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Privacy Policy

Last updated: October 2025

Data Controller

Company Name: Citadel Tech Solutions
Email: support@citadel-master-pro.com

1. Introduction

This Privacy Policy ("Policy") describes how Citadel Tech Solutions ("we", "our") collects, uses, stores and protects users' personal data ("you", "your", "User") who visit our website and purchase the software Citadel Master Pro.

This Policy is drafted in compliance with:

We invite you to carefully read this Policy to understand how we process your personal data.

2. Personal Data Collected

2.1 Data Provided Directly by the User

We collect the following personal data that you voluntarily provide to us:

Data Type When Collected Purpose
First and Last Name During purchase or demo request Identification, service delivery, support
Email Address During purchase or demo request Software delivery, communications, support
ID cTrader During purchase or demo request Software customization and activation
Account Capital During purchase or demo request Software configuration optimization
Operating System During purchase or demo request Provision of compatible software version
Payment Data During purchase (via PayPal) Payment processing (managed by PayPal)

2.2 Automatically Collected Data

When you visit our website, we may automatically collect:

This data is collected through server logs and cookies (see Cookie section).

2.3 Data We DO NOT Collect

We do not collect nor have access to:

3. Purpose and Legal Basis of Processing

Your personal data is processed for the following purposes and legal bases:

Purpose Legal Basis (GDPR)
Provision of purchased service
Software customization with your cTrader ID, email delivery, license activation
Contract performance (Art. 6.1.b GDPR)
Payment processing
Transaction management, invoicing, accounting
Contract performance (Art. 6.1.b GDPR) and legal obligations (Art. 6.1.c GDPR)
Technical support
After-sales assistance, problem solving, configuration optimization
Contract performance (Art. 6.1.b GDPR)
Service-related communications
Sending software updates, important notifications, terms changes
Contract performance (Art. 6.1.b GDPR) and legitimate interest (Art. 6.1.f GDPR)
Legal compliance
Retention of tax and accounting data, response to authority requests
Legal obligations (Art. 6.1.c GDPR)
Direct marketing
Sending newsletters, promotions, product news (only with consent)
Consent (Art. 6.1.a GDPR)
Service improvement
Anonymous statistical analysis, website optimization
Legitimate interest (Art. 6.1.f GDPR)

4. Processing Methods and Security

4.1 Processing Methods

Personal data is processed with IT and telematic tools, adopting appropriate security measures to ensure:

4.2 Security Measures

We implement the following technical and organizational measures:

4.3 Data Retention

We retain your personal data for the following periods:

After these terms, data will be deleted or anonymized irreversibly.

5. Data Sharing with Third Parties

5.1 Categories of Recipients

Your personal data may be shared with the following categories of subjects:

Destinatario Purpose Ruolo GDPR
PayPal
(paypal.com)
Online payment processing Independent data controller
Netlify
(netlify.com)
Website hosting and form management Data processor
Email service providers Sending transactional emails and communications Data processor
Accountant/Tax Consultant Tax and accounting compliance Data processor
Competent authorities Legal compliance, judicial requests N/A (legal obligation)

5.2 Extra-EU Transfer

Some of the services we use (e.g. cloud services) may transfer data to countries outside the EU. In such cases, we ensure that the transfer occurs:

5.3 We Do Not Sell Your Data

⚠️ IMPORTANT: We do not sell, rent or transfer your personal data to third parties for marketing or commercial purposes. Your data is used exclusively for the purposes indicated in this Policy.

6. Cookies and Similar Technologies

6.1 What are Cookies

Cookies are small text files that websites save on your device to remember information about your visit.

6.2 Types of Cookies Used

a) Technical Cookies (Necessari)

These cookies are essential for site operation. They do not require consent.

b) Third-Party Cookies

6.3 Cookie Management

You can manage or disable cookies through your browser settings:

Note: Disabling technical cookies may compromise site functionality and prevent software purchase.

7. Your Rights (GDPR)

As a data subject, you have the following rights regarding your personal data:

7.1 Right of Access (Art. 15 GDPR)

You have the right to obtain confirmation whether or not processing is underway of personal data concerning you and, if so, to obtain access to the data and the following information:

7.2 Right of Rectification (Art. 16 GDPR)

You can obtain correction of inaccurate personal data or integration of incomplete data.

7.3 Right to Deletion - "Right to be Forgotten" (Art. 17 GDPR)

You can obtain deletion of your personal data in the following cases:

Limitations: We cannot delete data that we are required to retain by law (e.g. tax data).

7.4 Right to Restriction (Art. 18 GDPR)

You can obtain limitation of processing when:

7.5 Right to Portability (Art. 20 GDPR)

You have the right to receive your data in a structured format, commonly used and machine-readable, and to transmit them to another data controller.

7.6 Right to Object (Art. 21 GDPR)

You can object at any time to the processing of your personal data based on the legitimate interest of the controller, including direct marketing.

7.7 Right to Withdraw Consent (Art. 7.3 GDPR)

When processing is based on consent, you can revoke it at any time. Revocation does not affect the lawfulness of processing carried out before revocation.

7.8 Right to Lodge a Complaint with Supervisory Authority (Art. 77 GDPR)

You have the right to lodge a complaint to the Data Protection Authority if you believe the processing of your data violates GDPR:

7.9 How to Exercise Your Rights

To exercise any of your rights, you can contact us at:

Ti risponderemo entro 30 giorni from receipt of request (extendable by an additional 60 days in complex cases, with due notice).

Important: To ensure security, we may ask you to verify your identity before processing the request.

8. Marketing Communications

8.1 Newsletter and Promotional Communications

If you have given consent, we may send you marketing communications via email regarding:

8.2 How to Unsubscribe

You can unsubscribe from marketing communications at any time:

Note: You will continue to receive essential service communications (e.g. order confirmations, critical software updates) even after unsubscribing from newsletter.

9. Minors

Our service is not intended for minors under 18 years of age. We do not knowingly collect dati personali di minori.

If you are a parent or guardian and believe your child has provided us with personal data, contact us immediately at support@citadel-master-pro.com and we will proceed with immediate data deletion.

10. Changes to Privacy Policy

We reserve the right to modify this Privacy Policy at any time for:

Substantial changes will be communicated via:

We invite you to periodically consult this page to stay informed about how we protect your data.

11. Links to Third-Party Sites

Our site may contain links to third-party websites (e.g. MyFXBook, PayPal). This Privacy Policy applies exclusively to our site.

We are not responsible for the privacy practices of third-party sites. We invite you to read the privacy policies of every site you visit.

12. Privacy Inquiries Contact

For any question, doubt or request related to this Privacy Policy o to the processing of your personal data, you can contact us:

Data Controller:
Citadel Tech Solutions

Email: support@citadel-master-pro.com
Email Subject: "Privacy Policy - [your request]"

Response Time: Within 30 days from receipt of request

13. Summary of Your Rights

Access: Know what data we have about you
Rectification: Correct inaccurate data
Deletion: Request removal of your data
Limitation: Limit how we use your data
Portability: Receive your data in transferable format
Opposition: Object to certain types of processing
Withdraw consent: Withdraw previously given consent
Complaint: File a complaint with the Authority Privacy

14. Important Information

User Responsibility

It is your responsibility:

Limitations

Despite the security measures implemented, no system is completely secure. We cannot guarantee absolute security of data transmitted over the Internet.

15. GDPR Compliance - Summary

This Privacy Policy complies with GDPR and guarantees:

16. Privacy Policy Acceptance

By using our website and services, you accept the terms of this Privacy Policy.

If you do not accept these terms, please do not use our website and services.

For any questions or to exercise your rights, do not hesitate to contact us at support@citadel-master-pro.com

Your Privacy is Important to Us

Citadel Tech Solutions
Email: support@citadel-master-pro.com

Document updated October 2025 in compliance with EU Regulation 2016/679 (GDPR)