Privacy Policy

Introduction

Please read the following Privacy Policy (the “Privacy Policy”) carefully to understand how and why our web servers use your personal data in order for you to access and browse our website, https://www.citizenshipbay.com, (the “Website”).

Citizenship Bay

Citizenship Bay is a leading citizenship consultancy, specializing in offering second citizenship and European residency programs by investment.

Specializing in investment-based citizenship and residency for clients all over the world. Our citizenship and residency programs are globally accredited and highly reputable.

Headquartered in Dubai with additional offices around the globe, Citizenship Bay has years of experience assisting wealthy individuals and their families in the quest for citizenship and residency.

General information

We have structured our Website so that you can visit us on the internet without identifying yourself or revealing any personal information.

Once you choose to provide us with personal information, we will protect such information and use it only in the ways described below.

Purpose of this Privacy Policy

We are committed to respecting and protecting your privacy at all times. Citizenship Bay will not sell, rent, transfer, or otherwise make available to others any information about any person visiting our Website except as expressly provided for in this Privacy Policy.

The purpose of this Privacy Policy is to:

Set out the type of personal data Citizenship Bay will collect from you and how we will use your personal information (see section A., ‘The personal data we collect from you’ below)
Set out the basis on which any personal data is processed by Citizenship Bay (see sections B., ‘How we use your information’ and C., ‘Legal basis for processing’ below)
Make you aware of how Citizenship Bay will handle your personal data
Clarify Citizenship Bay’ obligations under the data protection regulations with regard to processing your personal data lawfully and responsibly
Inform you of your data protection rights (see section K., ‘Your rights as a data subject’ below)

We will comply with local data protection laws in the jurisdictions we operate in and to do so, the personal information we hold about you must be:

Used by us lawfully, fairly, and in a transparent way
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
Relevant to the purposes we have told you about and limited only to those purposes
Accurate and kept up to date
Kept only as long as necessary for the purposes we have told you about
Kept securely

This Privacy Policy should be read in conjunction with our Cookie Policy and any other Privacy Notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

A.The personal data we collect from you

While using this Website, you may contact our representatives and obtain information relating to the residence and/or citizenship programs or the services offered by Citizenship Bay and start the process of obtaining any of the services in which you may be interested.

We will collect and process the following personal data about you:

The information you give us

These are personal details and include your first name, last name, nationality, country of residence, e-mail address, and phone number. These details also include information on which services you are interested in or details about your enquiry. The information you give us may also include data about any marketing preference.

Such information may be provided by you in the following circumstances:

Filling in an enquiry form on the Website
Corresponding with us by post, phone, e-mail, or otherwise when you apply for our services
Subscribing to our services or publications
Requesting marketing to be sent to you
Giving us some feedback
Starting negotiations for or entering into a contract to supply goods and/or services to us

We may also require you to provide us with information that might be needed to establish and serve as proof of your identification, such as copies of your passport or national ID card.

Where we are collecting or processing further information, we will provide you with separate privacy notices that further describe how and why we are using your personal data.

Where we are required 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 services as agreed or we may not be able to enter into a contract with you, but we will notify you if this is the case at the time. We may have to terminate that contract with you as a result.

The information we collect about you from our Website

Whenever you visit our Website, we will automatically collect the following:

Technical information: including the IP address used to connect your computer to the internet, your log-in information, the browser type and version, the full uniform resource locators (URL), and the clickstream to, through, and from our Website (including date and time), as well as other information regarding your experience on our Website such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Location information: We may receive information about your location and may determine your location through your IP address and, when accessing the Website through a mobile device, by using the data that we collect from that device. This includes information about the wireless networks or cell towers near your mobile device at the time of access.

Our Website uses cookies to distinguish you from other users of our Website. This helps ensure that we provide you with a good experience when you browse our Website and allows us to improve it.

Information we receive from other sources

We may receive personal data about you from various third parties and publicly available sources as set out below:

Technical data from Google Analytics advertising features, including Google AdWords, Facebook Pixel’s, Google Tag Manager, Amiando, Microsoft Dynamics, LinkedIn, Gmail, and other ad hoc paid media partnerships.
Identity, contact, and background data from publicly available sources, compliance databases, and/or compliance and due diligence service providers within and outside the EU so we can confirm that you are a suitable client of or supplier to us.

B.How we use your information

The information you give us

We shall use this information:

To facilitate the provision of the services that you request and where we need to perform the contract we are about to enter into or have entered into with you
Where it is necessary for our legitimate interests (or those of a third party), and where your interests and fundamental rights do not override those interests
Where we need to comply with a legal or regulatory obligation
To resolve any issues that you have reported and to provide support-related services
To manage the supplier relationship you have with us

The information we collect about you from our Website

We shall use this information:

To administer our Website and for internal operations, including troubleshooting, and in order to keep our Website safe and secure
To improve our Website to ensure that content is presented most effectively for you
To ensure that content displayed on the Website is presented in a user-friendly manner

Information we receive from other sources

We will combine information we receive from other sources with information you provide to us and information that we collect from you. We will use your information only for purposes as described in the paragraphs above.

C.Legal Basis for processing

We shall only process your personal data insofar as this is necessary for us to be able to provide the services we offer and/or for the purposes indicated in this Privacy Policy .

We may also process your personal data based on any legitimate interest or in order to comply with any legal obligations. These interests and obligations may include the exercise or defense of legal claims or in order to comply with an order of any court, tribunal, or authority, or disclosure to a government or regulatory entity.

Generally, we do not rely on consent as a legal basis for processing your personal data. However, where your consent is required, we will provide you with a form requesting explicit consent to do so.

E.Marketing

You will receive marketing communication if you have requested such information from us by providing us with your details through this Website and have consented and opted-in to receiving such information. Where we have entered a business relationship (namely a contract) with you, we may inform you about our activities, offers, or other information that we believe would be useful to you in accordance with our legitimate interest.

You have the right to withdraw consent or to object to receiving marketing information at any time by contacting [email protected] or clicking the unsubscribe button. Once you have withdrawn your consent or object to any one of the purposes listed herein, we will stop sending you any marketing communications. If you choose not to consent or to object to any one of the purposes listed herein or withdraw your consent at any time, we will still be able to provide our services; however, we would not be able to provide you with the full range of services that we offer, and it may affect the efficiency with which we provide the services you request.

E.Disclosure of your information

We may disclose your personal data to any of our international offices or the companies that form part of Citizenship Bay that may act as joint data controllers or data processors to the company. These offices or companies will be the data controller for your data when you obtain our services and/or they may provide administration, controls, and reporting services.

We may need to share personal data with government agencies and authorities in the country where you seek to obtain residence or citizenship. We shall only provide the necessary information in order to perform services under our contract with you.

We may be required to share your data with local agents or other service suppliers (in their capacity as data processors), which is necessary for us to provide the services you request. These local agents and suppliers store and process your data based on strict confidentiality and subject to the appropriate security measures and safeguards in place as described in section H. below.

We may also share your data with other third parties in their capacity as data controllers such as legal, tax, real estate, immigration or other advisors and consultants, (international) banks for payment details, or third parties providing other or additional services or goods to you such as real estate agencies, owners, or developers who you might wish to engage with under separate terms and conditions between you and such third parties. These third parties will process your data in their own right as data controllers and their data protection policies and processes shall become applicable.

We may also disclose or share your data if we are under a duty to do so in order to comply with any legal obligation, judgment, or under an order from a court, tribunal, or authority. We may also disclose your data to enforce our terms of use, or to protect our rights, property, or safety, that of our partners or other users of our Website. This includes exchanging information with other companies and organizations for the purposes of anti-money laundering or KYC checks, compliance with anti-bribery or corruption laws, and/or fraud protection.

F.Third party access to your personal data

We work closely with third parties to provide you with the services you request on our Website. These third parties include cloud storage providers, analytics providers, and search engine information providers. We will only work with third-party providers that comply with applicable laws in the jurisdictions in which we operate and that abide by the GDPR and, if applicable, agree to be bound by the SCC (as defined in section F., ‘Transfers of data to third countries’) to adequately protect and safeguard your personal data.

G.Data security

We will ensure that appropriate security measures are taken against unlawful or unauthorized processing of personal data, and against the accidental loss of or damage to personal data.

The transfer of information between our Website and your device is protected with transport layer security (TLS) certificates. When the Website is accessed using compatible browsers, that technology protects personal information using both server authentication and data encryption to ensure that personal information is safe and secure while in transit. The mainstream browser versions compatible with this technology are Internet Explorer (from version 11), the Mozilla Firefox (from version 27), Google Chrome (from version 32), and Apple Safari (from version 7).

All personal data is stored in a secure server environment that uses a firewall and other advanced technology to protect against interference or unauthorized access. Usernames and passwords are issued to persons authorized to access the personal data, such as our employees, who are bound by confidentiality not to disclose any personal data.

No method of transmission of data is 100% secure, and absolute security cannot be guaranteed.

H.Data storage

We shall only store your data as long as is strictly necessary for the purposes for which it was collected (that is, to provide you with our services or to satisfy any legal, accounting, or reporting requirements).

i.Data minimization

Whenever and to the extent possible, we anonymize the data that we hold about you when it is no longer necessary to identify you from that data.

j.Your rights as a data subject

You are entitled to exercise the following rights under the GDPR:

The right to access information

You have the right to request information as to whether or not your personal data is being processed by Citizenship Bay as well as information as to how and why it is processed by sending an e-mail to [email protected]. You shall receive one electronic copy of the information free of charge via e-mail.

The right to object

You may contact us at any time by e-mailing [email protected] to ask us not to process your personal data, if our legal grounds for processing is that it is necessary for a legitimate interest pursued by us or a third party or for marketing purposes (for example, receiving information from us about upcoming events, newsletters, and publications). In the case of your written objection, your data will no longer be processed for such purposes.

The right to correction

You have the right to obtain correction of any inaccurate personal data about you that we have processed, update any data that is out-of-date, and complete any incomplete personal data including by means of a supplementary statement.

The right to erasure

You have the right to obtain the erasure of personal data we have concerning you when it is no longer required, for cases where:

You withdraw your consent to us processing your personal data on which the processing is originally based or where no other legal grounds for processing exists
Your personal data is no longer necessary in relation to the purpose for which it was originally collected
You object to the processing and there are no overriding legitimate grounds for the processing for marketing communication
Your personal data has been unlawfully processed
Your personal data must be erased to comply with a legal obligation to which we are subject

The right to restriction of processing

You have the right to restrict our processing activities where:

You contest the accuracy of this personal data, for a period enabling Citizenship Bay to verify the accuracy of the same personal data
Our processing is deemed unlawful, and you oppose the erasure of your personal data and request restriction of its use instead
We no longer need your personal data for the purposes stated in this Privacy Policy, but you require it for the establishment, exercising, or defending of legal claims
You have objected to our processing pending the verification of whether the legitimate grounds of our processing activities overrode those pertaining to you

K.Right to withdraw consent

Where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose (for example, for marketing), you have the right to withdraw your consent for that specific processing at any time, or you may withdraw your consent to this Privacy Policy. To withdraw your consent, please contact [email protected]. This will not affect the lawfulness of the processing we carried out on the basis of such consent before its withdrawal. Once we have received notification that you have withdrawn your consent, we will no longer process your information for that purpose unless we have another legitimate basis for doing so in law. Withdrawal of consent to this Privacy Policy will result in us having to terminate our services with you immediately.

Quality of website and overall experience

To improve the quality and overall user experience of the Website as well as facilitate event bookings and client event registrations, we use Google Analytics advertising features, as well as Zoho CRM and calendly.

M.Complaints

We welcome any comments, complaints, and queries in relation to data protection. As indicated above, you may contact our data protection officer at [email protected] or use the contact details at section P. ‘How to contact us’ below, and we shall try our best to deal with any issue or concern you may have.

N.How to contact us

If you have any questions regarding this Privacy Policy, or if you would like to send us your comments, please contact us today. Alternatively, write to us using the details below:

Address: Sheikh Zayed Rd Emaar Business Park, Building 4, Office 404 – Dubai

Phone: +971 4 430 8028

WhatsApp: +971581788208