Privacy Policy

This policy explains what personal information Civita Global LLC, doing business as Civita("Civita", "we", "us"), collects, why, how we use and protect it, and the choices and rights you have over it. Civita is an independent investment-migration advisory operating from the United States. The Sites can be accessed internationally, including from the European Economic Area, the United Kingdom and California. References to where we work describe service availability and business-hour coverage only; they do not represent a branch, office or regulated establishment.

Information we collect

Information you give us. When you contact us or request a Program-Fit Report, we collect what you submit: your name and email address; age; citizenship, country of birth, residence and tax-residence context; the relationships, ages and country context of family members applying with you; budget, capital-liquidity preferences, goals and timeline; source-of-funds category; and any immigration or due-diligence flags you choose to disclose. We ask for a high-level flag rather than supporting records at the intake stage. Do not submit passport or identity-document numbers, exact birth dates, account numbers, case numbers or document copies through a site form.

Brief interest list. If you ask to hear about The Brief, we store your email address and the page where you signed up as an expression of interest. No automated newsletter is currently sent. You may withdraw that interest at any time by emailing us.

Payment information. Online checkout is currently paused. If it reopens, payment will be processed by Square. Civita will not receive or store full card details; Square will handle them under its own terms.

Information collected automatically. When you use the site we collect limited technical data such as IP address, device and browser type, pages viewed and referring source. This comes from Cloudflare, which provides hosting, security and privacy-first cookieless analytics, and, only if you allow it, from Google Analytics (see Cookies and analytics below).

How we use your information

To respond to you and to prepare and deliver advisory work you request.
To record and manage requests to hear about The Brief.
To communicate with a professional you independently engage, but only when you ask us to and the scope is confirmed in writing.
To operate, secure and improve our sites.
To meet legal, regulatory, and anti-money-laundering obligations.

Our legal bases (where GDPR applies)

We process personal data on the bases of your consent, our performance of a contract or steps taken at your request, our legitimate interests in running and improving the business, and compliance with legal obligations.

How we share information

We do not sell or "share" (as the CCPA defines it) your personal information, and we never pass your data to a program, developer or fund as a condition of a recommendation. We disclose information only to:

Service providers who process data on our behalf: Cloudflare (hosting, content delivery, security, cookieless analytics and Cloudflare D1 database storage for accepted form submissions), Resend (sending limited form-submission notifications to Civita), Google (Google Analytics, only with your consent) and Square (payments).
A professional you independently engage, only at your direction and after the proposed disclosure is explained.
Authorities or advisers where we are required to by law, or to establish or defend legal claims.

Data retention

The lead system deletes accepted website intake records once they are more than 180 days old when the intake or protected lead dashboard next runs. If neither runs immediately after the deadline, deletion may occur shortly after day 180 rather than at that exact moment. If an enquiry becomes a client engagement, information needed for that engagement is moved into the separately governed client file and kept only for the contract, legal, regulatory and record-keeping periods that apply to the work. Other personal information is deleted or anonymised when it is no longer needed. You may ask us to delete your information sooner, subject to any legal or contractual retention duty.

Security

We use appropriate technical and organisational measures, including encryption of data in transit, to protect your information. No method of transmission or storage is perfectly secure, and we cannot guarantee absolute security.

Your rights

If you are in the EEA or the UK, you may access your data, have it corrected or deleted, restrict or object to its processing, request portability, withdraw consent, and lodge a complaint with your local data protection authority.

If you are a California resident, the CCPA as amended by the CPRA gives you the right to know, access, delete and correct your personal information, to opt out of its sale or sharing (we do not sell or share), and to limit the use of sensitive personal information. We honor Global Privacy Control signals, we will not discriminate against you for exercising these rights, and you may use an authorized agent.

To exercise any right, use the "Your Privacy Choices" link in the footer or email us at the address below. We will verify your request and respond within the time the applicable law requires.

International transfers

We and several of our service providers are based in the United States, so your information may be processed there and elsewhere. The listed providers publish their own transfer locations and safeguards. Before any client work requires a separate international transfer arrangement, Civita will document the applicable provider and contractual mechanism rather than assume one.

Cookies and analytics

We keep cookies to a minimum and run no advertising or marketing cookies. Cloudflare's analytics are cookieless and do not track you across sites.

Google Analytics is off by default. We use it only to understand aggregate usage. Under Google Consent Mode, analytics storage is set to "denied" until you actively accept through our consent banner, so no analytics cookie is set without your permission. If your browser sends a Global Privacy Control (GPC) signal we treat it as a decline automatically. You can change your choice at any time through the "Your Privacy Choices" link in the footer.

Children

Our forms and services are for adults and must be submitted by an adult. A parent or guardian may provide limited age, relationship and country information about a dependent child when it is needed to model family eligibility and cost. Children should not submit a form themselves, and no one should submit a child's name, exact birth date or identity-document number through the site.

Changes to this policy

We may update this policy from time to time. The "last updated" date above reflects the most recent version.

Contact

The controller is Civita Global LLC, doing business as Civita. For any privacy question or to exercise your rights, email us at[email protected].