IE's Tools menu Locate the "Temporary Internet files" heading, click the "Delete Files" button, and choose "OK" when prompted. Locate the "History" heading, click the "Clear History" button, and choose "OK" when prompted. Click the OK button at the bottom of the Internet Options window. Close and re-start your browser. Netscape 7.2 for Windows Choose "Preferences" from the Edit menu Select "Advanced" Select Cache, then click the "Clear Cache" button Click OK Close and restart your browser Firefox 1.0.7 for Windows Choose "Options" from the Tools menu Click "Privacy" Select the Cache tab Check the "Clear " button Click OK Close and restart your browser Firefox 1.5 for Windows Choose "Options" from the Tools menu Click "Privacy" Select the Cache tab Check the "Clear Cache Now" button Click OK Close and restart your browse Safari 1.2.2 for Macintosh Choose "Empty Cache" from the Safari menu Click Ok Close and restart your browser Automatic Cache Clearing for Internet Explorer Users Choose "Internet Options" from the Tools menu. Select the Advanced tab. Check "Empty Temporary Internet Files folder when browser is closed," located under Security. Click OK Close and restart your browser. Automatic Cache Clearing for Firefox Users Choose "Options" from the Tools menu. Click the "Privacy" icon. Click the "Settings" button at the bottom of the Options window. Check "Cache" under "Select the items to be cleared." Check "Clear private data when closing Firefox" under "Settings." Click OK Close and restart your browser. ^ back to top