Kroger Personal Finance: Kroger Privacy Notice

One of our most important responsibilities to you, our customer, is the safekeeping of the nonpublic personal (“confidential”) information you have entrusted to us and using this information in a responsible manner. Appropriate use of the confidential information you provide us is also at the heart of our ability to provide you with exceptional service whenever you contact us. We are providing you with this important notice to inform you of how we use and protect your confidential information.

This Privacy Notice protects customers who have opened a Credit Card account with us, our former customers, and consumers who have provided confidential information to us but have not entered into a customer relationship. If you have selected a credit insurance product, you will receive a separate policy from Central States Indemnity Co. of Omaha.

We encourage you to read and retain this notice and to call us if you have any questions. This Privacy Notice applies to Kroger Personal Finance. RBS Card Services, a division of RBS Citizens N.A., has a separate privacy policy for its other card services. Other divisions of RBS Citizens, N.A., also have a separate privacy policy. This Privacy Notice enables you to make an informed decision about the sharing of your confidential information with RBS Citizens, N.A.’s affiliates and nonaffiliated third parties. RBS Citizens, N.A.’s affiliates are the family of companies controlled by Citizens Financial Group, Inc.(“Family of Companies”).

We are committed to providing you with exceptional personal service and to safeguarding your confidential information.

We will safeguard, according to prudent security standards, the confidentiality of all confidential information you provide us.

We limit the collection, use and retention of confidential information to what we believe is necessary to administer our business, to provide you with exceptional quality service, to comply with regulatory retention of confidential information, and to make available to you other accounts, services, and opportunities that may be of benefit or interest to you. For example, your confidential information may be used to evaluate your eligibility for a loan or other service, to improve our accounts and services or the way we are able to deliver them to you, to protect you from fraud or to create specific Program offers for you or otherwise improve the Program.

When you visit our website, you will be assigned a permanent “cookie” (a small, unique identifier text file) to be stored on your computer's hard drive. The purpose of the cookie is to identify you when you visit our site so we can enhance and customize your online experience.

We also collect certain technical information from your computer each time you request a page during a visit to our websites. This information may include your Internet Protocol (IP) address, your computer's operating system, browser type and the address of a referring website, if any. We collect this information to enhance the quality of your experience during your visit to our site and for system administration, security and troubleshooting purposes. We will not sell or rent this information to any third parties. While cookies are optional and can be disabled on your computer, cookies are required to provide optimal use of our website and to access certain portions of our website, including logging in or purchasing items.

Information we receive from you on applications, forms, or other information that you provide to us – for example, your income, where you work, telephone number, or social security number;
Information we obtain at your request – for example, your fax number, your e-mail address, or information that we need to complete a transaction that you authorized;
Information about your transactions with us – such as purchases, account balances, or account usage;
Information we receive from a consumer reporting agency – such as your creditworthiness, your employment verification, credit score, or your payment history;
Information from your browser about your Internet usage when you visit our website or the Program website;
Information we receive from others, including public sources;
Information from Kroger Personal Finance™ regarding your use of the Program; and,
Information from Kroger and its affiliates regarding your participation in and use of the Shopper’s Card program.

A fundamental element of safeguarding your confidential information is to provide protection against unauthorized access or use of this confidential information. We maintain physical, electronic and procedural safeguards designed to comply with federal guidelines to guard your confidential information against unauthorized access or use. Our employees are subject to a corporate code of ethics and other policies that require maintaining the confidentiality of customer information.

We may share all the collected information about you within our Family of Companies, as permitted by law. For example, we have centralized processing areas that may service your account, or make credit decisions, or prepare statements for a number of companies or business divisions. Our employees may access information about you in order to maintain your accounts, to complete a transaction that you authorized, to notify you of new products or special offers, or otherwise meet your needs. We may also access information about you when considering a request from you for additional services, to protect against fraud, or when exercising our rights under the law or any agreement with you.

We are permitted by law to share certain confidential information about you within our Family of Companies that we gather internally from our transactions and experiences with you, such as your name, address, account balance and payment history.

We may also share other credit-related confidential information about you within our Family of Companies that we obtain from external sources, such as information relating to your creditworthiness gathered from credit applications and credit reports. You may instruct us not to share this information within our family of companies by selecting Option 2 in this notice.

SHARING INFORMATION WITH KROGER PERSONAL FINANCE, KROGER AND ITS AFFILIATES

To enable us to provide you the Program benefits and services you requested when you applied for the Credit Card, we will share information regarding your account with Kroger Personal Finance, and as permitted by law and the terms of the program with Kroger and its affiliates. This information allows Kroger Personal Finance to provide you with Program rewards and other benefits pursuant to the Program terms provided to you when you were approved for your Credit Card account. Kroger Personal Finance, Kroger and its affiliates will also use this information to offer you additional Program promotions, enhanced Program reward offers and other opportunities to earn rewards in the Program from time to time.

To 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;
To third parties that assist us in marketing our accounts and services;
To insurance companies that underwrite insurance we arrange for our customers;
To consumer reporting agencies;
To third parties that process or service a financial product, service or transaction that you requested or authorized;
To respond to a subpoena, court order or judicial process;
To pursue a sale, merger, or transfer of all or a portion of a business or operating unit;
To our regulators and auditors;
To protect against or prevent fraud, manage risk, or resolve customer disputes; or,
To a third party to whom you specifically authorize us to share the information.

Whenever other companies or third parties provide services for us or on our behalf, we require them by contract to maintain the confidentiality of the information that we provide them.

Because certain disclosures of confidential information are specifically required or permitted by law, we can make these disclosures even if you prefer we do not do so.

We may share information with unaffiliated companies outside the Family of Companies that are able to extend special offers for products and services that we feel may be of value to you.

If you do not want us to share certain confidential information, please let us know by calling us at the toll-free number listed at the end of this notice or writing to us at the address listed at the end of this notice. Your written request should include your name, address, telephone number and account number. An opt-out request by any party on a joint account will apply to all parties on the account.

We will process your request within a reasonable time after receipt; however , please note that you may continue to receive offers in process before your request was received and processed by us.

SHARING OUTSIDE OUR FAMILY OF COMPANIES (not applicable to California and Vermont residents)

Select Option 1 if you do not want us to share your confidential information with companies outside our Family of Companies (other than disclosures permitted by law).

For California and Vermont Residents, state law limits how we share information about you. We have chosen to limit the sharing of information in the following manner.

If you are a California Resident, we will automatically treat accounts with California billing addresses as if you have directed us not to share non-public personal information with companies outside our Family of Companies.

If you are a Vermont Resident, we will automatically treat accounts with Vermont billing addresses as if you have opted out of the sharing of non-experience information within our family of companies and opted out of the sharing of confidential information outside our Family of Companies, without requiring you to write to us to opt out. In addition, if we disclose confidential information about you to other financial institutions with whom we have joint marketing agreements (as described in “Sharing Information with Third Parties Outside our Family of Companies”), we will only disclose your name, contact information and information about your transactions.

We offer the following guidance on how you can help us protect your confidential information:

• We ask that you do not send confidential information (credit card numbers, account numbers, social security numbers, etc.) to us by e-mail. E-mail may be intercepted and is not necessarily a secure environment for confidential information.

• It is extremely important that you protect your password and PIN, because this is your best defense to unauthorized access to your accounts. We recommend that you do not share your password and PIN information.

• Review your statements promptly and notify us of any unauthorized transactions.

Our website may allow you the opportunity to review your credit card account. Please review the website Privacy Notice by clicking the “Privacy Notice” links located on our website, listed at the end of this notice.

This Privacy Notice supercedes all previously issued confidentiality and confidential information sharing disclosures. We reserve the right to change this Privacy Notice, and any of the practices described in the disclosure, at any time upon proper notice to you. We are dedicated to providing you with exceptional service and to ensuring your trust. If you have any questions regarding this notice, please call us toll-free at the toll-free number listed at the end of this notice and a customer service representative will be pleased to discuss any aspect of our Privacy Notice with you. Thank you for your business.

EFFECTIVE April 1, 2008