Privacy Policy

Section 1 of 22

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 22

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.

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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 22

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 22

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 22

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 22

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, Financial, and Marketing and Communications Data) when you:

• Fill out forms on our website or other service sites.
• Correspond with us via email, chat, or other communication channels.
• Register for our services, subscribe to our content, or request information.
• 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 & Interactions

When you interact with our website, we may automatically collect technical data about your device, browsing behavior, and usage patterns. This is done through cookies, server logs, and other tracking technologies.

3. Information from Third Parties & Publicly Available Sources

We may receive personal data about you from external sources, including:

• Technical Data from:

  • Analytics providers (e.g., Google and other services based outside the EU).
  • Advertising networks.
  • Search information providers.

• Contact, Financial, and Transaction Data from payment processors and delivery service providers.

• Identity and Contact Data from:

  • Data brokers or aggregators.
  • Publicly available records.

Technical Data from:

• Analytics providers (e.g., Google and other services based outside the EU).
• Advertising networks.
• Search information providers.

Contact, Financial, and Transaction Data from payment processors and delivery service providers.

Identity and Contact Data from:

• Data brokers or aggregators.
• Publicly available records.

This ensures that we collect and use personal data in compliance with international data protection laws. If you have any questions about how we collect your data, please contact us at support@citytradersimperium.com.

Section 8 of 22

Types of Personal Data We Collect

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

• Identity Data – First name, last name, maiden name, username or similar identifier, marital status, title, date of birth, and gender.
• Contact Data – Billing address, delivery address, email address, and telephone numbers.
• Financial Data – Bank account and payment card details.
• Transaction Data – Details of payments made by you, records of products and services purchased from us, and any legal services provided or proposed.
• Technical Data – Internet protocol (IP) address, login data, browser type and version, time zone setting, location, browser plug-in types and versions, operating system, platform, and other technical details related to your device.
• Usage Data – Information about how you use our website and services, including traffic data, communication data, and resources accessed for billing or service improvement purposes.
• Profile Data – Username, password, interests, preferences, feedback, and survey responses.
• Marketing and Communications Data – Your preferences for receiving marketing from us and third parties, as well as your communication preferences.

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

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 or biometric data.
❌ Criminal convictions or offenses.

⚠️ 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 22

Sharing Your Personal Data with Third Parties

When you consent to provide us with your personal data, we will also ask for your consent to share it with third parties for the purposes outlined in this policy.

• External Third Parties – These are service providers acting as data processors based overseas who assist us with IT infrastructure, system administration, and other operational support services.
• Business Transfers & Mergers – In the event that we choose to sell, transfer, or merge parts of our business or assets, your personal data may be shared with the acquiring entity. Similarly, if we acquire or merge with another company, your personal data may be used in line with this privacy policy.

Commitment to Data Security & Compliance

• We strictly require all third parties to handle your personal data securely and in full compliance with applicable international data protection laws.
• Third-party service providers are prohibited from using your personal data for their own purposes. They may only process your data for the specific purposes outlined in this policy and under our instructions.

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 22

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: In general, we do not rely on consent as the sole legal basis for processing personal data, except for sending third-party direct marketing via email or text message. You are always in control and can withdraw consent at any time by contacting us using the details provided at the beginning of this policy.

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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:

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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 13 of 22

How We Use Your Data for Marketing

We may use your Identity, Contact, Technical, Usage, and Profile Data to understand your preferences and determine which products, services, or offers may be most relevant to you. This process helps us tailor our communications to provide you with valuable and relevant opportunities—we call this marketing.

✅ No Spam Guarantee: We won’t overwhelm you with messages. However, unless you choose to opt-out (see below for details), we may send you marketing communications if:

• You have requested information from us.
• You have purchased services from us.
• You have not opted out of receiving marketing communications.

You are always in charge of your marketing preferences. If you no longer wish to receive marketing emails, opting out is quick and easy—simply follow the opt-out instructions in our emails or contact us at support@citytradersimperium.com.

We respect your privacy and ensure that all marketing activities comply with applicable international data protection laws.

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We Do Not Share Your Data for Marketing

We simply don’t do it. When you provide us with your personal data, we keep it confidential and secure.

• No third-party marketing – We never share, sell, or distribute your personal data to any third party for marketing purposes.
• Your data stays with us – Any personal information you provide is used only for the purposes outlined in our Privacy Policy and in compliance with international data protection laws.

Your trust is our priority, and we are committed to protecting your privacy at all times.

Section 15 of 22

Cookies: Your Choice, Your Control

Some people dislike cookies, while others appreciate the seamless experience they provide. Which one are you?

✅ Your browser, your rules – You can set your browser to refuse all or some cookies or to alert you when a website sets or accesses them.

⚠️ Keep in mind that disabling or refusing cookies may limit your access to certain features or content on our website.

Want the full experience? Enabling cookies ensures smoother navigation and a more personalized experience.

Section 16 of 22

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. 

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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 authorization. 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.

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

Data Retention & Compliance

• Legal Obligation – We are required by law to retain basic client information (Contact, Identity, Financial, and Transaction Data) for six years after the client relationship ends to comply with tax, regulatory, and insurance requirements.
• Anonymization for Research & Statistics – We may anonymize your personal data so that it can no longer be linked to you. In such cases, we may use this data for research or statistical purposes indefinitely without further notice.

Section 18 of 22

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.

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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 20 of 22

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 21 of 22

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.

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Response Time for Data Requests

We aim to respond to all legitimate requests within one month.

⏳ Need more time? It may take longer if your request is complex or you’ve made multiple requests. In such cases:

• We will notify you of the delay.
• We will keep you updated on the progress.