Legal

Privacy Policy

Last updated: 26 July 2026

This Privacy Policy explains how CitiGrow Ltd ("CitiGrow", "we", "us", or "our") collects, uses and protects your personal data when you use the CitiGrow website and digital products.

We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable UK data protection laws.

1. WHO WE ARE

CitiGrow Ltd operates the CitiGrow website and digital products.

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

Email: hello@citigrow.ai

2. WHAT THIS POLICY COVERS

This Privacy Policy applies to the current version of the CitiGrow website, including:

  • browsing the public website and free preview content;
  • purchasing digital products such as The Shanghai Archive and Deeper Shanghai (typically through Stripe guest checkout using an email address);
  • submitting enquiries through our Contact form.

Creating a password-protected user account is not currently required to purchase our products.

If we introduce optional customer accounts or additional services in the future, we will update this Privacy Policy accordingly.

3. PERSONAL DATA WE COLLECT

Depending on how you use our website, we may collect the following information.

Contact Information

Your email address, and where applicable your name, so we can:

  • confirm purchases;
  • provide or restore access to digital products;
  • respond to enquiries;
  • send service-related communications.

Contact Form Information

When you submit our Contact form, we collect:

  • your name (if provided);
  • your email address;
  • the contents of your message.

Purchase and Access Information

We maintain limited records of digital purchases and content access in order to:

  • verify purchases;
  • provide access to purchased products;
  • prevent unauthorised sharing;
  • administer our Refund Policy.

Payment Information

Payments are securely processed by Stripe.

We receive payment confirmations and limited transaction information but do not receive or store your full payment card details.

Technical Information

We may automatically collect limited technical information, including:

  • IP address;
  • browser type;
  • device information;
  • pages visited;
  • access times;
  • security logs.

This information helps us operate, maintain and secure the website.

Cookies

We use essential cookies required for the operation and security of our website.

Where required by law, we display a cookie notice allowing you to accept optional cookies or continue using only essential cookies.

We do not currently use advertising cookies.

If we introduce analytics or marketing cookies in the future, we will update this Privacy Policy and obtain any consent required under applicable law.

4. HOW WE USE YOUR DATA

We use your personal data to:

  • process purchases;
  • provide access to digital products;
  • respond to enquiries;
  • maintain and improve the website;
  • detect fraud, abuse and unauthorised use;
  • protect our intellectual property;
  • comply with legal, tax and accounting obligations.

We do not sell your personal data.

5. LEGAL BASES FOR PROCESSING

Depending on the circumstances, we rely on one or more of the following legal bases under UK GDPR:

  • Contract – to provide products you purchase.
  • Legitimate Interests – to operate, secure and improve our services while respecting your rights.
  • Legal Obligation – where we are required to retain records by law.
  • Consent – where we ask for it, for example in relation to optional cookies or marketing communications.

6. SHARING YOUR DATA

We share personal data only where necessary to operate our services.

This may include trusted service providers such as:

  • Stripe (payment processing);
  • website hosting providers;
  • email service providers;
  • technical service providers supporting website operation.

These providers process data on our behalf under appropriate contractual protections.

We may also disclose information where required by law or where necessary to establish, exercise or defend legal claims.

7. HOW LONG WE KEEP YOUR DATA

We retain personal data only for as long as reasonably necessary.

Purchase records and access records may be retained while access remains available and for any period required to:

  • administer purchases;
  • provide customer support;
  • process refunds;
  • comply with legal, tax or accounting obligations.

Contact form enquiries are retained only as long as reasonably necessary to respond to your enquiry and any related follow-up, after which they may be deleted or anonymised.

8. YOUR RIGHTS

Under UK GDPR you may have the right to:

  • request access to your personal data;
  • request correction of inaccurate information;
  • request deletion of your data in certain circumstances;
  • request restriction of processing;
  • object to certain processing;
  • request data portability where applicable;
  • withdraw consent where processing is based on consent.

To exercise your rights, please contact:

hello@citigrow.ai

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO).

9. INTERNATIONAL DATA TRANSFERS

Some of our service providers may process personal data outside the United Kingdom.

Where this occurs, we use appropriate safeguards recognised under UK data protection law, including where appropriate the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or other lawful transfer mechanisms.

10. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time as our services evolve.

The latest version will always be available on this page.

The "Last updated" date at the top of this Privacy Policy indicates when it was most recently revised.