Privacy Policy

Section 1 of 25

Introduction

Thank you for visiting the website of CTI FZCO (CTI, we, us). We want to ensure that you understand this Privacy Policy and how we handle your personal data. If you have any questions, please contact us at support@citytradersimperium.com.

This Privacy Policy applies to our website and any software applications we provide.

Section 2 of 25

Global Data Protection Compliance

We comply with applicable international data protection laws, including the General Data Protection Regulation (EU) 2016/679 (GDPR) and other relevant global regulations governing the collection, use, and security of personal data.

If you are located in a region with specific data protection laws, you have rights regarding your personal data, as outlined below.

If you have concerns about how we handle your data, you have the right to file a complaint with your local data protection authority. However, we encourage you to contact us first so we can address your concerns directly.

Section 3 of 25

Our Commitment to Protecting Your Data

We are committed to respecting your privacy and protecting your personal data. We ensure that your data is:

• Used lawfully, fairly, and transparently
• Collected for specific, legitimate purposes that we have clearly explained
• Relevant and limited to what is necessary for those purposes
• Accurate and kept up to date
• Stored securely and retained only as long as necessary

Section 4 of 25

How We Handle Your Data

This policy explains how we collect, process, and correct your data, whether provided directly by you or collected through our systems.

IMPORTANT NOTICE: If you are under 18 years old, we do not collect, store, or process your data, nor will we engage in any form of communication with you.

For any inquiries or further details, please contact us at support@citytradersimperium.com.

Section 5 of 25

Us as a Data Controller

Under applicable data protection laws, we act as a data controller when you visit our website. This means we are responsible for determining how we collect, store, and use your personal information.

To ensure full transparency, our details are as follows:

• Full name of legal entity: CTI FZCO
• Email address: support@citytradersimperium.com
• Postal address: Dubai Silicon Oasis, DDP, Building A2, Dubai, United Arab Emirates.

If you have any questions or concerns regarding your personal data, please contact us at support@citytradersimperium.com.

Section 6 of 25

Changes

We are always reviewing our Privacy Policy to keep it up to date. You can help us too, as it’s important that the personal data we hold about you is accurate and current. So, please let us know as soon as possible if your personal data changes during your relationship with us. Please contact us using the contact details above. This is your duty to us. Please help us to help you.

Section 7 of 25

How Do We Collect Your Personal Information?

We collect personal information about you from the following sources:

1. Direct interactions

You provide us with personal information (identity, contact, transaction, and marketing and communications data) when you:

• Fill out forms on our website or other service sites.
• Correspond with us by email, chat or other communication channels.
• Register for our services, subscribe to our content or request information.
• Submit information to verify your identity.
• Search for services or report issues related to our platform.

If you contact us, we will keep a record of that correspondence.

2. Automated technologies and interactions

When you interact with our website and client dashboard, we may automatically collect technical data about your device, browsing behaviour and usage patterns. We do this through cookies, server logs and similar technologies (see section 18).

3. Information from third parties and publicly available sources

We may receive personal data about you from:

• analytics and advertising providers (technical data, where you have allowed these in our cookie settings);
• payment processors (contact and transaction data);
• identity verification providers (the results of identity checks);
• publicly available records.

If you have any questions about how we collect your data, please contact us at support@citytradersimperium.com.

Section 8 of 25

Types of Personal Data We Collect

We may collect, use, store and transfer different types of personal data about you. This mainly includes the following:

• Identity data: first and last name and username.
• Contact data: address, email address and telephone number.
• Identity verification data: the identity document, date of birth, a selfie and other information you submit when we verify your identity, and the result of the check. Our identity verification provider collects this on our behalf.
• Transaction data: details of payments you make, the products you buy from us, and the payout details you give us so that we can pay you rewards or profit shares. We do not receive or store your card details; they are handled by our payment processor.
• Technical data: IP address, approximate location worked out from it, login data, browser type and version, time zone setting, operating system and device type.
• Usage data: how you use our website, client dashboard and emails.
• Profile data: username, password (stored only in encrypted form), preferences, feedback and survey responses.
• Marketing and communications data: your marketing preferences and your correspondence with us.

The term personal data (or personal information) means any information that can identify an individual. Anonymous data, where identity details have been removed, does not fall under this category.

Apart from the biometric data used for identity verification (see below), we do not collect any special categories of personal data, including:

• Race or ethnicity.
• Religious or philosophical beliefs.
• Sex life or sexual orientation.
• Political opinions.
• Trade union membership.
• Health-related information.
• Genetic data.
• Criminal convictions or offences.

Biometric data for identity verification. When we verify your identity, our identity verification provider compares your selfie with the photo on your identity document (a face match) and checks that the selfie is of a live person. This involves biometric data. We use it only to verify your identity and prevent fraud, with your explicit consent, which you give during the verification process. We keep it only as long as we need it for these purposes and to meet our legal obligations.

Important notice: our website and services are not intended for individuals under 18 years old. If you are under 18, please log out immediately.

Section 9 of 25

Sharing Your Personal Data with Third Parties

We share your personal data only with the following categories of recipients, and only as far as each needs it:

• Service providers acting on our behalf (processors): hosting and IT infrastructure, content delivery and security, customer support and chat, email delivery, payment processing, identity verification, fraud prevention, and marketing attribution and analytics. They may use your data only on our instructions and under a written contract, and not for their own purposes.
• Advertising and analytics platforms: only where you have allowed analytics and marketing cookies (see section 18). Some of these platforms use the data they receive for their own purposes, under their own privacy policies.
• Professional advisers, such as lawyers, accountants and auditors.
• Authorities, regulators and law enforcement, where the law requires it or to protect our rights.
• Buyers or successors of our business, if we sell, transfer or merge all or part of it. They may use your data only as this policy describes.

A list of the service providers we use is available on request from support@citytradersimperium.com.

By joining the Trader Rewards Program, you will need to create a profile on Zealy.io, a third-party platform.

• Your data will be collected and processed by Zealy.io in accordance with their Privacy Policy and Terms of Service.
• CTI FZCO does not control or assume responsibility for how Zealy.io handles your data.

What You Should Do:

We strongly encourage you to review Zealy.io’s Privacy Policy and Terms of Service before proceeding.

By continuing to use Zealy.io, you acknowledge that your data will be processed according to their policies.

Section 10 of 25

International Transfers

We are based in the United Arab Emirates, so your personal data is processed there. Some of our service providers are in other countries, including the United States.

Where the law requires it, we protect personal data passed to them with a recognised safeguard. That is either the European Commission’s Standard Contractual Clauses (with the UK Addendum where relevant), or the provider’s certification under the EU–US Data Privacy Framework and its UK and Swiss extensions.

You can ask us for more information on these safeguards at support@citytradersimperium.com.

Section 11 of 25

How and for What Purpose Might We Use Information About You?

We will only use your personal data when the law allows us to. Below are the most common legal bases for processing your data (though this list is not exhaustive):

• With Your Consent – When you have explicitly given us permission before processing your data.
• Contractual Necessity – When processing is required to perform a contract we are about to enter into or have already entered into with you.
• Legitimate Interests – When processing is necessary for our legitimate business interests (or those of a third party) and your rights do not override those interests.
• Legal or Regulatory Obligations – When we need to process your data to comply with legal or regulatory requirements.

Note: we rely on your consent for non-essential cookies and similar technologies on our website (see section 18). You can withdraw your consent at any time. Doing so does not affect processing carried out before you withdrew it.

Section 12 of 25

Why Do We Process Your Data?

To give you a better understanding, below is a breakdown of how we use your personal data, along with the legal basis for processing:

Section 13 of 25

Fraud Prevention and Security

To protect our business and our customers, we use fraud-prevention and security tools on our website and services. They analyse technical data such as IP address, device and browser information, and patterns of use, to detect fraudulent clicks, fraudulent sign-ups or purchases, and abuse.

We rely on our legitimate interest in preventing fraud. These tools run for all visitors, because they cannot protect us otherwise. They keep the minimum data needed:

• On our website, they keep a session identifier that is deleted when you close your browser.
• In our client dashboard, once you have signed up, we record your activity for every user. This includes pages and actions, IP address, and device and browser information. We use it to detect fraud, account sharing and abuse, and to protect your account. We use this data for fraud prevention and security only.

You can object to this processing (see section 21), and we will consider your objection against our need to prevent fraud.

Section 14 of 25

Automated Decisions

We do not make decisions about you that are based solely on automated processing and that have legal or similarly significant effects on you.

Where our fraud-prevention tools flag an order or account, a member of our team reviews it before any action is taken.

Section 15 of 25

And If You Don’t Give Us Any Personal Data?

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. So, let us do what we need to get your contracts performed and give us the details we need, now that you know how we keep them safe and what we need them for. And remember to tell us about the changes!

Section 16 of 25

How We Use Your Data for Marketing

We may use your identity, contact, usage and profile data to decide which products, services and offers may interest you.

Service emails. When you register, we email you about your account and our services. These include account and security notices, changes to our programmes, rules and terms, and updates you need to use our services. They are part of providing our services, so they continue while you have an account.

Marketing emails. We also send news, offers and promotions about our own programmes and services to people who have registered with us or bought from us. We do this under our legitimate interest in promoting our own services. We never send marketing on behalf of other companies.

You can opt out of marketing emails at any time, free of charge, using the unsubscribe link in every email or by contacting support@citytradersimperium.com. Opting out does not affect your account or your service emails. If you do not open or click any of our emails for three months, we remove you from our mailing list.

Section 17 of 25

We Do Not Sell Your Data

We do not sell your personal data. We do not share your personal data with other companies so that they can market their own products to you.

Where you have allowed marketing cookies, advertising platforms receive information about your visit so that we can measure and show our own ads. See section 18.

Section 18 of 25

Cookies: Your Choice, Your Control

We use cookies and similar technologies, such as local storage and pixels, on our website and client dashboard. We use the following categories:

• Strictly necessary (always on): needed for the website to work, for example to remember your cookie choice, keep the site secure and keep you logged in.
• Preferences (optional): remember choices you make, such as language or region.
• Fraud prevention and security (always on): help us detect fraud and abuse (see section 13).
• Support chat: loads only when you choose to open it.
• Analytics and marketing (optional): our own analytics and third-party tools that help us understand how our website is used and measure our advertising.

Your choice. If you visit from the EEA, the United Kingdom or Switzerland, no analytics or marketing cookies are set until you accept them in our cookie banner. Elsewhere, they may be set when the page loads, and you can switch them off at any time.

You can change or withdraw your choice at any time through the Cookie settings link at the foot of every page. You can also block cookies in your browser, though parts of the website may then not work.

Cookies last from the end of your visit up to two years, depending on their purpose. In our client dashboard, we record activity for all users for fraud prevention and security (see section 13).

Section 19 of 25

Change of Purpose

We’ve explained why we collect your personal data and what we use it for. Now, let’s be clear on how we handle it:

• We use your data only for its intended purpose – We will only process your personal data for the specific reasons for which it was collected.
• If the purpose changes, we’ll assess compatibility – If we need to use your data for another reason that aligns with the original purpose, we’ll ensure it is legally compatible.
• If the purpose is unrelated, we’ll inform you – Should we ever need to use your personal data for an entirely different purpose, we will notify you and explain the legal basis for doing so.

Important Note: In some cases, we may process your personal data without your knowledge or consent, but only where legally required or permitted under international data protection laws.

Your privacy matters, and we ensure that all data usage remains transparent, legal, and secure. 

Section 20 of 25

How We Protect Your Personal Data

We take your data security seriously and ensure that all information you provide is stored on secure servers.

Your responsibility: if we have given you (or you have chosen) a password to access certain parts of our platforms, it is your responsibility to keep it confidential. Do not share your password with anyone.

Our security measures: we implement strict security procedures to prevent your data from being lost, misused, or accessed without authorisation. In the event of a suspected data breach, we have procedures in place to:

• Notify you as required by law.
• Inform relevant regulatory authorities when necessary.

How long we keep your data

We keep personal data only as long as we need it for the purpose we collected it for:

• Client records (identity, contact and transaction data): six years after the client relationship ends, for tax, regulatory and insurance purposes.
• Identity verification records: for as long as we need them to meet our legal obligations and to prevent fraud, and at least as long as the law requires.
• Your account: while your account is open. You can ask us to close your account and delete your data at any time. We then keep only the records this section says we must keep.
• Mailing list: until you unsubscribe, or three months after you last opened or clicked one of our emails. We then keep only a record of the unsubscribe, so that we do not email you again.
• Support conversations, records of your consents and your data protection requests: while your account is open. After that, we keep them only as long as we need to show that we handled your requests correctly, or to deal with a legal claim.
• Our own website analytics: detailed events for 90 days and visit records for 180 days. Summary records with no identifier in them are kept longer.
• Fraud-prevention data: full IP addresses for 48 hours, or for 90 days where the visit led to a purchase.

We may anonymise data so that it can no longer be linked to you, and use it for statistics.

Section 21 of 25

Your Rights Over Your Personal Data

As we’ve said, you’re in charge—and under international data protection laws, you have the right to take specific actions regarding your personal data. You can:

• Request access – Also known as a “data subject access request,” this allows you to request a copy of the personal data we hold about you and confirm that we are processing it lawfully.
• Request correction – If any of the personal data we hold about you is incomplete or inaccurate, you can request corrections.
• Request erasure (“Right to be Forgotten”) – You can ask us to delete or remove your personal data if there is no legitimate reason for us to continue processing it. You can also request erasure if you have objected to processing (see below).
• Object to processing – If we process your personal data based on legitimate interests (ours or a third party’s), and you believe that your specific situation gives you a reason to object, you have the right to do so.
• Object to direct marketing – You can ask us to stop processing your personal data for marketing purposes at any time.
• Request restriction of processing – You can request that we suspend processing your personal data in certain situations (e.g., if you need us to verify its accuracy or explain why we are processing it).
• Request data portability – You can ask us to transfer your personal data to another party in a structured, commonly used format.
• Withdraw consent – Where we rely on your consent, you can withdraw it at any time. This does not affect processing carried out before you withdrew it.
• Automated decisions – You have the right not to be subject to a decision based solely on automated processing that significantly affects you (see section 14).
• Complain – You can lodge a complaint with a data protection authority, in particular in the country where you live or work. We would appreciate the chance to deal with your concerns first, so please contact us.

Section 22 of 25

How to Exercise Your Rights

If you would like to review, verify, correct, erase, restrict, or transfer your personal data, or object to processing, please contact our Data Privacy Manager in writing.

Email: support@citytradersimperium.com

We are committed to respecting your rights and ensuring your data remains secure and properly handled. 

Section 23 of 25

No Fees for Exercising Your Rights

Accessing your personal data and exercising your rights is free of charge.

However, if your request is clearly unfounded, repetitive, or excessive, we may:

• Charge a reasonable fee to cover administrative costs.
• Refuse to comply with the request if it is unreasonable.

Section 24 of 25

Verifying Your Identity for Data Requests

To protect your privacy and security, we may need to request specific information from you to:

• Confirm your identity before granting access to your personal data.
• Ensure your right to access or exercise any of your other data rights.
• Prevent unauthorized access or disclosure of personal data.

We may also contact you for additional details related to your request, which can help speed up our response.

Section 25 of 25

Response Time for Data Requests

We respond to requests within one month of receiving them.

If a request is complex, or you have made several, we may extend this by up to two further months. In that case we will tell you within the first month, and explain why.