Terms of Service
These Terms of Service (the “Terms”) govern your use of the Citadel First mobile application (the “App”) operated by us (“we”, “us”, “our”). By creating an account or using the App, you agree to these Terms and to our Privacy Policy. If you do not agree, do not use the App.
1. Eligibility
You must be at least 18 years old, have full legal capacity, and not be an undischarged bankrupt. You must not use the App if doing so would break any law that applies to you, including sanctions laws.
2. Your Account
- You must give true, accurate and complete information, and keep it up to date.
- You must complete identity verification (eKYC) and any further due diligence we ask for. We may refuse, suspend or close an account at our discretion, including where we cannot verify your identity or source of funds.
- You are responsible for keeping your login details and device secure, and for all activity on your account. Tell us at once if you suspect unauthorised access.
- Each person may hold only one client account.
3. What the App Does
The App lets you register, view and purchase trust products, upload payment proof, add and manage beneficiaries, view dividends and statements, and request rollovers, reallocations and redemptions. Agents may use the App to service their clients and view commissions.
No advice. Information in the App is general and does not take your personal circumstances into account. It is not financial, legal, tax or investment advice. Seek independent advice before you invest.
Returns are not guaranteed. Any rate, dividend or projection shown is indicative unless your trust deed states otherwise. The value of a trust and its distributions may vary.
4. Trust Products and Trust Deeds
Each trust you establish is governed by its own trust deed or agreement and the product terms (together, the “Trust Documents”). If these Terms conflict with your Trust Documents, the Trust Documents prevail. Vanguard trust products are administered by Vanguard as trustee under their own Trust Documents.
A trust order is accepted only when we approve your payment and the Trust Documents are executed. The agreement date, tenure and maturity date are set as stated in your Trust Documents, or as confirmed by the trustee.
5. Payments
You pay for trust products by bank transfer to the trustee account shown in the App. The App does not process card payments or in-app purchases. You must upload proof of each payment. Payments from a third party are accepted only from your immediate family (parent, sibling, spouse or child) with a signed third-party declaration, and we may reject any payment we cannot verify.
6. Requests on Your Trust
Rollovers, reallocations, redemptions and withdrawals are subject to the eligibility rules, notice periods, minimum amounts, fees and penalties in your Trust Documents, and to our approval. Early redemption or termination may carry a penalty. A request is complete only when we confirm it is approved.
7. Agents
Your servicing agent is not authorised to give financial advice for us, receive cash or payments on our behalf, or vary these Terms or your Trust Documents. Pay only into the trustee account shown in the App. Agents who use the App must also follow their agency agreement with us, which prevails for agent matters.
8. Your Obligations
You must not:
- provide false or misleading information or documents, or use another person's identity;
- use the App for money laundering, terrorism financing, fraud or any unlawful purpose;
- upload personal data about another person without their authority;
- try to access data or accounts that are not yours, or interfere with, copy, reverse engineer or overload the App; or
- copy, photograph or distribute confidential documents shown in the App, including signed trust agreements.
9. Documents and Electronic Communications
You agree to receive documents, statements and notices electronically, in the App, by email or by push notification. Your electronic signature and acceptances in the App are binding as permitted by the Electronic Commerce Act 2006. For your protection, some documents can be viewed but not downloaded or captured in the App; you may request a copy from us.
10. Intellectual Property
The App and its content belong to us or our licensors. We grant you a personal, non-transferable, revocable licence to use the App on your own device for its intended purpose. All other rights are reserved.
11. Availability
We aim to keep the App available but do not guarantee that it will be uninterrupted or error-free. We may suspend it for maintenance, security or legal reasons, and may change or withdraw features. Your rights under your Trust Documents are not affected by the App being unavailable.
12. Liability
To the extent permitted by law, the App is provided “as is”, and we are not liable for indirect or consequential loss, or for loss caused by your failure to keep your account secure, by inaccurate information you provide, or by events beyond our reasonable control. Nothing in these Terms limits liability that cannot be limited by law, or your rights under the Consumer Protection Act 1999 where it applies. Our liability for your trust is as set out in your Trust Documents.
13. Suspension and Termination
You may stop using the App or ask to delete your account at any time (see the Privacy Policy). We may suspend or close your account if you breach these Terms, if required by law or a regulator, or to prevent fraud. Closing your account does not end any active trust, which continues under its Trust Documents.
14. Changes to These Terms
We may update these Terms. We will notify you of material changes in the App or by email before they take effect. If you keep using the App after that, you accept the updated Terms.
15. Governing Law and Disputes
These Terms are governed by the laws of Malaysia. Please raise any complaint with us first at the contact below; we will respond within 14 business days. Any dispute not resolved will be subject to the exclusive jurisdiction of the courts of Kuala Lumpur, Malaysia.