Privacy Policy

This Privacy Policy sets out how Citizend Operations Ltd. (“Citizend” or “we”), obtains, records, holds, and processes the data and personal information you (“you” or “user”) share when using this Website, the Citizend App, and any other product or service made available to you are referred herein as the "Services" (regardless of where you visit it from) and when you use the Services. It will also tell you about your rights and how you can contact us if you have any concerns.

You agree to be bound by the terms of this Privacy Policy. Citizend may review the Privacy Policy periodically and reserves the right to change the Privacy Policy at any time at its sole discretion by posting such changes within the Services, for example, on the Website. Changes will be effective immediately when posted. By using the Services you are agreeing to be bound by the then-current version of this Privacy Policy. We encourage you to review this Privacy Policy on a regular basis for the latest version.

This Privacy Policy applies only to your use of the Services, including newsletter subscription and any promotion/offers we make available from time to time. It does not extend to any websites that are linked to or from our site (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored, or used by third-party websites you connect to and we advise you to check the privacy policies of any such websites before providing any data to them.

1. Personal information and additional data:

“Personal information” refers to any data, information, or combination of data and information that is provided by you to us, or through your use of the Services. Personal information does not include data where the identity has been removed (anonymous data). We may collect, use, store, and transfer the following types of personal information:
a. Personal information provided by users to us including name, email, residential address, contact information, birth date, gender, nationality, photograph, signature, occupational history, job title, income, assets, other financial information, bank details, investment history, tax residency, tax identification information, and IP address.
b. Personal information collected or generated by us, including information related to emails (and related data), correspondence, call recordings, and website usage data.
c. Personal information obtained by us from other sources, including Know Your Customer(“KYC”) / Customer Due Diligence procedures (Anti-Money Laundering (“AML”), Counter Terrorist Financing (“CTF”), Proliferation Financing, Sanctions, Politically Exposed Persons), tax purposes (US Foreign Account Tax Compliance Act (“FATCA”), OECD Common

Reporting Standard (“CRS”), future regulatory, securities and tax requirements, information from public websites, public sources of information, and information received from your advisors or intermediaries. Where we require personal information to comply with AML, CTF, Proliferation Financing, Sanctions, or other legal requirements, failure to provide such personal information may prohibit us from accepting a user, and we may ultimately terminate the relationship as a result.

We may also collect, use, store, and transfer the following types of data:
a. Technical Data: includes IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Services.
b. Usage Data: includes information about how you use the Services.
c. Communications Data: includes your preferences in receiving marketing from us.

2. Collection of Data and Collection Purposes

Citizend will collect your personal information only by lawful and fair means and not in an intrusive way. Citizend uses different methods to collect information from and about you including through:
a. Direct interactions. You may give us your information by filling out a form, signing up for the Services or newsletter, signing a contract with us, via email or social media communications, interacting directly with a member of our team, be it in person or electronically, or providing services to us;
b. Automated technologies or interactions. As you interact with the Services, we will automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies; or
c. Third parties or publicly available sources. We may receive personal information about you from third parties such as analytics providers (technical data), KYC, and other service providers and public records.

We collect data for the following purposes:
a. Compliance with a legal obligation including where it is necessary to comply with any applicable current or future legal, regulatory, or tax requirements imposed on Citizend and/or any third-party service provider. Citizend will process users’ personal information in accordance with legal obligations under company law, tax law, AML, and CTF legislation;
b. Enhancement of user experience through the use of data analytics and cookies to improve the Services, marketing, customer relationships, and experiences;
c. Administration and protection of our business and the Services, including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data.

3. How We Store the Information We Collect

We will not keep personal information for longer than is necessary to satisfy the purpose or purposes for which the personal information was collected or processed. We will retain personal information for a period of seven (7) years after the end of the business relationship or as long as required for us to comply with applicable legal or regulatory obligations, or establish, pursue, maintain, or defend legal claims or proceedings.

4. How We Keep Your Information Safe

We are committed to securing personal information from our users. In order to safeguard against unauthorized or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, personal information, we have established appropriate physical, electronic, and managerial procedures. However, processing and transmission of personal information via the internet is not entirely secure and, whilst we make all reasonable efforts to protect it, we cannot guarantee the security of online personal information transmission. Any information which you transmit to Citizend is transmitted at your own risk. However, once Citizend receives your transmission, Citizend will take reasonable steps to protect your personal information from misuse, loss, and unauthorized access, modification, and disclosure. Ultimately, you are solely responsible for maintaining the secrecy of your username, password, and any account information. Please be careful whenever using the internet and the Services.

5. Transfer of Personal Information

Where a personal information transfer is made to a jurisdiction that provides a lower level of data protection, we will take steps to ensure the security and confidentiality of personal information.

6. Your Rights

a. Request in writing a copy of, or access or rectification to, your personal information;
b. Request in writing a description of:
i. Your personal information;
ii. The purposes for which your personal information is being or is to be processed;
iii. The recipients to whom your personal information is or may be shared by us or on our behalf;
iv. Any countries or territories outside of the BVI to which we, whether directly or indirectly, share, intend to share, or seek to share your personal information; and
c. Request in writing that we stop processing, not begin processing, or specify your personal information for a specified purpose, subject to applicable legal restrictions;
d. Request in writing that we ensure that no decision taken on our behalf that significantly affects you is based solely on automated processing; and
e. Request in writing that we stop or not begin processing your personal information for direct marketing purposes.

7. Use of the Services

By using the Services, you agree to Citizend collecting and processing your personal information on the basis explained in this Privacy Policy. If you have any queries, requests for access or correction, or complaints relating to the handling of your personal information, please contact us by email: legal@citizend.xyz.

8. Updates to this Privacy Policy.

This Privacy Policy undergoes regular review and may be modified or updated from time to time. Modifications and updates to this policy are effective from the publishing date. You should review this Privacy Policy regularly and remain familiar with its terms.