Effective 2026/10/27
This notice explains how The Network State Company AG, a Swiss company registered in the Commercial Register of the Canton of Zug under number CHE-385.997.597, with its registered office at Bahnhofstrasse 20, 6300 Zug, Switzerland, trading as CitizenX (“CitizenX”, “we”, “us”), collects, uses, shares and protects personal data. We are the controller of that data.
It applies to the websites and online channels we operate, including citizenx.com, ntltrust.com and planbpassport.com, our client platform and mobile experiences, our newsletters and social-media accounts, and the communications we have with you by email, telephone, video call and messaging applications. It also applies to the personal data we process when you enquire about or engage us for residence, citizenship and related mobility and concierge services (the “Services”).
We are subject to the Swiss Federal Act on Data Protection (“FADP”). Where we offer Services to individuals in the European Economic Area or the United Kingdom, the EU General Data Protection Regulation (“GDPR”) and the UK GDPR also apply.
Applying for residence or citizenship means we must collect detailed personal information about you and your family, including sensitive information such as police certificates and medical reports, and pass it to the governments, licensed agents and due diligence firms involved in the programme you choose. Section 3 to 6 explain what, why and to whom.
Your data is processed in Switzerland and, through our service providers and the programmes you apply to, in other countries. Section 7 explains the safeguards.
We keep application and compliance records for the periods required by law, typically ten years. Section 8 has the detail.
You can access, correct and in many cases delete your data, object to marketing at any time, and complain to a data protection authority. Section 12 explains how.
Questions: [email protected].
Identity and contact data: name, date and place of birth, nationality and citizenships held, gender, postal and email addresses, telephone numbers, messaging-app identifiers, and copies of passports, identity cards and other identity documents.
Application and eligibility data: the information and documents required by the residence or citizenship programme you are interested in or apply to, which may include birth, marriage and divorce certificates, educational and professional history, employment details, business ownership, residence history, immigration history, military service, and the equivalent information about family members included in your application.
Financial and source-of-funds data: bank statements and references, tax identification numbers and tax returns, evidence of income, wealth and the origin of funds, investment details, and payment information (card details are handled by our payment processors and not stored by us).
Sensitive data: police clearance and criminal-record certificates and data on administrative or criminal proceedings; medical certificates and health information required by a programme; biometric data such as fingerprints and facial images captured for a programme; and information from which religion, ethnic origin or political opinions may be inferred where it appears in application documents or is required by a programme (for example, data on political exposure). See Section 4.
Data about your family and other people: the data listed above about your spouse or partner, children, parents and other dependants you include in an application, and the contact details of referees, employers, accountants, lawyers and other persons you ask us to deal with. You are responsible for informing those people that you have shared their data with us and for having the authority to do so.
Communications and account data: the content of your enquiries, emails, calls, messages and meetings with us, call and meeting notes, and recordings or transcripts where we tell you that a call or meeting is being recorded, your login credentials and settings on our client platform, and your preferences, including for marketing.
Introducers and referral partners: if you were introduced to us by a referral partner, agent, adviser or strategic advisor, we receive your name, contact details and the services you are interested in from that person.
Businesses we acquire: when we acquire a business or its client lists, we receive the personal data held by that business. We acquired the NTL Trust brand, website and contact databases from NTL Caribbean Agent Services Limited; if you were a contact of NTL Trust, your name, contact details, enquiry history and marketing preferences were transferred to us on that basis and we use them as described in this notice. Ongoing client matters of NTL Trust were not transferred and continue to be handled by NTL. We also acquired the Plan B Passport website (planbpassport.com) and its contact databases; if you were a contact of Plan B Passport, your data was transferred to us on the same basis.
Due diligence, screening and public sources: sanctions, politically-exposed-person and adverse-media screening providers; our identity-verification tools, which run on our own infrastructure; commercial and public registers; court and press records; and information provided by the banks, employers and referees you nominate.
Governments, citizenship units and agents: during an application, the authorities and licensed agents involved send us information about the status of your application, requests for further information, and their decisions.
Your professional advisers and other persons acting for you.
Residence and citizenship programmes require applicants to provide police certificates, medical reports, biometric data and detailed personal history, and to undergo due diligence. We process this sensitive data only because, and to the extent that, the programme you choose requires it, to assess your eligibility, prepare and submit your application and respond to the authorities. We rely on your explicit consent, which we ask for when you engage us, and on the necessity of the processing for the contract you have asked us to perform; where we disclose sensitive data to third parties, we do so with your express consent as required by Swiss law or because the disclosure is necessary to perform the Services. You may withdraw your consent at any time by contacting us; if you do, we will usually be unable to continue with your application.
Applications frequently include children and other dependants. We process the personal data of dependants, including minors, when it is provided by the principal applicant or another adult with authority over the child, who confirms that authority to us. We do not knowingly market our Services to anyone under 18, and our websites are not directed at children.
Swiss law allows us to process personal data in accordance with the principles of the FADP, without requiring a specific legal basis for each purpose, save where we process sensitive data or disclose it to third parties, or where we rely on consent. Under the GDPR and UK GDPR we must have a legal basis for each purpose. The table sets out both. “Legitimate interests” means our interests, or those of a third party, which we have assessed are not overridden by your rights; you may object to processing on this basis (Section 12).
| Purpose | Data used | Legal basis for use | | --- | --- | --- | | Responding to your enquiry and assessing whether and how we can help | Identity, contact, communications, eligibility information you give us | Steps at your request before a contract (Art. 6(1)(b)); legitimate interest in responding to enquiries | | Providing the Services: eligibility assessment, preparing and submitting applications, concierge services, managing your file | All categories in Section 3, including sensitive data | Performance of our contract with you (Art. 6(1)(b)); explicit consent for sensitive and criminal-record data (Art. 9(2)(a), Art. 10); FADP Art. 6(7)(a) express consent for disclosure of sensitive data | | Know-your-client, anti-money-laundering, sanctions and fraud checks, and programme compliance | Identity, financial, source-of-funds, screening results, sensitive data where it appears | Legal obligation where applicable (Art. 6(1)(c)); otherwise legitimate interest in preventing financial crime and meeting programme rules; substantial public interest (Art. 9(2)(g)) where national law provides | | Billing, payment collection, accounting and tax | Identity, contact, payment and transaction data | Contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) | | Paying and reporting to introducers and referral partners | Name or file reference, service type, fees received | Legitimate interest in performing our partner agreements; data shared is minimised (Section 6) | | Operating, securing and improving our websites and platform | Usage data, device data, account data | Legitimate interest in running secure, reliable services; consent for non-essential cookies (Section 9) | | Marketing: newsletters, product news, event invitations, and reminders about services you have asked about | Contact data, preferences, enquiry history, usage data | Consent, or legitimate interest in marketing similar services to existing clients and enquirers where law allows; you can opt out at any time | | Online advertising and measurement, including remarketing | Cookie and pixel identifiers, usage data | Consent (cookie banner); see Section 9 | | Establishing, exercising or defending legal claims; responding to authorities | Any relevant data | Legitimate interest; legal obligation; Art. 9(2)(f) for sensitive data | | Corporate transactions (financing, merger, acquisition or sale of a business or assets) | Any relevant data, usually in aggregated or anonymised form until a transaction completes | Legitimate interest in running and developing our business |
We share personal data only as described here. We never sell personal data.
Governments and programme authorities. To make an application we send your file, including sensitive data, to the government ministry, citizenship or residence unit, immigration authority or other body that administers the programme in the relevant country, and to any approved fund, developer or real-estate project in which you invest where the programme requires it. Those bodies process your data under their own laws, may share it with other agencies, and may keep it indefinitely; we have no control over that processing.
Licensed and local agents. Many programmes require applications to be submitted through an agent licensed in that country. Where that applies we work with licensed agents and sub-agents, who receive the file for submission and liaise with the authority.
Due diligence firms. Programmes appoint independent due diligence firms to verify applicants. They receive your file from the authority or from us and may contact your employers, banks, referees and others directly. We also use screening providers for our own checks.
Professional advisers and service providers for your application: lawyers and notaries, translators, apostille and legalisation services, medical examiners, property valuers, couriers, and banks that open accounts or receive investment funds.
Our service providers (processors) who act on our instructions under contract: cloud hosting, file storage and web infrastructure (Exoscale, Switzerland; Hetzner, Germany; Cloudflare for security and traffic distribution); contact management and delivery of transactional and marketing email (Loops); meeting scheduling (Cal.com) and meeting notes and transcription (Granola); electronic signature (Documenso); screening and due-diligence checks (Exiger); artificial-intelligence services used to extract information from documents, translate and summarise (accessed through OpenRouter, using models configured so that your data is neither retained nor used for training); error and performance monitoring (Sentry); analytics (Matomo Cloud and Plausible); internal collaboration tools (Slack); payment processing; and professional advisers (auditors, accountants, lawyers). Our client platform, CRM and identity-verification systems run on our own infrastructure, so no third-party provider receives your data through them. A current list of our processors and their locations is at citizenx.com/subprocessors.
Introducers and referral partners. If you were introduced to us by a partner or advisor, we may confirm to them that you have engaged us and report the fees received, so that we can pay the agreed referral share. We do not share your application documents with them unless you ask us to, and they are bound by confidentiality.
Advertising and social-media platforms, subject to your cookie choices (Section 9).
Authorities, courts and regulators where the law requires or permits it, including to comply with anti-money-laundering and sanctions obligations, respond to lawful requests, or protect our rights, our clients or others.
Group companies and successors. With companies under common control with us for the purposes in this notice, and with a buyer or successor in the event of a merger, acquisition, financing, reorganisation or sale of all or part of our business or assets, who will be bound by this notice in respect of your data.
We are based in Switzerland. Your data is transferred outside Switzerland, the EEA and the UK in three situations:
To the country of the programme you apply to. Submitting an application necessarily means sending your data to that country’s authorities and agents — for example Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, Saint Lucia, Vanuatu, São Tomé and Príncipe, Nauru, El Salvador, Argentina, Malta, Portugal, Greece, Türkiye, the United Arab Emirates and other programme countries we support. Many of these countries are not recognised as providing an adequate level of data protection. These transfers are necessary for the performance of the contract you have asked us to perform (Art. 17(1)(b) FADP; Art. 49(1)(b) GDPR), and we tell you the country before you apply.
To our service providers, mainly in Switzerland, Germany and the United States (Cloudflare, Loops, Slack, Cal.com, Granola, Exiger, OpenRouter and Sentry process data in the United States). For US providers certified under the Swiss-US and EU-US Data Privacy Frameworks (which Switzerland and the EU recognise as providing adequate protection) we rely on that certification; the certified providers we use are listed at citizenx.com/subprocessors. For other providers outside Switzerland, the EEA, the UK and countries recognised as adequate, we use the European Commission’s Standard Contractual Clauses with the Swiss and UK addenda, together with an assessment of the laws of the destination country and additional measures where needed.
To banks, professional advisers and other recipients in other countries where that is necessary for your application or at your request.
You can ask us for a copy of the safeguards we use, or for the list of countries to which your data has been sent, by contacting [email protected].
We keep personal data for as long as needed for the purposes in this notice and then for the periods required by law or needed to deal with claims.
Data submitted to a government or programme authority is retained by that authority under its own rules, and we cannot delete it on your behalf. Where we no longer need data, we delete or anonymise it securely.
Our websites and platform use the following cookies and similar technologies:
Strictly necessary: session and registration cookies that let you log in and complete registration and onboarding; preference cookies that remember your language and the file you are working on; and local storage in your browser that saves drafts so you can continue later. These do not require consent.
Referral attribution: a cookie that records the partner or advisor whose link brought you to us, so that we can attribute your engagement and pay the agreed referral share. In the EEA and the UK we ask for your consent before setting it; if you decline, you can still tell us who introduced you.
Analytics: Matomo, which analyses navigation, conversions and use of the platform using pseudonymised identifiers, and Plausible, which measures website traffic without cookies or personal identifiers.
Advertising measurement: Google Ads, LinkedIn and X tags, used only before you register and to measure registration conversions. They do not receive your email address, telephone number, programme or amounts, and no data is sent to them after you register.
When you first visit from the EEA, the UK or another jurisdiction that requires consent, a banner asks you to accept or decline the referral, analytics and advertising categories; you can change your choice at any time via [“Cookie settings”] in the footer. Visitors from Switzerland and other jurisdictions may opt out in the same way. Where the law of your location requires us to treat a browser signal such as Global Privacy Control as an opt-out, we do so. The Cookie Policy at citizenx.com/cookies lists each cookie, its provider, purpose and duration, and the opt-out tools of the providers we use.
We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. Our eligibility assessments and screening use software tools to assist our team, but a person reviews the result before any decision that affects you. We also use artificial-intelligence tools to extract information from documents you provide, to translate and to summarise; their output is checked by our team, and the providers are configured not to retain your data or use it to train their models. We use your enquiry history and website usage to tailor the information and offers we show you, which is profiling for marketing purposes.
We protect personal data with technical and organisational measures appropriate to its sensitivity, including encryption of data in transit and at rest, access controls and multi-factor authentication, logging and monitoring, hosting of our client platform, CRM and identity-verification systems on our own infrastructure in Switzerland and Germany, secure document-transfer tools rather than ordinary email for sensitive documents where available, due diligence on our service providers and written data-processing agreements with them, and confidentiality obligations and training for our team. No system is completely secure; if a breach of security affecting your data occurs, we will notify the Federal Data Protection and Information Commissioner and any other competent authority, and you, where the law requires it.
Subject to the conditions set out in the FADP, the GDPR and the UK GDPR, you have the right to:
obtain confirmation of whether we process your data and a copy of it, together with the information in this notice (access);
have inaccurate data corrected and incomplete data completed (rectification);
have your data deleted where we no longer need it, where you withdraw consent or object and we have no overriding grounds, or where it has been processed unlawfully (erasure);
restrict our processing in certain circumstances, and object to processing based on legitimate interests and, at any time, to direct marketing and related profiling;
receive the data you provided to us in a structured, commonly used, machine-readable format and have it transmitted to another controller where technically feasible (portability);
withdraw consent at any time, without affecting processing carried out before withdrawal; and
not be subject to a decision based solely on automated processing which produces legal or similarly significant effects, and to obtain human review.
To exercise a right, write to [email protected] or to our postal address, or to our EU or UK representative. We may ask you to verify your identity. We respond within 30 days under Swiss law and within one month under the GDPR, which may be extended by up to two further months for complex or numerous requests, in which case we will tell you. Requests are free of charge unless they are manifestly unfounded or excessive. Some rights are limited: for example, we cannot delete records we are legally required to keep, data already submitted to a government is retained by that government under its own rules, and deleting application data during an engagement will usually mean we cannot continue the Services.
You also have the right to lodge a complaint with a supervisory authority: in Switzerland, the Federal Data Protection and Information Commissioner (edoeb.admin.ch); in the EEA, the data protection authority of your country of residence or workplace; in the UK, the Information Commissioner’s Office (ico.org.uk). We would welcome the chance to address your concern first.
We send newsletters and information about our Services by email and, where you have agreed, by messaging applications. Every message contains an unsubscribe link, and you may also opt out by writing to us; we will act on your request promptly and keep your details on a suppression list so that we do not contact you again. If your details came to us from a business we acquired, our first message to you will tell you so and give you the same choice. We do not share your contact details with third parties for their own marketing.
Our websites and communications may contain links to websites and services operated by others, including programme authorities, banks and partners. Their privacy practices are their own, and this notice does not apply to them.
We may update this notice from time to time. We will publish the new version on our websites with its effective date.
The Network State Company AG (CitizenX), Bahnhofstrasse 20, 6300 Zug, Switzerland
Privacy enquiries: [email protected]