Privacy

Privacy For Users of CitiFX Pro.com/asia

Our goal is to maintain your trust and confidence when handling personal information about you.

You Have Choices
As a Citibank* CitiFX Pro customer, you have the opportunity to make choices about how personal information about you may be shared and used. As you consider this, we encourage you to make choices that enable us to provide you with quality products and services that help you meet your financial needs and objectives.

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.

About This Notice
This notice tells you how we collect, handle, and disclose personal information about you, and how you can limit this disclosure. It also tells you how you may limit our affiliates from using certain information to market their products and services to you. Please see the Privacy Choices Form at the conclusion of this notice for how to make your choices. If you are a joint account holder, we will accept instructions from either of you and apply them to the entire account. This notice applies to both current and former customers. We may change this notice from time to time. If we do, we will notify you as required by applicable law.

Personal Information We Collect and May Disclose
The personal information we collect about you comes from the following sources:

• Information we receive from you, such as your name, address and telephone number.
• Information that we receive from our affiliates and our/their representatives, and non-affiliated third parties, about you and your financial activities with our affiliates.
• Information about your transactions, such as your trading activities and results, margin balances, and payment history.
• Information we receive from consumer reporting agencies and other sources, such as your credit bureau reports and other information relating to your creditworthiness.

We may disclose any of the above information that we collect to affiliates and nonaffiliated third parties as described below.

The term “personal information” as used in this notice means information that identifies you personally. We may use information which does not personally identify you to help manage our businesses and to develop products that provide us, our affiliates, and other companies insight into consumer investment behavior. We may do this even if you ask us to limit disclosure of personal information about you, as described in the Privacy Choices Form.

Affiliates to Whom We May Disclose and From Whom We May Receive Personal Information
Our affiliates are the family of companies controlled by Citigroup. Affiliates to whom we may disclose and from whom we may receive personal information about you are in several different businesses, including banking, credit cards, consumer finance, insurance, and securities. Our affiliates include those doing business under the Citi name, such as CitiFinancial and CitiMortgage, as well as Smith Barney and Primerica.

Nonaffiliated Third Parties to Whom We May Disclose and From Whom We May Receive Personal Information

Nonaffiliated third parties are those not part of the family of companies controlled by Citigroup. We may disclose personal information about you to the following types of nonaffiliated third parties:

• Agents or sub-contractors who have been assigned or sub-contracted any services or functions performed by any Citi group company in connection with the operation of CitiFX Pro and the provision to you of related services or information (including, without limitation, Saxo Bank and its affiliates),
• Financial services providers, such as companies engaged in banking, credit cards, consumer
  finance, securities, and insurance, and
• Non-financial companies, such as companies engaged in direct marketing and the selling of

If you fill in Box 1 on the Privacy Choices Form, we will not disclose personal information about you to nonaffiliated third parties except as follows.

First, we may disclose information about you as described above in “Personal Information We Collect and May Disclose” to third parties that perform marketing services on our behalf, or provide introductions or referrals to us or our affiliates, or to other financial institutions with whom we have joint marketing agreements.

Second, we may disclose personal information about you to third parties as permitted by U.S. or Hong Kong law or regulation, such as disclosures necessary to process and service your
account and transactions, to protect against fraud, and to protect the security or confidentiality of our records.

Third, we may disclose personal information about you to Saxo Bank and its affiliates and to any other agent or sub-contractor who have been assigned or sub-contracted any services or functions performed by any Citigroup company in connection with the operation of CitiFX Pro and the provision to you of related services or information.

More information on the use, collection and sharing of your personal information can be found in the Client Agreement.

Your Privacy Choices

This section describes your privacy choices. Please remember that we will continue to protect personal information about you regardless of your privacy choices.

Your privacy choices will apply only to your CitiFX Pro account. If you are a customer of another Citigroup affiliate or Citibank business and you receive its privacy notice, you should also review that privacy notice since you may need to separately notify that entity of your privacy choices.

Limit Disclosure to Nonaffiliated Third Parties (Box 1)
As described in this notice, we will limit the personal information about you that we disclose to nonaffiliated third parties if you fill in Box 1 on the Privacy Choices Form. However, we may still disclose personal information about you and your transactional activity with respect to your CitiFX Pro account, with those nonaffiliated third parties that have introduced or referred you to us.

Limit Sharing with Citigroup Affiliates (Box 2)
Our ability to share information with our affiliates helps us to more easily provide you with quality products and services to meet your financial needs and goals. The laws of the United States allows us to share with our affiliates any information about our transactions or experiences with you including, without limitation, your account history, and also your name, address, telephone number, and any information necessary to process and service your account and transactions, to protect against fraud, and to protect the security or confidentiality of our records. Unless otherwise permitted by U.S. or Hong Kong law or regulations, we will not share with our affiliates other information that you provide to us or that we obtain from third parties (for instance, credit bureaus) if you fill in Box 2 on the Privacy Choices Form. However, we and our affiliates, and our/their representatives may still from time to time disclose between themselves any personal information concerning you and your transactional activity with respect to your CitiFX Pro account.

Limit Marketing by Citigroup Affiliates (Box 3)
Relevant Federal law gives you the right to limit some, but not all marketing from our affiliates. You may limit our affiliates from marketing their products and services to you based upon personal information about you that we collect and share with them. This information may include your account history with us. If you fill in Box 3 on the Privacy Choices Form, we will tell our affiliates to limit their marketing to you based upon this information, unless otherwise permitted by law, such as if you currently do business with one of our affiliates.

Information for Vermont and California Customers
In response to Vermont regulation, we will automatically treat accounts with Vermont home addresses as if you filled in Box 1, Box 2 and Box 3 on the Privacy Choices Form. And if we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transactions or experiences with you.

In response to a California law, we will automatically treat accounts with California home addresses as if you filled in Box 1 on the Privacy Choices Form and will not disclose personal information about you to nonaffiliated third parties except as permitted by the applicable California law. We will also limit the sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us. To further restrict sharing with and marketing by affiliates as described in this notice, you can fill in Box 2 and Box 3 on the Privacy Choices Form.

Privacy Choices Form
Your Choices to Limit Information Sharing and Marketing

To limit disclosures of personal information about you, or to limit marketing offers by our affiliates, as described in this notice, you can call us toll free at the Customer Service number shown below. Or you can fill in the appropriate box or boxes to indicate your privacy choices and send the form to the address listed below.

1 Limit the personal information about me that you disclose to nonaffiliated third parties.