This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of clients’ personal information when our clients use our service, application, or websites.

Our clients’ privacy is important to us, we respect our clients’ privacy and aim to comply with any applicable laws and regulations in handling any personal information we may collect in dealing with our clients, be it through our website or the use of our Apps.

For ease of reference, “personal information or data” is any information about our clients that we may collect that can be used to identify our clients or information that is linked or is linkable to our client’s use of our Apps. This information includes our clients’ names, addresses, and dates of birth (for individuals). In some cases, this will include data that does not directly identify our clients but that can reasonably be used to identify our clients, such as serial numbers on our clients’ devices, or our client devices.

1. Information we may collect when our clients use our Application or website (collectively referred to as “our platforms”)
   • While our client uses our platforms, we may ask you to provide us with certain personal information that can be used to contact or identify you. Personal information may include, but is not limited to:
     • Contact Information: data such as name, email address, physical address, phone number, or other contact information.
     • Account information, which would include your email address, age, client’s account ID, and related account information.
     • Payment Information: data about the client’s billing address and method of payment, such as bank details, credit, debit, or other payment card information.
     • Transaction Information. Data about purchases of services on the platforms or transactions in the platform.
     • Usage Data. Data about your activity and use on the platform, including your location while using the platform.
     • Information relating to the device the client uses the platform on.
     • Other Information our clients provide to us, such as the content of our client’s communications with us, including interactions with customer support and contacts through social media channels.
   • Clients are not obliged to provide us with the personal information we request while they make use of our platforms, however, if clients elect not to provide us with the information, it may not be possible for us to provide our clients with the service they require from the platforms or for us to respond to any query or request the clients may have.

2. How we use the personal information we collect from our platforms
   • We use the personal information we collect for the following purposes:
     • To provide and maintain our Service: including monitoring the usage of our platforms.
     • To manage our clients’ accounts: to manage client’s registration as a user of the platform. The personal information we collect powers our services offering and is also used to improve our offering based on the client’s use.
     • For internal purposes: Such as auditing, data analysis, troubleshooting, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our services, products, and your experience.
     • Communicate with You: To respond to clients’ queries or requests, contact clients regarding clients’ transactions or accounts, market our platform/service offering or request information or feedback.
     • For business transfers: We may use the client’s personal information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which client information held by us about our platform users is among the assets transferred.
     • For legal compliance: to comply with applicable law – we may be required to disclose clients’ personal information in order for us to comply with lawful governmental or court requests.

3. Sharing of collected personal information
   • Personal Information we collect from our clients is processed at our operating offices and in any other places where the parties involved in the processing are located. It means that our client’s personal information may be transferred to and maintained on computers located outside of the client’s country, state/province, or other governmental jurisdiction where the data protection laws may differ from those from the client’s jurisdiction.
   • By submitting such personal information, our clients consent to this Privacy Policy and agree to the transfer mentioned above.
   • We will take all steps reasonably necessary to ensure that our client’s personal information data is treated securely and in accordance with this Privacy Policy and no transfer of personal information will take place to a third party unless there are adequate controls in place including the security of client’s personal information and other client’s data.
   • By operation, we may share your personal data with our affiliated companies, service providers who act on our behalf, our partners, developers, publishers, or others at your direction. We do not share Personal Data with third parties for their own marketing purposes.
     • Service Providers: We may share our client’s personal information with service providers who perform certain tasks on our behalf, such as processing or storing data, including the client’s personal information, in connection with the client’s use of our platform and delivering products to clients. Our service providers are obligated to handle personal information consistent with this Privacy Policy and according to our instructions.
     • Affiliates: We may share our client’s personal information with our affiliates, in which case, our affiliates are obliged to handle our client’s personal information consistent with this Privacy Policy and according to our instructions. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies that we control or that are under common control with our parent company.
     • Business partners: We may share our client’s personal information with our business partners to offer our clients certain products, services, or promotions. Our partners are also obligated to are obligated to handle personal information consistent with this Privacy Policy and according to our instructions.
     • Developers and publishers from whom our clients subscribe to our platform. When our client subscribes to our platform using a third-party operation system, a Subscriber ID that is unique to our client will be created. The Subscriber ID will be shared between the operating system and ourselves to provide reports to the operation system provider, developer, or publisher, which include information about the subscription.
     • Other users: We may share the client’s personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
     • Your consent: With our client’s consent, we may disclose our client’s personal information for any other purpose.
   • We do not sell any collected personal information as “sale” is defined in Nevada and California. We also do not “share” your personal information as that term is defined in California. We may disclose personal information to:
     • a parent, subsidiary, or affiliate of our company,
     • third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators.
     • our employees, contractors, and/or related entities
     • our existing or potential agents or business partners
     • credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you.
     • courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights.
     • third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
     • third parties to collect and process data.
     • an entity that buys, or to which we transfer all or substantially all of our assets and business

4. Protection or security of our client’s personal information
   • The security of our client’s personal information is important to us, but the transmission of information over the Internet, or electronic storage is not 100% secure. While we strive to use administrative, technical, and physical safeguards to protect our client’s data, including personal information, we cannot guarantee its absolute security.
   • We are constantly working to improve on these safeguards to help keep your personal data secure.
   • For any collection or processing of personal information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.
   • Our clients are responsible for selecting account-linked passwords and the password’s overall security strength, ensuring the security of their own information within the bounds of our services.

5. Children’s Privacy
   • We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.
   • If we learn that a child’s personal data was collected without appropriate authorization, it will be deleted as soon as possible.

6. Retention of collected personal information
   • We will retain our client’s personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use the client’s personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain the data to comply with applicable laws), accounting, reporting obligations or for archive purposes in the public interest, scientific, historical research purposes, statistical purposes, resolve disputes, and enforce our legal agreements and policies.

7. Removal of collected personal information
   • Our clients retain the right to delete or request that we assist in deleting the personal information that we have collected during the provision of our services or their use of the platforms.
   • We will always include functionality that gives our clients the ability to delete or amend certain personal information from the platform while retaining the functionality. However, clients must be aware that we may need to retain certain information when legally required.
   • For clients who are residents of the State of California, USA, the clients have the right to delete the personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, clients have the right to request the following from us:
     • The categories of personal information we have collected about them;
     • The categories of sources from which the personal information was collected;
     • The categories of personal information about the client we disclosed for a business purpose or sold;
     • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
     • The business or commercial purpose for collecting or selling the personal information; and
     • The specific pieces of personal information we have collected about the client.
   • To exercise any of the rights detailed in 7.3, Californian clients must contact us using the details provided in this privacy policy. To receive this information, the Californian clients are requested to send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

8. Additional Disclosures for California Compliance (US)
   • Under California Civil Code Section 1798.83, Californian clients may ask us about the information we release to other organizations for their marketing purposes.
   • To make such a request, the California clients must contact us using the details provided in this privacy policy with “Request for California privacy information” in the subject line. The clients may make this type of request once every calendar year. We will email a list of categories of personal information we revealed to other organizations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.

9. California Consumer Privacy Act of 2018 (“CCPA”) – permitted financial incentives
   • In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide.
   • Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information, and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
   • For more information on personal information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.

10. International Transfers Outside of the European Economic Area (EEA)
    • We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

11. Compliance with the South African Protection of Personal Information Act
    • We will ensure that all collected and transferred Personal Information will comply with the substantive provisions of the South African Protection of Personal Information Act, 4 of 2023 (“POPIA”).

12. Limits of Our Policy
    • Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

13. Changes to this Privacy Policy
    • We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
    • We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated”; date at the top of this Privacy Policy.
    • You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14. Client’s rights and control of collected personal information
    • Client’s choice: By providing personal information to us, our clients understand that we will collect, hold, use, and disclose the collected personal information in accordance with this privacy policy. Our clients do not have to provide personal information to us, however, if they do not, it may affect their use of our platforms or the products and/or services offered on or through the platform.
    • Information from third parties: If we receive personal information about our clients from a third party, we will protect it as set out in this privacy policy.
    • Marketing permission: If our clients have previously provided permission for the use of their personal information for direct marketing purposes, the client may change their mind at any time by contacting us using the details in this policy.
    • Access: Our clients may request details of the personal information that we hold about them.
    • Correction: If our clients believe that any information, we hold about them is inaccurate, outdated, incomplete, irrelevant, or misleading, they may contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
    • Non-discrimination: We will not discriminate against a client for exercising any of their rights over their personal information. Unless personal information is required to provide the client with a particular service or offer (for example providing user support), we will not deny our client goods or services and/or charge the client different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide clients with a different level or quality of goods or services.
    • Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
    • Complaints: If a client believes that we have breached a relevant data protection law and wishes to make a complaint, such a client is welcome to contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate the complaint and respond accordingly, and in writing, setting out the outcome of our investigation and the steps we will take to deal with the complaint. The client also has the right to contact a regulatory body or data protection authority in relation to the complaint.

15. How our client may contact us
    • Our clients can contact Us by emailing info@citrii.com. Questions, comments, or concerns regarding this Privacy Policy or Our use of Your personal information are welcomed.
    • For any questions or concerns regarding your privacy, our client may contact us using the following details: info@citrii.com.