Privacy Policy:

Citizen Capital Markets respects the privacy of any user that accesses its websites, therefore, we are committed to taking all reasonable steps in order to safeguard information related to any existing or prospective clients, applicants or visitors. Before submitting any personal data, a person should examine the given terms and should only continue by agreeing with the Terms in the given Privacy Policy with principles set for data transfer, storage and processing.

Citizen is entitled to unilaterally amend the given principles at any time by notifying the clients no later than 14 days prior to any significant amendments via the Citizen website, emails or through the client portal. In issues not regulated by the given Privacy Policy, the parties shall be guided by the General Terms and Conditions of a respective investment firm.

1. Definitions
• 1.1 Client - means any natural or legal person who has entered into a client relationship with Citizen and is actively using, or has used, the services of Citizen until the termination of the client relationship. A prospective client is a natural or legal person who intends to use the services of Citizen and has made the initial registration for such use of services via the client portal(without concluding the client relationship).
• 1.2 Client Data - means information that is known to Citizen about the client and that is processed by Citizen. When this document refers to ‘personal information’, it means information from which the client`s identity is reasonably apparent. The various categories of client data are specified in point 5 of this document.
• 1.3 Processing of Client Data - means any action that is performed with the client data, including gathering, recording, structuring, safe keeping, changing, forwarding, deleting, archiving, etc.
• 1.4 Data Processor - Legal entities within Citizen capital markets and it's sister company Habibsons capital provides investment services and is the data processor of client’s personal information in relation to those services. In case a client holds trading accounts under multiple Citizen investment firms, there will be more than one Data Processor within the Group.
• 1.5 Authorised Processor - Citizen may also use authorised external processors for client data processing, based on concluded service agreements, which are governed by instructions from Citizen for the protection of client related data.

2. Consent to Process Data
• 2.1 Initial registration - In order to create a Demo account or a Live trading account with Citizen.com, a person must make an initial registration via an Citizen.com website’s registration form, or directly through their clients area and agree with the terms listed in the given Privacy Policy. The Client confirms acceptance of these terms by ticking the corresponding box on the registration form. If such consent is not given, Citizen cannot process a persons’ data, nor provide any services to the person in question.
• 2.2 Attending courses and participating in campaigns - The client’s data will be processed when registering for the offered webinars or seminars, or when landing on any of Citizen campaign pages that require registration – as Citizen will need to use a client’s personal information to perform its services and comply with its obligations. In all such cases, a client’s consent for data processing will be gathered through the registration form that they use to sign up, which subsequently creates login credentials for access to the client portal.
• 2.3 Cancellation of the initial registration - When a person cancels the registration process and does not complete it, that person ‘s data will not be retrieved by Citizen and will, therefore, not be saved for further processing in the future.
• 2.4 Declining the option to be contacted via phone - A person always has the right torequest not to be contacted via telephone by an Citizen representative. This request will be saved within Citizen’s internal systems and acts as a separate restriction which Citizen will, of course, be respected. The request to not to be contacted via telephone does not affect a client from using Citizen’s services. Additionally, this does not restrict said person to contact Citizen by their own initiative.

3.The Purposes of the Collection of Client Data

• Citizen needs to collect various data in order to set a person up as a client, as well as provide various aspects of its services. This data is collected for the below mentioned reasons.

4.Verification of identity
• 4.1 . Citizen is obligated to verify a person`s identity before entering into a client relationship and creating a trading account for the person. For this, Citizen can use third parties which carry out identity checks on its behalf.
• 4.2 To form a profile. In order to comply with legal obligations, Citizen creates a profile about the client, once the full application for a Live trading account has been reviewed and approved by Citizen. Citizen needs to apply the principles of KYC (Know-Your-Client) before entering into a client relationship in order to prevent malicious actions, such as money laundering or terrorist financing, and also to perform other duties imposed by law.
• 4.3 To assess the level of a Client’s investment knowledge. Citizen must assess clients’ investment knowledge, experience and expertise to deem the suitability and relevance of the offered service for the client.
• 4.4 Internal business purposes and record keeping. Citizen needs to process clients’ personal information to comply with its legal obligations and for internal business purposes. Such processing is in Citizen’s own legitimate interests. Citizen will also keep records that ensure that a client complies with its obligations, defined in the Terms of Business of a relevant Citizen or Habibsons investment firm.
• 4.5 Transaction reporting. Citizen is obligated to regularly report to the respective authorities on the market share products and the services held by client groups, as well as other financial figures.
• 4.6 Marketing. Citizen may use client data, such as location or trading history to deliver tailored content, such as news, analysis, research, reports, campaigns and training opportunities that may interest the client, to their registered email address. A client always retains the ability to change their preference if they wish or no longer wish to receive such communications.
• 4.7 Improvement of Citizen products and services. Citizen may, from time to time, use client data to help it analyse and improve its products and services.
• 4.8 To investigate or settle enquiries or disputes. Citizen may need to use collected client data in order to comply with applicable laws, court orders, or other judicial process or requirements of any applicable regulatory authorities. Personal data can also be processed to settle disputes with the client.
• 4.9 To send client surveys. Citizen may send client surveys as part of its customer feedback process as it is in its legitimate interest to ask for feedback to ensure that it provide the best service to its clients.
• 4.10 Website data analysis. Please find detailed review about website data analysis from Citizen Cookie Disclosure.
• 4.11 Security. If a client enters into any Citizen premises, Citizen may record the client’s image on its cameras, for security purposes. Citizen may also use client details to keep a record of who has entered Citizen premises on any given day. It is in Citizen’s legitimate interest to do this to maintain a safe and secure working environment.

5.Categories of Client Data

• Client data may be collected from the client, from the client’s use of the services and from external sources, such as public and private registers. Citizen has the right and the duty by virtue of its area of activity to check the accuracy of the client data contained in the databases by periodically asking the client to review and/or correct or confirm the accuracy of the client data pertaining to the client. Citizen does not collect sensitive information about the client. Client data categories which are primarily collected and processed by Citizen consist of the following:

• 5.1 Identification data – such as name, date of birth, personal identification code and data regarding the identification document (such as copy of the passport or ID card).
• 5.2 Contact data – such as physical address, email address, telephone number and language of communication.
• 5.3 Family data – such as information about the client’s family, heirs and other related person’s (only in cases if a client is related to a politically exposed person or the client has passed away).
• 5.4 Professional data – such as educational and employment details.
• 5.5 Financial data – such as income, assets and liabilities, collected in order to understand the client’s resources and trading activity (for the prevention of any illegal activity).
• 5.6 Data about the origin of assets or wealth – such as data regarding the client`s transaction partners and business activities (for the prevention of, for example, money laundering or the financing of terrorism).
• 5.7 Data that enables Citizen to perform its due diligence measures regarding the prevention of money laundering and terrorist financing and to ensure compliance with international sanctions, including the purpose of the business relationship, true beneficiaries and whether the client is a politically exposed person.
• 5.8 Data about the client’s tax residency – such as country of residence, tax identification number and citizenship.
• 5.9 Communication and activity data – such as visual and/or audio communication data recordings collected when the client visits any Citizen branches, including data related to the client’s visit to Citizen websites and the client portal.
• 5.10 Data related to Citizen services – such as the performance data related to the services of the agreements or the failure thereof, executed transactions, submitted applications, requests, complaints and applied service fees.
• 5.11 Data about habits, preferences and satisfaction – such as data about preferences, satisfaction and activeness of using the services, services used, personal settings, survey responses, etc.
• 5.12 Data about participation in campaigns – such as the points gained and prizes won in games or campaigns.
• 5.13 Data about client’s classification category, level of expertise and previous exposure to the financial market – including the client’s investment knowledge and experience, investment objectives, etc.

6.Contact us by Email or Via Live Chat

• When you email Citizen(via the ‘Contact Us’ page), or using the Live Chat feature, a person may be requested to provide some additional personal data, like their name or email address. Such data will be used to respond to their query and verify their identity. Emails are stored on Citizen standard internal contact systems which are secure and cannot be accessed by unauthorised external parties.

7.Recipients of Client Data

• If necessary, client data is shared with other recipients, such as:

• 7.1 Authorities, such as law enforcement authorities, bailiffs, notary offices, tax authorities, supervision authorities and financial intelligence units.
• 7.2 Legal entities within Citizen. Citizen businesses are supported by a variety of the Habibsons group's teams and functions. Citizen may make personal data available to them, if necessary, for the provision of services, trading platform administration, sales and marketing, customer and technical support. All Citizen employees are required to follow data privacy and security policies when handling personal data. Citizen may process personal data in respect of the website and the client portal in the following locations: United Kingdom, Cyprus, Australia and UAE.
• 7.3 Institutions providing financial services, for example banks, payment systems, institutions participating in the trade execution, settlement and reporting cycle (for example regulated markets as execution venues, multilateral trading facilities, organised trading facilities, trade repositories, local and foreign brokers).
• 7.4 Auditors, legal and financial consultants, or any other processor authorised by Citizen.
• 7.5 Third parties maintaining registers (such as to credit registers, population registers,commercial registers, securities registers or other registers holding or intermediating client data).
• 7.6 Debt collectors upon assignment of claims, courts and bankruptcy or insolvency administrators.
• 7.7 Other persons related to the provision of services of Citizen, such as service providers of archiving and postal services.
• 7.8 Citizen may use other external authorised processors for processing client data. In such cases, Citizen takes the needed steps to ensure that such data processors process client data under the instructions of Citizen with adequate security measures.
• 7.9 Citizen may share client data in the event of a merge, sale, restructure, acquisition, joint venture, assignment, transfer or other disposition of all or any portion of Citizen ’ business, assets or stock (including in connection with any bankruptcy or similar proceedings).

8.Client Rights

• Citizen respects clients’ rights to access and control their personal data. Citizen will respond to requests concerning personal data processing and, when applicable, Citizen will give access to, correct or delete such personal data.

• 8.1 Review of client data processing. Upon request by the client, Citizen shall provide a review of the gathered client data which is available in its client database. Before providing such a review, Citizen will ask the individual to prove their identity in order to reduce the risks of identity fraud. The client will also have the possibility to examine the submitted client data in the Client portal and on the trading platform.
• 8.2 Correction of data. If the personal information Citizen holds concerning the client is inaccurate or incomplete, the client is entitled to have it corrected by Citizen. Citizen may request additional information and documentation required to validate the need for the requested change of data.
• 8.3 Restrict processing. A client may ask Citizen to restrict the use of client data for marketing purposes. The client can change its preferences for receiving such notifications in the client portal, when choosing ‘Subscriptions’.
• 8.4 Deletion. A client may ask Citizen to delete the personal data that it holds. The request to delete an individual’s personal data will result in the closure of their account(s), removal of their data from active processing and a termination of the client relationship. However, Citizen is required to maintain the client’s personal data to comply with its legal and regulatory requirements, as well as in accordance with internal compliance requirements in relation to the maintenance of records. Citizen shall preserve data for at least five years following the termination of the client relationship, unless other terms for the preservation of data or documents are prescribed by law. Unnecessary client data shall be deleted or destroyed.