CIT Online Privacy Practices Policy: Non-US

Last Updated: August 5, 2010

Introduction


CIT respects your privacy and appreciates that you have provided us with your personal data. This Privacy Statement explains the basis on which we may process any personal data that we collect from you. It describes:

• Personal data we collect;

• How we collect your personal data;

• The purposes for which we use your personal data;

• How we use Cookies;

• When we may disclose your personal data;

• How we protect the security and confidentiality of your personal data; and

• How you can contact us.

Please read this Privacy Statement carefully.


Personal data we collect

We collect the following types of personal data about you:

• Personal details, such as name, age, occupation and marital status;

• Contact details, such as address, telephone, e-mail addresses, in-private and work-related contact details;

• Identification documents, such as your passport, national identity card or driver’s license, as required by laws and regulations regarding due diligence and related matters;

• A personal identifier such as, depending on your country of residence, your National Insurance Number, Tax File Number, etc.; and

• Financial Information, including source of wealth and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources.

Of course, you are not required to provide any of the personal data that we may request. However, if you decline to provide any of the personal data we may require, then we may be unable to open or maintain your account or to provide services to you or your company. To ensure that information that we hold about you is accurate, complete and current, please notify us if there are any changes to your personal data while you have an account with us.


How we collect your personal data

Personal data that we collect from you is derived primarily from information that you provide to us during the course of your relationship with CIT. Typically, we obtain personal data about you from the account application documents and forms used, your transactions activity, your access to or use of our products and services or from third parties authorized to provide us with such information. We also collect personal data when we record our communications with you or through use of certain technology as discussed below.


Purposes for which we use your personal data

We may process and use your personal data to:

• Administer and operate services consistent with customer documents (including authorizing or confirming transactions and for billing purposes);

• Conduct operational support and development of our businesses;

• Perform credit, anti-money laundering and conflict checks for fraud prevention purposes (this may also include consideration of information regarding political affiliations and criminal offences committed or alleged to have been committed);

• Contact you about other CIT products and services;

• Exercise and defend our legal rights;

• Comply with legal and regulatory obligations and requests anywhere in the world (e.g., complying with court orders);

• Record or monitor communications (e.g., e-mail, fax, telephone and other electronic communications), with you or your agent(s) for quality control and security purposes and as a record of your orders, instructions and related matters;

• Comply (and monitor compliance) with applicable laws and regulations, our agreements and any applicable policies and procedures; and

• As otherwise permitted under any applicable law or regulation.


How we use the information we collect

CIT uses certain technology on its websites to collect information from visitors and users to compile aggregate statistical information about how our websites are used, including information relating to the frequency of visits, IP addresses, average length of visits, and pages viewed during a visit. We also use this information to improve the website content and performance.

CIT neither collects individually identifiable information nor monitors individual visitor behaviour.

Information held in cookies set by CIT is kept to a minimum and can only be read by someone who has physical access to your personal computer. Cookies help us improve our site and to deliver a better and more personalized service to you. You may decline to accept cookies by activating the setting on your browser that allows you to refuse cookies. However, if you select this setting, you may be unable to access certain parts of our site. Unless you have adjusted your browser setting to refuse cookies, our system will issue cookies when you log on to the CIT website.


When we may disclose information you provide to us

You should be aware that CIT neither:

• Sells, rents or trades your personal data; nor

• Discloses your personal data, except as described in this Privacy Statement.

Our processing and use of your personal data, as specified in this Privacy Statement, may include disclosure of your personal data:

• To other persons processing your personal data on our behalf or otherwise providing us or them with professional or other services;

• To third parties such as settlement agents, overseas banks or exchange or clearing houses in providing products and services to you;

• To credit reference, fraud prevention and other similar agencies, and other financial institutions with whom information is shared for credit and money laundering checking;

• To persons to whom we assign or novate our rights or obligations;

• To a prospective buyer or seller in the event that we sell or buy any business or assets, or if all or substantially all of our assets are acquired by a third party, in which case personal data held by CIT about its customers may be one of the transferred assets; and

• To national and international regulatory, enforcement or exchange bodies or courts anywhere in the world as required by applicable laws or regulations anywhere in the world or at their request.

These disclosures may involve overseas storage and other overseas transfer, processing and use of your personal data, and disclosure to these third parties, including in or to countries which may not offer the same level of protection of personal data.


How we protect the confidentiality and security of your personal data

CIT uses reasonable measures to protect personal data from unauthorized access, deletion or alteration. To that end, we have physical, electronic, and procedural safeguards to protect any personal data that you provide to us from accidental or unauthorized loss, misuse, damage, modification, access or disclosure.

Third parties who process your personal data on our behalf are required to adhere to confidentiality standards with respect to such information.


Your rights under data protection laws

If you wish to access a copy of your personal data, modify personal data which we hold about you, or you want CIT to cease processing any of your personal data, you can do so by written request to the CIT Data Protection Counsel at the address noted below.

For requests to access personal data, we reserve the right to charge an appropriate fee, if applicable. As a security precaution, you may be required to supply a valid form of identification to assist us in preventing unauthorized disclosure of your personal data. We will process your request within the time provided by applicable law.


Changes to this Privacy Statement

CIT may update this Privacy Statement from time to time. You should periodically check the effective date at the top of this webpage to learn of any revisions.


How you can contact us

Should you have questions about this Privacy Statement, please contact us by e-mail at privacy.questions@cit.com.