Privacy & Cookie Policy

1. INTRODUCTION

Your privacy is important to us. We appreciate that seeking alternative residency or citizenship is a very personal matter and we are humbled by the trust you place in us when you make use of our services. This encourages and motivates us to continue to protect and safeguard any personal data you give us. We act in your interest and we are transparent about the processing of your personal data.

This document describes how we use and process your personal data together with how to contact us should you require further clarification or have any questions. We are also including information about how we make use of cookies and other similar technologies. It is also recommended that you read the appropriate terms and conditions.

CiviQuo is the first online marketplace for Residency and Citizenship by Investment. We intend to make it easy for our customers to understand how we process and manage their data and therefore, we will use this policy across our current and future platforms.

This one privacy statement applies to any kind of information we collect through any channel connected to the CiviQuo platform (such as contacting us via email). If you are one of our business partners, make sure to also check out our Privacy Statement for Business Partners to understand how personal data is further processed as part of the business relationship.

We might amend the Privacy Statement from time to time. If you like to keep updated with how we treat your privacy, it is recommended that you review this policy from time to time. If we make changes to the Privacy Statement which will have an impact on you, we will notify you of these changes before the new activities begin.

If you disagree with this Privacy Statement, you should discontinue using our services. If you agree with our Privacy Statement, then you are ready to start your journey towards acquiring alternative residency or citizenship with us! CiviQuo – The World, Your Way.


2. WHAT KIND OF PERSONAL DATA DOES CIVIQUO COLLECT?

2.1 Personal data you give to us

We collect and use information which you provide to us. When you submit an On-Boarding Request (OBR), you are at a minimum asked for your full name, nationality, date of birth, contact number, email address, current residential address and a copy of your passport details page.

If you need to get in touch with us through any of the channels we provide, we will collect information from you there too. You can also be asked to provide a review to help ensure future clients get exactly what they’re looking for. We will collect information from you included in your reviews, however, we will ensure that published reviews do not show who the author is.

There are also other instances where you may provide us with information. For example, if you’re browsing with your mobile device, you can decide to enable us to see your current location or grant access to your contact details – this helps us provide you with the best possible service and experience (for example, present you with prices in the currency related to your location or other recommendations). You can also open a user account, which allows you to save your personal settings, review current or previous applications or plan and manage future applications or benefit from other features only available to account holders (such as incentives or other benefits we may offer).

You can decide to participate in promotions and doing this will also mean providing us with personal data. In addition to that, you may want to provide us with feedback or ask for help with using CiviQuo’s services.

2.2 Personal data you give us about others

An OBR may include your dependents, such as your spouse or children, therefore you may be asked to provide details of others as part of your OBR, or it may be that you are asked to submit an OBR on behalf of someone else.

It is your responsibility to ensure that the person or people you have provided personal data about are aware that you’ve done so and have understood and accepted how CiviQuo uses their information (as described in this Privacy Statement).

2.3 Personal data we collect automatically

When you visit our websites or apps, we automatically collect certain information. This includes your IP address, the date and time you accessed our services, the hardware, software or internet browser you use and information about your computer’s operating system, like application versions and your language settings. We also collect information about clicks and which pages have been shown to you.

If you are using a mobile device, we collect data that identifies your mobile device, device-specific settings and characteristics, app crashes and other system activity. When you make an OBR, our system registers through which means and from which websites you have made your OBR or entered the CiviQuo websites and/or apps.

2.4 Personal data we receive from other sources

Apart from information you provide to us, we may also receive information about you from other sources. These includes business partners, such as affiliate partners, subsidiaries of the CiviQuo corporate family and other independent third parties, and anything we get from them may be combined with information provided by you. For example, our integrated third-party background check services use your information to gather open source information about you, and your dependents and report this information back to your chosen service provider to ensure that the onboarding process goes as smoothly as possible for you.

Another example is that we integrate communication services into our platforms to enable you to connect with your preferred service provider. In such scenarios, information about chats and calls may be recorded for quality and training purposes. We may also receive information about you to serve you more relevant advertisement for example additional cookie data made available to CiviQuo by social media partners.

Service Providers may share information about you with CiviQuo. This may happen if you have support questions about your pending OBRs or when disputes arise about an OBR.


3. WHY DOES CIVIQUO COLLECT AND USE YOUR PERSONAL DATA?
We use the information collected about you for various purposes. Your personal data may be used in the following ways:
3.1 OBRs: Primarily, we use your personal data to complete and administer your OBRs. An OBR is the submission sent to your chosen service provider. This is a core activity for CiviQuo and may include sending you communications in relation to your OBR such as confirmations, modifications and reminders.

3.2 Customer service: We provide international customer service from our head offices in Malta. Sharing your relevant details, such as OBR information or information about your user account with our staff allows us to respond when you need us – including helping to answer any questions you might have about your OBR and other queries.

3.3 Account facilities: CiviQuo users will be able to create a user account on our current and future channels, including our website. We use the information you give us to administer this account, allowing you to do several useful things. You can manage your OBRs, take advantage of special offers and manage your personal settings. Your account also allows you to update any reviews you have submitted. CiviQuo for Business account holders can save contact details in their account facility, manage their business showcase and manage incoming OBRs.

3.4 Marketing activities: We use your information for marketing activities. These activities include using your contact information to send you regular news of related products and services. You can unsubscribe from email marketing communications quickly, easily and at any time – just click on the "Unsubscribe" link included in any of our marketing emails.

Based on your information, individualised offers may be shown to you on any of the CiviQuo channels (including social media sites) and the content of the site displayed to you may be personalized. These may be offers that you can book directly through CiviQuo’s channels or on co-branded sites, or other third-party offers or products we think you might find interesting.

When you participate in other promotional activities (such as sweepstakes, referral programs or competitions), relevant information will be used to administer these promotions.

3.5 Communicating with you: There may be other times when we get in touch, including by email, by post, by phone or by texting you – which method we choose depends on your preferred contact information which you would have previously shared with us. And we process the communications you send to us. There could be several reasons for this, including responding to and handling any requests you or your preferred service provider have made.

CiviQuo.com offers various means to exchange information, requests, and comments about service providers and requests made through official CiviQuo channels. For more information, please see the section titled “How does CiviQuo process communications that you and your Service Provider may send through official CiviQuo channels?”.

If you have not finalized an OBR online, we can contact you with a reminder to continue with your OBR. We believe that this additional service benefits you as it allows you to carry on with an OBR without having to recommence the search activities or fill in your OBR details again.

When you use our services, we can send you a questionnaire or invite you to provide a review about your experience with CiviQuo or the chosen service provider.

We also send you other material related to your OBR, such as how to contact CiviQuo if you need our assistance, and information that we feel might be useful to you in planning or getting the best out of your journey to alternative residency or citizenship. We may also send you material related to pending OBRs or a summary of previous OBRs you made through CiviQuo.

Even if you do not have an upcoming OBR, we may need to send you other administrative messages, which may include security alerts.

3.6 Market research: We sometimes ask our customers to take part in market research. Please see the information provided when you are invited to participate to understand what personal data is collected and how your personal data is used further.

3.7 Improving our services: We also use personal data for analytical purposes. This is part of our drive to improve our services and enhance the user experience, but can also be used for testing purposes, troubleshooting and to improve the functionality and quality of our online services. The main goal here is to optimize and customize our online platform to your needs, making our site easier and more enjoyable to use. We strive to only use pseudonymized data for these analytical purposes.

3.8 Agent reviews and other service provider information: During and after the OBRs you submit through us, you may be invited to submit a review. We can also enable your dependents to provide a review. This invite asks for information about the Service Provider or their services. Reviews are always displayed anonymously. By completing a guest review, you are agreeing that it can be displayed on, for example, the relevant Service Provider information page on our websites, on our mobile apps, on our social media accounts and social media apps, or on the online platform of the relevant Service Provider or business partner's website. This is to inform other clients about the quality of the Service Provider you used, the programme you have chosen or other experiences you choose to share.

3.9 Call monitoring: When you make calls to our customer service team or you request service providers to call you back, CiviQuo uses an automated telephone number detection system to relate your telephone number to your existing OBRs – this can help save time for you, our customer support staff and the service provider. Our customer service staff or service providers may still ask for authentication, which ensures that your on-boarding details are kept confidential.

During calls with our customer service team, live listening may be done, or calls may be recorded for quality control and training purposes which includes the usage of the recordings for the handling of claims and fraud detection purposes. Not all calls are recorded, and recordings are kept for a limited amount of time and automatically deleted thereafter, unless CiviQuo has a legitimate interest to keep such recording for a longer period, including for fraud investigation and legal purposes.

3.10 Promotion of a safe and trustworthy service: In order to create a trustworthy environment for you, your family, CiviQuo’s business partners and our Service Providers, we may use personal data for the detection and prevention of fraud and other illegal or unwanted activities.

Similarly, we may use personal data for risk assessment and security purposes, including the authentication of users and OBRs. For such purposes, we may have to stop certain OBRs or put on hold OBRs until we have finished our assessment.

3.11 Legal purposes: Finally, in certain cases, we may need to use your information to handle and resolve legal disputes, for regulatory investigations and compliance, to enforce the terms of use of the CiviQuo OBR service or to comply with lawful requests from law enforcement.

Providing your personal data to CiviQuo is voluntary. However, depending on the type of service you may want to use, we may only be able to provide you with this service if certain personal data is collected. For instance, we cannot process your OBR if we do not collect your name and contact details.

If we use automated means to process personal data which produces legal effects or significantly affects you, we will implement suitable measures to safeguard you rights and freedoms, including the right to obtain human intervention.
To process your personal data as described above, we rely on the following legal bases:
In view of purpose 3.1 and 3.2, CiviQuo relies on the legal basis that the processing of the personal data is necessary for the performance of a contract, specifically to finalize and administer your OBR. If the required personal data is not provided, CiviQuo cannot finalize the OBR, nor can we provide customer service. In view of purposes 3.3 to 3.10, CiviQuo relies on its legitimate commercial business interest to provide its services, to prevent fraud and to improve its services. When using personal data to serve CiviQuo or a third party's legitimate interest, CiviQuo will always balance your rights and interests in the protection of your personal data against CiviQuo rights and interests or those of the third party.
For purposes 3.11, CiviQuo relies also where applicable on compliance with legal obligations (such as lawful law enforcement requests). Where needed under applicable law, CiviQuo will obtain your consent prior to processing your personal data for direct marketing purposes.
If you wish to object to the processing set out under 3.3 to 3.10 and no opt-out mechanism is available to you directly (for example, in your account settings), to the extent applicable, please contact [email protected]

4. HOW DOES CIVIQUO SHARE YOUR DATA WITH THIRD PARTIES?
In certain circumstances, we’ll share your personal data with third parties.
a. Your chosen Service Provider: In order to complete your OBR, we transfer relevant OBR details to the Service Provider you have booked. Depending on the OBR and the Service Provider, this can include your name, contact details, payment details, the same details

for your dependents and any preferences or other information you specified when you made your OBR. If you have a query about your OBR, we may contact the Service Provider and ask them to handle your request. In cases of OBR-related disputes, we may provide the Service Provider with information about the OBR process as needed to handle the dispute. This may include a copy of your OBR confirmation as proof that an OBR was made.

b. Your local CiviQuo office: In order to support the use of the CiviQuo services, your details may be shared with subsidiaries of the CiviQuo corporate family which act as service providers for CiviQuo, including in relation to customer support services.

c. Third-party service providers: We use service providers, which are not part of the CiviQuo corporate family, to support us in providing the CiviQuo services. These service providers provide support services such as:

a. customer support;
b. market research;
c. fraud detection and prevention services, including anti-fraud screening service;
d. payment services. We use third parties to process payments, handle chargebacks or provide billing collection services. When a chargeback is requested for your OBR by either you or by the holder of the credit card used to make your OBR, we need to share certain OBR details with the payment service provider and the relevant financial institution to handle the chargeback. This may also include a copy of your OBR confirmation or the IP address used to make your OBR.

We may share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes.

e. marketing services. We share personal data with advertising partners, including your email address, as part of marketing the CiviQuo services via third parties (to ensure that relevant advertisements are shown to the right audience). We strive to only share email addresses in hashed form to enable the matching of your email address with an existing customer database so that your email address cannot be used for other purposes.

All service providers are required to continue to adequately safeguard your personal data.

d. Competent authorities: We disclose personal data to law enforcement insofar as it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts and fraud or if we are otherwise legally obliged to do so. We may need to further disclose personal data to competent authorities to protect and defend our rights or properties, or the rights and properties of our business partners.

e. Business partners: We work with many business partners around the world. These business partners distribute or advertise the CiviQuo services, including the services and products of our Service Providers.

When you make an OBR on one of our business partners’ websites or apps, certain personal data that you give them such as your name and email address, your address, payment details and other relevant information, will be forwarded to us to finalize and administer your OBR. If customer service is provided by the business partner, CiviQuo will share details relevant to your OBR with the business partners (as and when needed) in order to provide you with appropriate and efficient support. When you make an OBR through one of our business partners’ websites, the business partners can receive certain parts of your personal data related to the specific OBR such as your name and email address. This is for their own internal purposes (such as analytical purposes) and, if requested by you, for the administration of loyalty programs or marketing.

When you make an OBR on a business partners’ website, please also take the time to read their privacy notice if you wish to understand how these business partners may process your personal data. For fraud detection and prevention purposes and as strictly necessary, we may also exchange information about our users with business partners.
The transmission of personal data as described in this Privacy Statement may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the countries within the European Union. Where required by European law, we shall only transfer personal data to recipients offering an adequate level of data protection. In these situations, as may be required, we make contractual arrangements to ensure that your personal data is still protected in line with European standards. You can ask us to see a copy of these contractual agreements by contacting us at [email protected]

5. HOW IS YOUR PERSONAL DATA SHARED WITHIN THE CIVIQUO CORPORATE FAMILY?
Civiquo.com is part of the CiviQuo corporate family.
We may receive personal data about you from other companies of the CiviQuo corporate family or share your personal data with them for the following purposes:
5.1 To provide services (including to make, administer and manage OBRs or handle payments);
5.2 To provide customer support services;
5.3 To detect, prevent and investigate fraudulent, other illegal activities and data breaches;
5.4 For analytical and product improvement purposes;
5.5 To provide personalised offers or send you marketing with your consent or as otherwise permitted by applicable law;
5.6 To ensure compliance with applicable laws


Unless indicated otherwise, for purposes 5.1 to 5.5, CiviQuo relies on its legitimate interest to share and receive personal data. For purpose 5.6, CiviQuo relies where applicable on compliance with legal obligations (such as lawful law enforcement requests).
All companies within the CiviQuo corporate family may need to exchange customer personal data to ensure it protects all users from fraudulent activities on its online platforms.

6. HOW DOES CIVIQUO PROCESS COMMUNICATIONS THAT YOU AND YOUR CHOSEN SERVICE PROVIDER MAY SEND VIA THE CIVIQUO PLATFORM?
CiviQuo can offer you and Service Providers ways to communicate about new and existing OBRs, directing the communications via the CiviQuo platform. This allows you to contact your Service Provider through CiviQuo, with questions including about your OBR.
CiviQuo accesses communications and may use automated systems to review, scan, and analyse communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research; customer engagement, including to provide you with information and offers that we believe may be of interest to you; and customer or technical support. We reserve the right to block the delivery of or review communications that we, in our sole discretion, believe may contain malicious content, spam, or may pose a risk to you, our partners, CiviQuo, or others. Note, all communications sent or received using CiviQuo communication tools will be received and stored by CiviQuo. Service Providers to whom you would have submitted an OBR may choose to communicate with you directly via email or other channels that CiviQuo does not control.

7. HOW DOES CIVIQUO MAKE USE OF MOBILE DEVICES?
CiviQuo may offer free apps in the future, as well as versions of our regular website that have been optimised for mobile and tablet browsing. These apps and mobile websites process the personal details you give us in much the same way as our website does – and they also allow you to use location services if you want us to. With your consent, we may send you push notifications with information about your OBR.
You may grant us access to your location data or contact details in order to provide services requested by you. When you upload a picture from your mobile device, your picture may also be tagged with your location information. Please read the instructions of your mobile device to understand how to change the settings and enable the sharing of such data or the receipt of push notifications.
We make use of something known as cross-device tracking in order to optimize our services and marketing activities. This may be done with or without the use of cookies. With cross-device tracking, CiviQuo can track user behaviour across multiple devices.


As part of cross-device tracking, CiviQuo may combine data collected from a browser or mobile device with another computer or device linked to the computer or device from which the data was collected.
In order to optimize the content of the CiviQuo newsletter, CiviQuo combines the searches and OBRs made from different computers and devices. You can unsubscribe from the CiviQuo newsletter at any time.
Personalised advertisements shown to you on other websites or in apps, can be offered based on your activities on linked computers and devices. By amending your cookie settings on your device. You can change your cross-device tracking settings for advertisement purposes. You should know that logging out of your user account will not actually mean that you no longer receive personalised advertisements.

8. HOW DOES CIVIQUO MAKE USE OF SOCIAL MEDIA?
At CiviQuo, we use social media in different ways. We use it partly to facilitate the use of our platform, to promote the services that our Service Providers offer, and to advertise, improve and facilitate our own services. You are free not to use the social media features.
In the future, we may enable you to log in with your social media account. This enables you to sign in to a CiviQuo user account with your social media account, which saves you from having to remember different user names and passwords for different online services. After you’ve signed in once, you’ll always be able to use your social media account to sign in to your CiviQuo account. You can decouple these accounts from each other at any time too.
We may also integrate social media plugins into the CiviQuo websites and apps. This means that when you click on one of the buttons (such as Facebook’s ‘Like’ button) certain information is shared with these social media providers. If you are logged in to your social media account at the same time, your social media provider may relate this information to your social media account and possibly present your actions on your social media profile to be shared with others in your network.
We may integrate other social media services (like social media messaging) to interact with CiviQuo or with your contacts about our services. We may maintain social media accounts and offer apps on several social media sites. Whenever you connect with CiviQuo through social media, your social media service provider may allow you to share information with CiviQuo.
If you choose to share, you will generally be told by your social media provider which information will be shared. For example, in the future, when you log into a CiviQuo user account with your social media account, certain information (as authorized by you to your social media provider) may be shared with CiviQuo. This might include your email address, age or profile pictures saved in your user account.

When you register with a CiviQuo social media app or connect to a social media messaging service without having a CiviQuo user account, the information you choose to share with us may include the basic information available in your social media profile (including your email address, status updates and a list of your contacts). We’ll use this information to help provide you with the service you requested – for example, to forward a message you want to send to your contacts or to create a personalised user experience in the app itself or on our websites. It means that if you want us to, we can tailor our services to suit your needs, connecting you and your friends with the best suited residency and citizenship by investment programmes and analysing and enhancing our related services. Your social media provider will be able to tell you more about how they use and process your data whenever you connect with CiviQuo through them, for instance by combining personal data they collect when you use CiviQuo through them with information they collect when you use other online platforms linked with your social media provider.

9. WHAT SECURITY AND RETENTION PROCEDURES DOES CIVIQUO PUT IN PLACE TO SAFEGUARD YOUR PERSONAL DATA?
We observe reasonable procedures to prevent unauthorised access to, and the misuse of, personal data.
We use appropriate business systems and procedures to protect and safeguard the personal data you give us. We also use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorized personnel are permitted to access personal data in the course of their work.
We will retain your personal data for as long as we deem it necessary to enable you to use our services, to provide our services to you (including maintaining the online user account (if created), to comply with applicable laws, resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All personal data we retain will be subject to this Privacy Statement.
If you have a question about a specific retention period for certain types of personal data, we process about you, please contact us via [email protected]

10. HOW DOES CIVIQUO TREAT PERSONAL DATA OF CHILDREN?
The services offered by CiviQuo are not directed at children under 18 years old. For children younger than 18 years old, the use of any of our services is only allowed with the valid consent of a parent or a guardian. In limited cases, such as part of an OBR or in exceptional other circumstances (such as features addressed to families), CiviQuo may collect and use information of children only as provided by the parent or guardian or with their consent. If we become aware that we process information of a child under 18 years old without the valid consent of a parent or guardian, we reserve the right to delete it.


11. HOW CAN YOU CONTROL THE PERSONAL DATA YOU HAVE GIVEN TO CIVIQUO?
We want you to be in control of how your personal data is used by us. You can do this in the following ways:
a. you can ask us for a copy of the personal data we hold about you;
b. you can inform us of any changes to your personal data, or you can ask us to correct any of the personal data we hold about you but, as explained below, you may be able to make such changes yourself;
c. in certain situations, you can ask us to erase, or block or restrict the processing of, the personal data we hold about you, or object to ways in which we are using your personal data; and
d. in certain situations, you can also ask us to send the personal data you have given us to a third party;
Where we are using your personal data based on your consent, you are entitled to withdraw that consent at any time subject to applicable law. Moreover, where we process your personal data based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal data subject to applicable law.
We rely on you to ensure that your personal data is complete, accurate and current. Please do inform us promptly of any changes to or inaccuracies of to your personal data by contacting us.
If you have an online user account, you can access some of your personal data through our website/apps. Our website/apps generally present you with the option to add, update or remove information we have about you.
If any personal data we have about you is not accessible through our website/apps, you can send us your request at no cost. For any of your requests regarding this Privacy Statement and to exercise any of your rights or if you have a complaint, please contact us by contacting our Data Protection Officer at [email protected] You may also contact your local data protection authority.
If you wish to object to the processing of your personal data based on legitimate interest and no opt-out mechanism is available to you directly, please contact us at [email protected]

12. Who is responsible for the processing of personal data via CiviQuo and how to contact us?
CiviQuo Ltd. controls the processing of personal data as described in this Privacy Statement. CiviQuo Ltd. is a private limited liability company, incorporated under the laws of Malta and has its offices at Level 1, Aragon House, Dragonara Road, St. Julian’s STJ3140, Malta.

If you have any questions about this Privacy Statement or about our processing of your personal data, please contact our data protection officer via [email protected] and we’ll get right back to you. For questions about your OBRs, please contact our customer service team via [email protected] Requests from law enforcement should be sent directly to [email protected]


Cookie Statement

Whenever you use our online services, including our applications, cookies and other tracking technologies can be used in various ways, such as making the CiviQuo website work, to analyse traffic, or for advertisement purposes. These technologies are either used by us directly, or by our business partners, including third party service providers and advertisers we work with. If you want to learn more about what a cookie is, how they are used and what your choices are, please read this document.


1. WHAT IS A COOKIE?

A cookie is a small amount of data that is placed in the browser of your computer or on your mobile device. So-called “first party cookies” are cookies which are served by the entity operating the domain through which the cookie is served. CiviQuo’s own cookies are therefore “first party cookies”. In case we allow others to service cookies through the CiviQuo websites and apps, these cookies are so-called “third party cookies”.

In addition, there is a difference between session cookies and permanent cookies. Session cookies will only exist until you close your browser. Permanent cookies have a longer lifespan and are not automatically deleted once you close your browser. We strive to serve cookies or allow the serving of cookies in line with industry best practices. Only in exceptional circumstances, such as for security purposes and where necessary, will a cookie have a longer lifespan than that.

Next to cookies, other tracking technologies are used which are like cookies. These can include web beacons (also known as pixel tags, web bugs or gifs), tracking URLs or software development kits (SDKs). A web beacon is a tiny graphic image of just one pixel that can be delivered to your computer as part of a web page request, in an app, in an advertisement or in an HTML email message. Pixels can be used to retrieve information from your device, such as your device type or operating system, IP address, and time of visit. They are also used to serve and read cookies in your browser. Tracking URLs are used to understand from which referring website the CiviQuo websites or apps are used. SDKs are small pieces of code included in apps, which function like cookies and web beacons.

All these technologies are together referred to in this Cookie Statement as “cookies”.


2. How are cookies used?

Cookies are used for different purposes. They allow you to be recognised as the same user across the pages of a website, between websites or when you use an app. The types of information that we collect through cookies include IP address; device ID; viewed pages; browser type; browsing information; operating system; internet service provider; timestamp; whether you have responded to an advertisement; the referring URL; and features used, or activities engaged in within the website/apps.

Our website and apps use cookies for different purposes:

a. Technical cookies: We try to give our visitors an advanced, user-friendly website and apps that adapt automatically to their needs and wishes. To achieve this, we use technical cookies to show you our website, to make them function correctly, to create your user account, to sign you in and to manage your OBRs. These technical cookies are necessary for our website to function properly;

b. Functional cookies: We also use functional cookies to remember your preferences and to help you to use our website and apps efficiently and effectively. If you are using the CiviQuo websites or apps to search for a residency or citizenship by investment programme, for example, these cookies remember your searches and your previously viewed service providers.

We may also use cookies to remember your registration information so that you don’t have to retype your login credentials each time you visit our site. Passwords will, however, always be encrypted. These functional cookies are not strictly necessary for the functioning of our website or apps, but they add functionality and enhance your CiviQuo experience.

c. Analytics cookies: We use these cookies to gain insight into how our visitors use CiviQuo. This means we can find out what works and what doesn't, optimize and improve our websites or apps, understand the effectiveness of advertisements and communications, and ensure we continue to be interesting and relevant. The data we gather can include which web pages you have viewed, which referring/exit pages you have entered and left from, which platform type you have used, which emails you have opened and acted upon, and date and time stamp information.

It also means we can use details about how you’ve interacted with the site, such as the number of clicks you make on a given page, your mouse movements and scrolling activity, the search words you use and the text you enter various fields. We make use of analytics cookies as part of our online advertising campaigns to learn how users interact with our website or apps after they have been shown an online advertisement. This may include advertisements on third-party websites. Analytics cookies may also be used to enable our business partners to learn if their customers make use of offers integrated into their websites.

d. Commercial cookies: We use third-party cookies as well as our own to display personalized advertisements on our websites and on other websites. This is called “retargeting,” and it is based on browsing activities, such as the destinations you have been searching for, the programme you have viewed and the prices you have been shown.


3. WHAT ARE YOUR CHOICES?

To learn more about cookies and how to manage or delete them, simply visit allaboutcookies.org and the help section of your browser. In the settings for browsers such as Internet Explorer, Safari, Firefox or Chrome, you can set which cookies to accept and which to reject. Where you find these settings depends on which browser you use. Use the "Help" function in your browser to locate the settings you need.

If you choose not to accept certain technical and/or functional cookies, you may not be able to use some functions on our website. We may choose to not support the “Do Not Track” browser settings. In case a common standard has been developed which defines what exactly is meant by “Do Not Track” browser signals, we will review this Cookie Statement again.

a. Advertising: When it comes to online advertising and marketing companies, we strive to work with companies that of good repute and that follow industry best practices. You may want to visit www.youronlinechoices.com or www.youradchoices.com to learn how to opt out of customized advertisement. Your mobile device may allow you to limit the sharing of information for retargeting purposes through its settings.

Please be aware that opting out of an online advertising network does not mean that you will no longer receive or be subject to online advertising or marketing analysis. It means that the network from which you opted out will no longer deliver ads tailored to your web preferences and browsing patterns.

b. Analytics: In order to control the collection of data for analytical purposes through Google Analytics from certain browser types, you may want to visit the following link:

Google Analytics Opt-out Browser Add-on (only for desktop). In order to control the collection of data for analytical purposes by Yandex.Metrica (a tracking pixel owned by Russian search engine YANDEX), users with language setting Russian, Ukrainian or Turkish may want to visit the following link: yandex.com. Yandex.Metrica is not used for users with any other languages. You also have an option to opt-out from Yandex personalized advertisement. In order to do so, please, visit this page and untick the box “Consider my interests”.

c. If you have any questions about this Cookie Statement, please send an email to [email protected] Our Cookie Statement may also be amended from time to time. So, visit this page regularly to keep abreast of updates.

Last Updated 1st of March 2019