Privacy Notice

RESPONSIBLE USE AND PROTECTION OF CUSTOMER INFORMATION

EFFECTIVE SEPTEMBER 1, 2009

RBS Card Services, a division of RBS Citizens, N.A., is the issuer of your Kroger Personal Finance credit card. Kroger Personal Finance is a joint venture between The Kroger Co. and Citizens Financial Group, Inc. Kroger Personal Finance is responsible for the operation and administration of the credit card benefits program (the Program) and provides the Program benefits and services described in the credit card agreement which you requested when you applied for the credit card. In this notice, when we refer to we, our or us, we mean RBS Card Services.

We are providing you with this important notice to inform you of how we use and protect your nonpublic personal information, including financial information that we obtain in connection with your application for and use of your credit card. In this notice, we will refer to that personal information as your Information. Information gathered through your participation in the Shopper's Card program is subject to the Kroger Co. Privacy Policy found at www.kroger.com, as amended from time to time.

Your trust is our most important asset, which is why one of our foremost responsibilities to you is the safekeeping of your Information and the use of your Information in a responsible way. Appropriate use of your Information is also at the heart of our ability to provide you with exceptional customer service whenever you contact us.

This notice applies to customers who have opened a credit card account with us, former customers, and consumers who have provided us with Information but have not entered into a customer relationship. If you have selected a credit insurance product, you will receive a separate notice directly from your insurance service provider. We encourage you to read and retain this notice and to call us if you have any questions.

This notice applies to the card issued in connection with the Program offered by Kroger Personal Finance. RBS Card Services has a separate privacy notice for its other card services, and other entities within our family of companies have separate privacy notices. This notice enables you to make an informed decision about our sharing and use of Information within our family of companies and nonaffiliated third parties. Our family of companies are those banks and companies controlled by Citizens Financial Group, Inc.

The following companies are within the Citizens Financial Group family of companies: Citizens Bank of Pennsylvania, RBS Citizens, N.A. which does business through its divisions, including Citizens Bank, Charter One, and CCO Mortgage, KPF Mortgage, LLC, Southeast Mortgage Group, LLC, Complete Mortgage, LLC, First NH Mortgage Corp., Citizens Automobile Finance, Inc., Citizens Automobile Finance Corp., CCO Investment Services Corp., Citizens Financial Services Insurance Agency, Inc., Citizens Insurance Agency of New York, Inc., RI Realty Trust, Inc., Citizens Auto Receivables, LLC and other banks or companies that may be acquired or established from time to time.

We are committed to providing you with exceptional personal service and to safeguarding your Information. The following is our continuing commitment to the responsible use and protection of your Information:

COLLECTION, USE, AND RETENTION OF YOUR INFORMATION

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

INFORMATION COLLECTION

We may collect Information about you from the following sources, such as:

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

OUR PROTECTION OF YOUR INFORMATION

The security of your Information is important to us. We maintain physical safeguards, such as shredding documents and securing buildings, electronic safeguards, such as encyrption and monitoring, and procedural safeguards, such as customer authentication procedures, to guard your Information against unauthorized access or use. We limit the access by our employees and agents to Information that we believe is reasonably necessary to maintain your accounts, to complete a transaction that you authorized, or otherwise meet your needs. Our employees are subject to a corporate code of ethics and other policies that require maintaining the confidentiality of Information. You have a role in helping us by safeguarding your Information from others and by reviewing your statements promptly.
How to contact us: If you suspect someone has made unauthorized transactionson your accounts with us or if you believe that any Information about you is not accurate, please call us at any time at 1-888-311-0862.

SHARING INFORMATION WITH KROGER PERSONAL FINANCE AND 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 and 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.

We share Information with Kroger Personal Finance and Kroger and its affiliates, including Information from your application; your credit card purchases, your account performance and your credit card number. Kroger Personal Finance and Kroger and its affiliates will use this Information solely in connection with the Program.

SHARING INFORMATION WITH THIRD PARTIES OUTSIDE OUR FAMILY OF COMPANIES

We may share your Information, as permitted by law; for example:

With 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;
With third parties that assist us in marketing our accounts and services;
With other financial institutions with which we have joint marketing agreements to enhance our financial product or service offerings, such as credit insurance providers;
With insurance companies that underwrite insurance we arrange for our customers;
With consumer reporting agencies;
With third parties that process or service a financial product, service, program, or transaction that you requested or authorized;
With third parties that process, service, or administer credit card affinity or Rewards programs that you enrolled in;
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,
With a third party with which you specifically authorize us to share the Information.

We may also share your Information with other companies outside our family of companies to extend special offers for non-financial products or services that we feel might be of value to you. You may tell us not to share your Information with these companies by selecting Option 1 on our Privacy Choices Form or contacting us in the ways that we have outlined in that form.

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.

SHARING AND USING INFORMATION WITHIN OUR FAMILY OF COMPANIES

We may share your Information within our family of companies, as permitted by law. For example, we have centralized processing areas that may service your account, make credit decisions or prepare statements for a number of companies or business divisions. We may also share 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 within our family of companies Information 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 within our family of companies other credit-related Information that we obtain from external sources, such as Information relating to your creditworthiness and other Information gathered from credit applications and credit reports. You have the right to tell us not to share this application and credit-related Information within our family of companies by selecting Option 2 on our Privacy Choices Form or contacting us in the ways that we have outlined in that form.

LIMITING USE OF YOUR INFORMATION FOR MARKETING WITHIN OUR FAMILY OF COMPANIES

You have the right to limit some but not all marketing within our family of companies. Federal law also requires us to give you this notice to tell you about your choice to limit marketing from our affiliates. Your choice to limit the use of this information within our family of companies does not apply to any Citizens Financial Group company that has an existing business relationship with you, where the use is otherwise permitted by law or to Information collected prior to October 1, 2008. You may limit our affiliates (such as our affiliated insurance agencies, securities broker-dealer and banks) from marketing their products or services to you based on your Information that we collect and share with them. This Information may include, among other things, your income, account history and credit score.

Your choice to limit marketing offers from our family of companies will apply for at least five years from when you tell us your choice. Once that period expires, you will receive a renewal notice that will allow you to continue to limit marketing offers from our family of companies for at least another five years.

You may instruct us not to use this Information within our family of companies for marketing purposes by selecting Option 3 on our Privacy Choices Form or contacting us in the ways that we have outlined in that form.

If you ask us to limit the sharing of Information or use of that Information for marketing within our family of companies, you may miss learning of financial products or services that may be of interest to you.

FOR VERMONT RESIDENTS ONLY

If you are a Vermont resident, we will automatically consider that you have selected all three options on the Privacy Choices Form. You will not be required to return the Privacy Choices Form for these elections to apply. In addition, if we do disclose Information about you to other financial institutions with which 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.

FOR CALIFORNIA RESIDENTS ONLY

If you are a California resident, we will automatically consider that you have selected Option 1 on the Privacy Choices Form. Unless you specifically authorize us to do so, we will not disclose Information about you to unaffiliated third parties to market their non-financial products or services. You will not be required to return the Privacy Choices Form for this election to apply. In addition, if we do disclose Information about you to other financial institutions with which 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.

FOR NEVADA RESIDENTS ONLY

Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 West Washington Street, Suite 3900, Las Vegas, NV 89101; telephone number: 1-702-486-3132; email BCPINFO@ag.state.nv.us. Kroger Personal Finance, P.O. Box 42020, Providence, RI 02940-2020.

AMENDMENTS TO THIS NOTICE

This notice is accurate as of the date given and supersedes all previously issued confidentiality and information-sharing disclosures. We reserve the right to change this notice, and any of the practices described in the notice, at any time upon proper notice to you.

YOUR COMMENTS AND QUESTIONS

We are committed 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 1-888-311-0862, and a customer service representative will be pleased to answer your questions about our notice.

PRIVACY CHOICES FORM

If you would like to tell us to not share or use for marketing certain types of your Information as discussed in this notice, you may do so by indicating your preferences below. If you have previously completed this form, there is no need to do so again, unless you wish to change your selections.

Your Privacy Options

☐ Please do not share Information about me with companies outside your family of companies (other than disclosures permitted or required by law).
☐ Please do not share Information about me within your family of companies (other than disclosures permitted or required by law).
☐ Please do not use Information about me within your family of companies for marketing purposes (other than disclosures permitted or required by law).

To complete your request, please provide us with the following information regarding your account(s) with us to which these elections apply:

My Credit Card Account Number(s): ____________________________
My Name: ________________________________________________
My Street Address: _________________________________________
City, State, and Zip: _________________________________________
My Phone Number: _________________________________________
Form ID: KPFPRIVACY

If you have checked any of the above options, either mail this form in a stamped envelope to:

Kroger Personal Finance
P.O. Box 42020
Providence, RI 02940-2020

Or, call us at 1-888-311-0862.

Your privacy choices will apply to all the personal accounts that you have with our family of companies. If you have a joint account, we will treat a request by one party to the account as applying to all parties to the account. The option you request will apply to accounts that each joint account holder has in his or her own name and any accounts the joint account holders have with each other. We will process the choices made on your Privacy Choices Form 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.

CREDIT CARDS