Last updated: January 6, 2026
This Privacy Policy for Citrinitas Capital Management Inc. (doing business as Citrini Research) ("Company," "we," "us," or "our") explains how we collect, use, disclose, and safeguard your information when you visit our website (http://www.citrini.com) and use our services ("Services").
If you do not agree with the terms of this Privacy Policy, please do not access or use our Services.
If you have any questions, you can contact us at admin@citrini.com.
1. INFORMATION WE COLLECT
We collect personal information that you voluntarily provide to us when you:
Personal Information
This may include:
Automatically Collected Information
When you access our Services, we may automatically collect certain technical and usage information, including:
We use Vercel Analytics to collect aggregated and anonymized usage data to understand how users interact with our website and to improve performance and user experience. This data does not identify individual users.
Sensitive Information
We do not collect or process sensitive personal information, and our Services are not designed to collect financial or portfolio data.
2. HOW WE USE YOUR INFORMATION
We use your information strictly for legitimate business purposes, including:
We do not use personal data for profiling, automated decision-making, or targeted advertising.
3. LEGAL BASES FOR PROCESSING (EU/UK USERS)
If you are located in the European Economic Area (EEA) or United Kingdom, we process your personal data under the following legal bases:
4. SHARING YOUR INFORMATION
We limit disclosure of personal information to what is necessary for business operations.
Service Providers
We may share information with a limited number of trusted infrastructure and service providers that support our operations, including hosting and analytics providers (such as Vercel). These providers are contractually obligated to safeguard information and use it only for specified purposes.
Business Transfers
In the event of a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction, subject to confidentiality protections.
Legal and Regulatory Requirements
We may disclose information where required by law, regulation, legal process, or governmental request.
We do not sell, rent, or trade personal information to third parties.
5. DATA RETENTION
We retain personal information only as long as necessary to:
When no longer required, we will delete or anonymize your information.
6. DATA SECURITY
We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information.
However, no system is completely secure, and we cannot guarantee absolute security.
7. CHILDREN’S PRIVACY
Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children.
If we become aware that we have collected data from a minor, we will delete it promptly.
8. YOUR PRIVACY RIGHTS
Depending on your location, you may have rights including:
To exercise your rights, contact us at admin@citrini.com.
We will respond in accordance with applicable law.
9. DO NOT TRACK & GLOBAL PRIVACY CONTROL
Our Services do not currently respond to Do Not Track (DNT) browser signals due to lack of a consistent industry standard.
We do recognize Global Privacy Control (GPC) signals where required by law and treat them as valid opt-out requests.
10. U.S. PRIVACY RIGHTS (INCLUDING TEXAS & CALIFORNIA)
If you are a U.S. resident, you may have rights under applicable state laws, including:
We do not sell personal information or use it for targeted advertising.
To submit a request, email admin@citrini.com.
We may need to verify your identity before processing your request.
11. INTERNATIONAL USERS
If you access our Services from outside the United States, your information may be transferred to and processed in the United States.
By using our Services, you consent to this transfer.
12. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. Updates will be reflected by a revised "Last updated" date.
We encourage you to review this policy periodically.
13. CONTACT US
If you have questions about this Privacy Policy, contact us at:
Citrinitas Capital Management Inc.
515 Madison Avenue 14B
New York, NY 10022 United States
Email: admin@citrini.com
14. DATA REQUESTS
To request access, correction, or deletion of your personal data, please email admin@citrini.com with the subject line "Data Request." We will respond in accordance with applicable laws.
IMPORTANT NOTES FOR COMPLIANCE
This Privacy Policy reflects a conservative, investor-grade approach to data governance:
This policy is designed to be appropriate for institutional users, investors, and professional audiences expecting high standards of data handling and transparency.