1. Introduction
CitiPage ("we," "us," or "our") operates the CitiPage financial services platform (the "Service"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services.
By using our Service, you consent to the data practices described in this policy. If you do not agree with any terms, please discontinue use of our Services immediately.
2. Information Collection
2.1 Personal Information Collected
We collect personal information that you voluntarily provide when registering for our services, including:
- Full legal name and contact details (email address, phone number)
- Government-issued identification documents (including but not limited to National ID, Passport, Driver's License)
- Financial information (bank account details, transaction history, wallet balances)
- Biometric data for identity verification (where required by regulation)
- Demographic information (age, gender, occupation)
2.2 Automated Data Collection
- Device Information: IP address, browser type, device identifiers, operating system
- Usage Data: Feature usage patterns, clickstream data, error logs
- Location Data: GPS data (with explicit consent), approximate location derived from IP
- Cookies and Tracking Technologies: Session cookies, persistent cookies, security tokens
3. Use of Information
We use collected information for the following purposes:
- Account creation and user authentication
- Transaction processing and financial service delivery
- Fraud detection and prevention measures
- Regulatory compliance (including KYC and AML requirements)
- Service improvement through data analytics
- Personalized user experience and recommendations
- Security monitoring and incident response
- Legal obligations and dispute resolution
4. Data Sharing and Disclosure
We may share information with:
- Financial institutions and payment processors for transaction completion
- Regulatory bodies and law enforcement agencies as required by law
- Third-party service providers (cloud hosts, analytics providers, customer support)
- Business partners offering integrated services (with explicit consent)
- Successor entities in case of merger or acquisition
We never sell user data to third-party advertisers.
5. Data Security Measures
We implement enterprise-grade security measures including:
- 256-bit SSL encryption for data in transit
- AES-256 encryption for data at rest
- Multi-factor authentication systems
- Regular penetration testing and security audits
- Role-based access controls
- Secure deletion protocols
6. User Rights and Choices
You have the right to:
- Access your personal data in machine-readable format
- Request rectification of inaccurate information
- Withdraw consent for non-essential processing
- Request data portability
- Request account deletion (subject to legal retention requirements)
- Opt-out of marketing communications
To exercise these rights, contact us via the information below.
7. Data Retention
We retain personal data:
- For active accounts: Until account deletion request
- Transaction records: 7 years as required by financial regulations
- Fraud-related data: Up to 10 years for legal protection
- Marketing data: Until consent withdrawal
8. International Data Transfers
Your data may be transferred to and processed in countries outside your residence. We ensure adequate protection through:
- EU Standard Contractual Clauses
- GDPR-compliant vendor agreements
- Data protection impact assessments
9. Children's Privacy
Our Services are not directed to individuals under 18. We do not knowingly collect data from minors. If we become aware of such collection, we will promptly delete it.
10. Policy Updates
We may update this policy periodically. Material changes will be notified through:
- In-app notifications
- Email alerts to registered users
- Prominent website notices
Last Updated: October 15, 2023