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Privacy Policy

We at Zengo Ltd. (“Zengo”, “Company”, “we”, “us”, “our”) respect your privacy. This Privacy Policy (“Policy”) explains the privacy practices for the Zengo mobile application (“App”) and Zengo websites zengo.com, help.zengo.com, (“Website(s)”). It also describes the rights and options available to you with respect to your information.

This Policy is combined into our User Agreement and Website Terms of Use (the “Terms”) and is a part of them.

PERSONAL INFORMATION WE PROCESS

Initial Account Sign-up Information.

To sign up to and create a user account on the App, we collect your email address.

Facial Image Information

If you wish to activate your App user account with the back-up feature, as further explained in our Terms, you will need to provide your biometric data of your facial image, which is a mathematical representation of your face. You do not have to provide us with your face image data. However, you will not be able to use this back-up functionality of the App without providing such information.

If you are a resident of the State of Illinois, our use of your Facial Image Information will be further subject to our BIPA Notice.

Support Information

When you contact us for technical and customer support requests, we collect the information included in your request and in follow-up interactions we have with you.

Inquiry Information

When you contact us with general inquiries through our online contact forms, chats or otherwise, we collect and process your email address and the information you include in your inquiry.

Affiliate Information

When you contact us through the app to become a Zengo affiliate, we collect your name, email address, App username your traffic sources and your affiliate payment details – e.g., beneficiary name, beneficiary full address, bank name, bank address, account Number / IBAN and swift code. You may also choose to provide us with your skype username, link to your website and any relevant information about your planned campaigns.

You do not have a legal duty to provide the above information. However, without providing the above information, you will not be able to sign up to, and use the full functionalities of the App, and we will not be able to provide you with support services, respond to your inquiry or facilitate your affiliation request,.

Survey Information.

We may from time to time invite you to participate in surveys about your experience using the App and the Websites. If you agree to participate in a survey, we will collect the information included in your answers to the survey.

Transaction Information.

When you activate your App user account, your public key and private key will automatically be created. Using Secure Multi-Party Computation (MPC), we create two parts (“Shares”) that can be used together to perform the functionality of a private key. One of the Shares will be stored on your mobile device and the second Share will be stored on our servers. We will also collect information on all transactions connected to your public key created through the App.

Device Information.

We collect information about the device, including its model, its operating system, browser you use, its version and language preferences, network information and the Internet Protocol (IP) address through which you accessed the App or the Websites.

Analytics Information.

We use third party tools to automatically record and collect analytics information about your use of the App and the Websites, including your session durations, the content you accessed on the App and Websites, your interactions and user-interface clicks, the frequency and scope of your use of the App and the Websites.

The overall personal information outlined above will be referred to as the “Information” or “Personal Information”.

HOW WE PROCESS AND USE PERSONAL INFORMATION

We will process your information to provide you with the App features and functionality

We process your email, Facial Image Information, Back-up Email Information, and Transaction Information to operate the App and provide you with its features and functionality.

We use your Information to prevent fraud

We use your Facial Image Information, Back-up Email Information, Analytics Information, Inquiry Information and Device Information to confirm your identity and prevent fraud.

We will process your information to send you administrative notifications and Promotional Communications

We process your Initial Account Sign-up Information, Transaction Information and Analytics Information, to send you administrative notifications relating to the App as well as promotional updates relating to Zengo (“Promotional Communications”). You can control your App notification settings and preferences through your mobile device setting.

Opt Out. You may also ‘opt-out’ of using your information for Promotional Communications at any time by sending an email to our support service at: [email protected].  By doing so, we will only delete your Information from our mailing list, while we will continue to process your Information submitted to us which is necessary to provide you with our services.

We will process your Information to develop and enhance our services

We process your Analytics Information to understand how users interact with the App and Websites so that we can further develop and enhance our services.

We will process your information to provide technical or customer support

We process your email, Analytics Information and Support information to provide you with technical or customer support in response to inquiries on these topics.

We will process your information to respond to and handle your inquiry

We process your Inquiry Information to contact you about your inquiry and handle your inquiry.

We will process your information to facilitate your request to become our affiliate

We process your Affiliation Information to facilitate your request to become our affiliate, so you will be able to monetize your content and enrich Zengo.

We will process your information to invite you to participate in surveys to further enhance and develop Zengo

We process your email to contact you, from time to time, and invite you to participate in surveys about your experience using the App and Websites. If you agree to participate in a survey, we use your answers to further enhance and develop the App and Websites, or as otherwise explained in each particular survey.

WHEN AND HOW YOUR PERSONAL INFORMATION IS SHARED WITH OTHERS

We will not share your Information with third parties, except in the events listed below or when you provide us your explicit and informed consent.

We will share information with our service providers that are helping us to operate the App and Websites

We will share your Information with our service providers who assist us with the internal operations of the App and Websites. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own promotional purposes. We do not sell your personal information to third parties.

We will share information with Third Party Platforms if you use their services to transfer Assets

We will share your Information If you use services provided by Third Party Platforms, such as purchasing crypto with fiat currency or locking funds into an interest-bearing smart contract, Zengo will share your digital wallet address with these Third Party Platforms in order to enable the transfer of cryptocurrencies, tokens and digital assets (“Assets”) from and to your digital wallet on the App.

We will share your Information with competent authorities, if you violated any applicable law in connection with the App and Websites

We will share your Information If you violated any applicable law, your Information will be shared with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation.

We will share your Information if we are legally required to

We will share your Information If we are required to disclose your it by a judicial, governmental or regulatory authority.

USE OF THIRD-PARTY PLATFORMS

Zengo enables you to interact with certain third party services, decentralized applications and platforms (they will all be referred to as “Third Party Platforms”), such as purchasing crypto with fiat currency, locking funds into an interest bearing smart contract, choosing to access Third Party Platforms through the App and the Platform or to grant permission to Third Party Platforms to access your App user account.

Your use of such Third Party Platforms and those Platforms’ use of your information are governed by their respective terms of use and privacy policy, not by this Policy. These platforms will go through the Know-Your-Client process with you, collect and process your information, execute their services, and send back the Assets to your digital wallet on the App. These services are fully operated by these Third Party Platforms, not Zengo. Your personal data is collected by them and you will have to agree to their terms of service. They are the controller of your personal data that they process.

These Third-Party Platforms will not share the information you provide them with Zengo.

Zengo will only share your digital wallet address with these Third Party Platforms in order to enable the transfer of Assets from and to your digital wallet on the App.

COOKIES

What are cookies?

Cookies are text files, comprised of small amounts of data, that are saved on your computer or other device (e.g., smartphone, tablet, etc.) when you use the internet and visit various websites.

The information that the cookies maintain is read by the App or Websites you visit, during the session of your visit to the App or Websites (these are called ‘session’ cookies), and when you return to visit it again (these are called ‘persistent’ cookies). We also use techniques called web beacons and web pixels for purposes similar to the use of cookies.

We use an add-on to provide you detailed information about the cookies and enable you to control the use of cookies.

We use an add-on to provide you with more detailed information about the cookies we use (including their origin, purpose, and expiration dates). It also enables you to control the use of cookies. Click here to access the Website add-on. You can change your mind at any time by enabling or disabling certain cookies or categories of cookies. However, you cannot disable the ‘necessary’ cookies because the Website cannot operate without them. By enabling cookies, you give your consent to collect the data which is collected by them.

We use cookies necessary to operate the Website, for statistics, for marketing purposes and to remember your preferences.

We use cookies for several purposes, as briefly explained below. You can review additional information about the specific cookies used in relation to each purpose, through the Website Add-on

Necessary. Cookies that are strictly necessary for the functioning of the Website. They cannot operate properly without these cookies. You can set your device or browser to block or alert you about these cookies, but some parts of the Website may not function properly.

Preferences. Cookies that remember your choices when you use the Website and allow them to react by reflecting your preferences.

Statistics. Cookies that help us to understand how you and other users interact with our Website by collecting data that does not directly identify you, including third party cookies such as Google Analytics, AppsFlyer and Amplitude, that track and monitor your use of our App and Websites.

Marketing. Cookies that track your use of the Website and allow us to tailor content, both on and off the App and Websites, that we believe is relevant to you.

You can always delete or disable cookies.

Other than using the cookie add-on, you can always delete or disable the cookies saved on your device through the settings of your computer browser or device.

SECURITY AND DATA RETENTION

We will retain your Information for as long as we need it for business purposes, and thereafter as needed for record-keeping matters.

We retain personal Information for the duration needed to support our ordinary business activities operating our services. Thereafter, we will continue to retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our Terms.

We implement measures to secure your information.

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the App and Websites will be immune from information security risks.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE UK OR THE EUROPEAN ECONOMIC AREA

Zengo Ltd. is the Data Controller.

Zengo Ltd. is the data controller of the personal data we process about you. Zengo’s address is at: Derech Menachem Begin 121-123, 30th Floor, Tel Aviv (TEL AVIV, SARONA).

Maetzler Rechtsanwalts GmbH & Co KG is the EU Representative.

Our European representative, for the purposes of this Policy, is Prighter Group. If you are within the European Economic Area, you may contact our representative by visiting https://prighter.com/q/18444125 or through the following address:

PrighterGDPR-Rep by Maetzler Rechtsanwalts GmbH & Co KG

c/o Zengo LTD

Schellinggasse 3/10, 1010 Vienna, Austria

Website: https://prighter.com

Please add the following subject to all correspondence: ID-18444125

Legal Basis for Processing Your Data.

The legal basis for processing your Information for the purpose of operating the App and Websites and providing their features is the performance of our contract with you as part of our Terms and our legitimate interests in the proper management and operation of the App and Websites.

The legal basis for processing your Facial image Information is your explicit consent.

The legal basis for processing your Information for the purpose of sending you notifications (including Promotional Communications) relating to Zengo is our legitimate interests in informing users of administrative issues and encouraging user engagement with Zengo.

The legal basis for processing your Information for the purpose of confirming your identity and preventing fraud is the performance of our contract with you as part of our Terms, our legitimate interests in keeping our services free of fraudulent conduct and our necessity for compliance with legal obligations.

The legal basis for processing Information to provide you technical or customer support is our legitimate interests in assisting our users on issues relating to their use of the App.

The legal basis for processing your Information for the purpose of responding to and handling your inquiry is our legitimate interests in responding to your inquiry.

The legal basis for processing your Information for the purpose of you becoming an affiliate with us is the performance of a contract with you. Your explicit consent and our legitimate interests in fulfilling your request.

The legal basis for processing Analytics Information to further develop and enhance the App and Websites is our legitimate interests in fostering and advancing the App and Websites.

The legal basis for collecting and processing Survey Information is your explicit consent, as well as our legitimate interest in developing and enhancing the App and Websites.

The legal basis for sharing your Information with competent authorities and with third parties for the purpose of handling violations is our legitimate interests in enforcing our legal rights.

The legal basis for disclosing your Information at the request of a judicial, governmental or regulatory authority is our compliance with legal obligations to which we are subject.

The legal basis for sharing your digital wallet address with Third Party Platforms is for the performance of your contract with these Third Party Platforms.

The legal basis for processing your Information for the purpose of notifying you or providing you with updates to this Policy is our necessity for compliance with legal obligations under the GDPR.

Cross-Border Data Transfers.

Information we collect from you will be processed by Zengo in Israel, which is recognized by the European Commission as having adequate protection for personal data.

When we transfer your Information from within Europe to other jurisdictions outside Europe, we will do so by using adequate safeguards determined by the EU Commission.

You have certain rights to access, update or delete your information, obtain a copy of your information, withdraw your consent and object or restrict certain data processing activities.

You have the following rights:

Right to Access your Personal Information that we process and receive a copy of it.

Right to Rectify inaccurate Personal Information we have concerning you and to have incomplete Personal Information completed.

Right to Data Portability, that is, to receive the Personal Information that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this Information to another service provider. Where technically feasible, you have the right that your Personal Information be transmitted directly from us to the service provider you designate.

Right to Withdraw Consent to processing your Personal Information, at any time, where the processing is based on consent. If you do that, we will still process certain information on a legal basis other than consent, as described in this Policy. Withdrawing your consent will not affect the lawfulness of the data processing we carried out based on your consent before such withdrawal.

Right to Object, based on your particular situation, to using your Personal Information on the basis of our legitimate interests. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise or defense of legal claims. You may also object at any time to the use of your Personal Information for direct marketing purposes.

Right to Restrict processing your Personal Information (except for storing it) if you contest the accuracy of your Personal Information, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the Personal Information and request instead to restrict its use; if we no longer need the Personal Information for the purposes outlined in this Policy, but you require them to establish, exercise or defend legal claims; or if you object to processing, pending the verification whether our legitimate grounds for processing overrides yours.

Right to be Forgotten. Under certain circumstances, such as when your right to object overrides our legitimate interests, you have the right to ask us to erase your Personal Information. However, we may still process your Personal Information if it is necessary to comply with a legal obligation, we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.

If you wish to exercise any of these rights, contact our representative at https://prighter.com/q/18444125.

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

If you are in the UK, you can lodge a complaint to Information Commissioner’s Office (ICO) pursuant to the instructions provided here.

MINORS

The App and Websites are not directed to users under 18.

The App and Websites are not intended for children under the age of 18. We do not knowingly or intentionally collect information about children who are under 13 years of age.

IF YOU ARE UNDER THE AGE OF 13 YOU MAY NOT USE THE APP OR WEBSITES IN ANY WAY.

CHANGES TO THIS POLICY

If we change this Policy, we will make efforts to proactively notify you of such changes.

From time to time, we may change this Policy, If we do so, we will make efforts to proactively notify you of such changes. In any event, the latest version of the Privacy Policy will always be accessible at https://zengo.com/privacy-policy/.

CONTACT US

Should you have any inquiries, complaints or suggestions, you may contact us at [email protected] or via online contact forms, chats or other forms of communications as may be available through our App and Websites. We will do our best to respond to your inquiry in a timely manner.

Last Update: May 2023.

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