Privacy Policy
1. Data Controller
CAVEL INVESTMENT LLC (hereinafter "Citu", "we", or "the Controller") is the entity responsible for the processing of personal data collected through the Citu service and the website citu.ai.
Legal name: CAVEL INVESTMENT LLC
Registered address: 1395 Brickell Avenue, Suite 800, Miami, FL 33131, USA
Contact: info@citu.ai · +1 754 273 6099
2. Scope
This policy applies to personal data we collect when you interact with Citu, our educational conversational assistant on WhatsApp, focused on financial literacy and investing concepts, and when you visit the citu.ai website.
3. Personal data we collect
When you interact with Citu on WhatsApp, we collect:
- Your WhatsApp-associated phone number
- Your public WhatsApp profile name
- The content of the messages you send us and our replies
- Technical metadata: timestamps, internal conversation identifiers, detected language
The citu.ai website is informational and does not use tracking, analytics, or advertising cookies. We do not collect browsing data on the site.
4. Purposes of processing
- Provide the Citu conversational service (receive your message, generate a reply, maintain conversation context)
- Internally improve service quality through aggregated and anonymized analysis
- Comply with legal obligations and respond to requests from competent authorities
- Handle data subject requests (access, rectification, deletion, objection)
We do not use your messages to train third-party AI models, and we do not sell them to advertisers.
5. Legal basis
- Consent: by starting a conversation with Citu on WhatsApp you accept the processing described in this policy. You may withdraw consent at any time by requesting deletion of your data.
- Service performance: to deliver the service you request through WhatsApp.
- Legal obligation: when applicable law requires us to retain or disclose information.
6. Sharing with third parties
To operate the service we share strictly necessary data with technology providers acting as data processors, including:
- Instant messaging providers (required to route your WhatsApp messages)
- Cloud infrastructure providers (storage and compute)
- Artificial intelligence model providers (response generation)
All providers are bound by contractual confidentiality and security obligations and process the data exclusively under our instructions.
We do not sell, rent, or trade personal data with third parties for commercial purposes.
7. International transfers
Some of our technology providers operate outside your country of residence, including the United States of America. Such transfers are carried out with appropriate contractual and technical safeguards to protect your data.
8. Retention
We retain personal data for as long as needed to provide the service and, thereafter, for a reasonable period not exceeding twelve (12) months from your last interaction, unless a legal obligation requires a different term. Upon a deletion request, we proceed as described in section 10.
9. Data subject rights
You have the right to:
- Access your personal data
- Request correction of inaccurate data
- Request deletion of your data
- Object to or restrict the processing
- Withdraw your consent
- Request portability of your data
- Lodge a complaint with the competent data protection authority in your jurisdiction
To exercise any of these rights, contact info@citu.ai from an address that lets us identify you or including the associated WhatsApp number.
10. Data deletion
You may request deletion of your personal data at any time. The full instructions are published on a dedicated page:
In short: send an email to info@citu.ai with the subject Data deletion and include the WhatsApp number you used. We will confirm the deletion within 30 days of receiving your request, unless a legal obligation requires us to retain part of the information — in which case we will explicitly inform you.
11. Security
We apply reasonable technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. No system is completely infallible; please report any incident you suspect to info@citu.ai.
12. Minors
The service is not directed to individuals under 18. We do not knowingly collect data from minors. If you believe a minor has provided us with personal data, contact us so we can delete it.
13. Changes to this policy
We may update this policy. The current version is always available at https://citu.ai/privacy with the last-updated date at the top. Material changes will be communicated through reasonable channels.
14. Contact
Questions, requests, or complaints related to this policy: info@citu.ai