Privacy Policy

1. Introduction

Cition Capital, Cayman SPC ("Cition Capital", "we", "us", or "our"), regulated by the Cayman Islands Monetary Authority (CIMA) under Registration Nr. 1545154 and part of the OM24 Group, is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website citioncapital.com (the "Website").

By using our Website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our Website.

2. Data We Collect

We may collect the following types of personal data:

2.1 Information You Provide

• Contact information (name, email address) when you use our contact form or send us an enquiry
• Any other information you voluntarily provide in correspondence with us

2.2 Automatically Collected Information

When you visit our Website, we may automatically collect certain data, including:

• Browser type and version
• Operating system
• Pages visited, time spent on pages, and navigation paths
• Referring website or source
• IP address (anonymised where possible)
• Device type and screen resolution

This data is collected only with your consent through the use of cookies and analytics tools, as described in Section 5 below.

3. How We Use Your Data

We use the personal data we collect for the following purposes:

• Responding to enquiries: To reply to your messages submitted through our contact form or via email
• Website analytics: To understand how visitors interact with our Website, improve its functionality and user experience (only with your consent)
• Legal compliance: To comply with applicable laws, regulations, and legal processes, including requirements of CIMA and other relevant authorities
• Security: To protect our Website from misuse and ensure its technical integrity

4. Legal Basis for Processing

We process your personal data on the following legal bases:

• Consent: For analytics cookies and tracking technologies — you may grant or withdraw consent at any time via our cookie banner
• Legitimate interest: For responding to your enquiries and ensuring Website security
• Legal obligation: Where processing is required to comply with applicable laws and regulations

5. Cookies & Google Analytics

5.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help us understand how you interact with our Website and improve your browsing experience.

5.2 Cookies We Use

5.3 Google Analytics

We use Google Analytics 4, a web analytics service provided by Google LLC ("Google"), to analyse the use of our Website. Google Analytics uses cookies to collect anonymised information about your visits, including pages viewed, time spent, and your general geographic location.

Google Analytics is only activated after you provide your explicit consent via the cookie consent banner displayed on your first visit. If you decline, no Google Analytics cookies will be placed on your device, and no data will be transmitted to Google.

For more information on how Google processes data, please visit Google's Privacy Policy and Google Analytics Opt-Out Browser Add-On.

6. Data Sharing & Third Parties

We do not sell, trade, or rent your personal data to third parties. We may share your data in the following limited circumstances:

• Google LLC: Analytics data is processed by Google under their data processing terms when you have consented to analytics cookies
• Legal requirements: We may disclose your data if required by law, court order, or regulatory authority (including CIMA)
• OM24 Group entities: We may share data within the OM24 Group of companies for the purposes described in this policy

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this policy, or as required by law. Contact form submissions are retained for up to 24 months. Analytics data collected by Google Analytics is retained according to Google's data retention policies (default: 14 months).

8. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate personal data
• Right to erasure: Request deletion of your personal data ("right to be forgotten")
• Right to restriction: Request restriction of processing of your personal data
• Right to data portability: Request transfer of your data in a machine-readable format
• Right to object: Object to the processing of your personal data
• Right to withdraw consent: Withdraw your consent for analytics cookies at any time via the cookie banner — this will not affect the lawfulness of processing prior to withdrawal

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

9. International Data Transfers

As our Website uses Google Analytics, some data may be transferred to and processed in countries outside of your jurisdiction, including the United States. Google provides appropriate safeguards for these transfers under their data processing agreements. Our Website is hosted and operated from the Cayman Islands.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our Website uses SSL/TLS encryption to secure data in transit. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.

11. Children's Privacy

Our Website is not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will take steps to delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this page periodically to stay informed about how we protect your data.

13. Contact Us

If you have any questions about this Privacy Policy, your personal data, or wish to exercise your data rights, please contact us: