Privacy Policy

1. Who we are (data controller)

This website is operated by Citizenship and co L.L.C-FZ (trading as “Citizenship & Co.”; “we”, “us”, “our”), a company licensed in Dubai, United Arab Emirates under Business Licence No. 2650250.01, with its office at Office 1409, Grosvenor Business Tower, Barsha Heights, Dubai, United Arab Emirates. We are the controller responsible for the personal data described in this policy.

For any privacy question or request, contact us at info@citizenship.cc, or call +971 4 294 6199 (landline) or +971 54 166 2288 (mobile / WhatsApp).

2. Information we collect

We only collect what you choose to give us, plus a limited amount of technical information needed to run the site securely. Specifically:

• Enquiry and consultation details you submit through our contact, “book a consultation”, brochure-download, and program-finder forms — typically your name, email address, telephone or WhatsApp number, nationality, country of residence, the program or region you are interested in, your indicated investment range, when you would like to start, and anything you write in a message. If you use the Program Finder, we also receive the family members you entered there (relationship and age only — no names).
• Program-finder responses — the answers you select in the interactive questionnaire, so we can suggest suitable programs.
• Newsletter and update preferences — your email address if you subscribe, and, whenever you ask for occasional updates on any form, the date and the wording you agreed to, so we can show what you consented to.
• Campaign details — if you arrive through a link that carries campaign tags (for example, from an advertisement or a newsletter), the campaign name, the site that sent you, and the page you first landed on. These describe the link you followed, not you.
• Technical and usage data collected automatically — such as your approximate location (country/region), device and browser type, and the pages you view, gathered through the website analytics described in section 5.

3. What we do not collect through this website

We do not take payment through this website, and we do not ask you to upload identity documents, passports, or financial statements online. Any such documents required for a formal engagement are collected separately, through secure channels, only after you become a client.

We do not knowingly collect information from anyone under 18. Our services are directed at adults; where a family application includes minors, information about them is provided by the responsible adult during a formal engagement, not through this website.

4. How and why we use your information

We use your personal data for the purposes below, each with a lawful basis under applicable data-protection law (including the UAE Personal Data Protection Law and, for visitors in the EU/UK, the GDPR):

• To respond to your enquiry and provide the information, brochures, or comparison you request (to take steps at your request, and our legitimate interest in responding to you).
• To arrange and conduct consultations and, where you engage us, to deliver our advisory services (performance of a contract, once a separate engagement letter is in place).
• To send occasional program updates by email, where you have asked for them (your consent, recorded with its date and wording, which you can withdraw at any time with the unsubscribe link in any update or by contacting us).
• To understand which campaigns and pages lead to enquiries, using the campaign details above (our legitimate interest in knowing which of our own outreach works).
• To meet legal, regulatory, know-your-client, and anti-money-laundering obligations that apply to our work (compliance with a legal obligation).
• To keep the website secure, prevent abuse, and understand which content is useful (our legitimate interest in operating and improving the site).

5. Cookies and analytics

Analytics cookies are used only with your consent. When you first visit, a banner asks whether we may use Google Analytics 4 to understand which pages help people most (for example, how many people viewed a program page). If you decline, Google Analytics sets no cookies; under Google's consent mode it may still receive cookieless signals that a page was viewed, without any identifier, which Google uses only in aggregate. You can change or withdraw your choice at any time with “Cookie settings” at the bottom of every page.

Campaign details (see section 2) are kept in your browser's own storage for 30 days — not in a cookie — so that an enquiry you send later can be credited to the campaign that brought you. If you have accepted analytics cookies, we also keep the reference Google adds to its ad links; we do not send it back to Google.

Our office map is not loaded until you press “Show map”. Only then does your browser fetch it from Google Maps, which may set Google cookies under Google's own privacy policy; until you press it, nothing is sent to Google.

Two further tools run without cookies: Cloudflare Web Analytics and Ahrefs Web Analytics count page views in aggregate and cannot identify you. Strictly necessary cookies that make the site function are exempt from consent.

Advertising cookies are used only if you choose “Accept all”. We then use the Meta Pixel, a tool from Meta Platforms Ireland Ltd, to measure whether our Facebook and Instagram ads lead to enquiries and to help Meta show those ads to people likely to find them relevant. The Pixel sets a Meta cookie and tells Meta which of our pages you view and whether you sent an enquiry — never your name, email address, phone number or the contents of any form. Our server sends Meta the same events through Meta’s Conversions API, with your IP address, your browser type and the Meta cookie, so the measurement still works when a browser blocks the Pixel. It sends nothing if you have not chosen “Accept all”. Meta processes this as described in its own privacy policy, and may combine it with what it already knows about your Meta account. Choosing “Analytics only” or “Decline” keeps the Pixel off, and you can withdraw your choice at any time with “Cookie settings”.

We do not sell your data, and apart from the Meta Pixel when you allow it, we do not use advertising cookies or track you across other websites.

6. Who we share it with

We do not sell or rent your personal information to anyone. We share it only in these limited circumstances:

• Service providers (processors) acting on our instructions under contracts that require them to protect your data: Cloudflare (website delivery and security), our hosting provider in the Netherlands (Worldstream), Resend (email such as enquiry confirmations and the updates you asked for), and Google (Analytics 4, only with your consent). Enquiries and newsletter subscriptions are recorded in our own client-management system, which runs on our servers at the same hosting provider rather than with a third-party CRM. None of them may use your data for their own purposes. Meta is different: it receives Meta Pixel data only if you choose “Accept all”, and uses it for its own purposes as well as ours (see section 5). If you enquire through a Facebook or Instagram lead form, our client-management system later tells Meta how far that enquiry progressed (for example qualified, proposal sent or signed), using only Meta’s own reference for the form you sent — never your name, contact details or answers.
• Government units and licensed submission partners — only where an application you have instructed us to manage requires it, and only with your knowledge, as part of a formal engagement.
• Professional advisers (such as lawyers or accountants) where necessary to provide the service you have requested.
• Authorities or third parties where we are required to do so by law, regulation, or court order, or to establish, exercise, or defend legal claims.

7. International transfers

We are based in the United Arab Emirates, and our service providers may process data in other countries. Where personal data is transferred across borders, we take steps to ensure it remains protected by appropriate safeguards consistent with applicable law.

8. How long we keep it

We keep enquiry records only for as long as needed to respond to you and to pursue a possible engagement, and then delete them. Where you become a client, we retain records for the period required to deliver the service and to meet legal, regulatory, and anti-money-laundering record-keeping obligations, after which they are securely deleted or anonymized.

9. How we protect it

We apply appropriate technical and organizational measures to protect personal data against loss, misuse, and unauthorized access. Within our practice, access is limited to the advisors working on your matter. No method of transmission or storage is completely secure, but we take reasonable steps to safeguard your information.

10. Your rights

Subject to applicable law, you may exercise the following rights in relation to your personal data by contacting us:

• Access — request a copy of the information we hold about you.
• Rectification — ask us to correct information that is inaccurate or incomplete.
• Erasure — ask us to delete your information where there is no overriding legal reason to keep it.
• Restriction and objection — ask us to restrict, or object to, certain processing, including direct marketing.
• Withdraw consent — unsubscribe from updates at any time using the link in any update email, change your cookie choice with “Cookie settings”, or contact us.
• Complain — raise a concern with us, and with the competent data-protection authority.

11. Third-party links

This website may link to third-party sites, such as government program pages. We are not responsible for the content or privacy practices of those sites; please review their own policies.

12. Changes to this policy

We may update this policy from time to time to reflect changes in our practices or the law. The “last updated” date above shows when it was last revised. Material changes will be posted on this page.

13. How to reach us

To make any privacy request, or if you have questions about this policy, write to info@citizenship.cc or call +971 4 294 6199 (landline) or +971 54 166 2288 (mobile / WhatsApp). We aim to respond within the timeframes required by applicable law.