Data Protection Policy
General
This Data Protection Policy (DPP), together with our Terms of Use, governs ZoidPay’s collection, processing, and use of your Personal Data. As used in this Data Protection Policy, “ZoidPay” refers to the company ZCN ZOID LTD, including, without limitation, its owners, directors, investors, employees, or other related parties. Depending upon the context, “ZoidPay” may also refer to the services, products, website, content, or other materials (collectively, “ZoidPay Services,” “Service,” and/or “ZoidPay ecosystem”) provided by ZCN ZOID LTD.
We did our best to make our Data Protection Policy short, easy to access, easy to understand, and in clear and plain language.
We developed this policy having in mind your rights and our obligations under the GDPR and other privacy regulations.
We want you to read our entire Data Protection Policy and all the other documents that govern the relationship between us and you, and we want you to do it before creating an account, in order to have a good understanding of what, how, and more importantly why we are doing things as we do.
We acknowledge that you trust us with your Personal Data and that is a huge responsibility for us. We promise you that we do our best to keep your and our data safe, to process your and our data only for the purpose(s) for which it has been provided, and never abuse your data and your trust.
Summary
This summary presents important elements of the Data Protection Policy (DPP), but it does not replace the DPP and you have to read it and accepted:
OK! We process Personal Data to provide our service.
OK! We do our best to process only adequate and relevant data and to keep them securely.
OK! We are processing data lawfully, fairly, and in a transparent manner for specified, explicit, and legitimate purposes.
OK! We apply the highest standard of data protection to all our users regardless of their jurisdiction.
X! We DO NOT SELL your Personal Data!
X! We DO NOT PROFILE USERS!
X! We DO NOT MAKE AUTOMATED DECISIONS about you!
In short, you have the right to access, rectify, and/or erasure your data. In addition, you have the right to obtain a restriction of the processing. You can exercise your rights by contacting
Identity and Contact Details of the Data Controller
ZCN ZOID LTD (hereinafter referred to as “Company” “us”), a Cypriot legal entity, with its registered office, located Zinonos Sozou 11, 3rd Floor, Flat/Office 303, 1075, Nicosia, Cyprus, registered under no. 3839500, and VAT code CY10383950S
Definitions
A few definitions of the terms used in this Data Protection Policy.
Personal Data or Personal Information means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing means any operation or set of operations that are performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Restriction of processing means the marking of stored personal data to limit their processing in the future;
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;
Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
Processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller;
Recipient means a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with applicable laws shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing;
Third-party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
Consent of The Data Subject means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to them;
Personal Data Breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed;
Your Rights!
Your rights are important to us, and we want to inform you about your rights before anything else.
OK! You have the right to know if we are processing your personal data.
OK! You have the right to know what personal data we are processing and the purposes of the processing.
OK! You have the right to request from us access to your personal data.
OK! You have the right to obtain from us the rectification of inaccurate personal data.
OK! You have the right to obtain from us the erasure of your personal data.
OK! You have the right to obtain from us restrictions on the processing of your personal data.
OK! You have the right to object at any time to the processing of your personal data.
OK! You have the right not to be subject to a decision based solely on automated processing, including profiling.
OK! You have the right to receive your personal data and to transmit that data to another controller (data portability right).
OK! You have the right to be informed through email about a data breach 72 hours after the Company has become aware of it.
ZoidPay will respond to your request only where this is not inconsistent with our Terms of Use and other legal and regulatory obligations. Within 30 days of receipt of your written request, we will provide you with your Personal Data, including the purposes for which it was used and to whom it was disclosed in accordance with your Subject Access Request rights under the applicable regulation.
Any requests regarding your rights should be made in writing to our Data Protection Officer (DPO) - email: dpo@zoidpay.com
Access to Your Personal Information
You may access the Personal Information collected by ZoidPay by contacting us at support@zoidpay.com.
We will give you access to your Personal Information in the manner requested if that is possible and within a reasonable period. If we refuse your request or cannot give you access in the manner you have requested, we will do what we can to meet your requirements by other means. We may not be required to give you access to your Personal Information in certain circumstances which are set out in the APPs including where it may have an unreasonable impact on other individuals' privacy. If we refuse access for such reasons, we will advise you in writing of the refusal and our reasons and the complaint mechanisms available to you.
What We Do!
We have created ZoidPay to help people easily purchase goods and services with their crypto. In order to achieve our goals and to provide you with better services, we are relying on the data that you share with us. For example, you share with us personal data when you are creating your account, but also, when you just use the platform even though you do not post (e.g. the type of device you are using, the IP address of your device, etc). Learn more about data collected in the section Collection and Use of Personal Data of this Data Protection Policy.
What We Don’t Do
X! We DO NOT SELL your personal data!
X! We DO NOT collect any “Special categories” of personal data (sensitive personal data) related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or data concerning a natural person's sex life or sexual orientation.
X! We DO NOT provide services to children, therefore ZoidPay does NOT process the personal data of children.
Collection and Use of Personal Data
- Personal Data We Collect
You may choose to deal with us on an anonymous basis or to use a pseudonym unless it is not practicable for us to deal with individuals who we cannot identify or we are required by law to only deal with identified individuals. Also, if you do not provide ZoidPay with the Personal Information we request, we may be unable to process your request to become a User, provide you with our services or respond to your inquiry or complaint.
We collect the Personal Data you provide directly to us when you open a ZoidPay Account, perform any transactions on the ZoidPay Wallet, or use the ZoidPay ecosystem.
This may include:
Contact information, such as name, home address, email address, and phone number;
Account information;
Identity verification information, such as images of your government-issued ID, passport, national ID card, or driving license
Financial information;
We also automatically collect certain computer, device, and browsing information when you access the ZoidPay website, account, and/or other components of the ZoidPay ecosystem. This information is aggregated to provide statistical data about our users' browsing actions and patterns, and does not personally identify individuals. This information may include:
Computer or mobile device information, including IP address, operating system, browser type.
Website usage information.
- Use of Cookies and Similar Technology
The ZoidPay website is using cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Cookies are typically stored on your computer's hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends, and administer the ZoidPay ecosystem. The information collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge, we can improve the quality of your experience in the ZoidPay ecosystem by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Site.
We use a third-party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction information. Our service provider(s) analyzes this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors' interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the ZoidPay ecosystem. Our service provider(s) is/are contractually restricted from using information they receive from our Site other than to assist us.
- How we use your Personal Data
Your information will be used for the following purposes:
Creating and managing your account;
Complying with applicable regulations;
Process your ZoidPay transactions;
We will process your Personal Data only for the purpose(s) for which it has been provided to us;
Providing operational information;
Personalize your ZoidPay experience;
Analyze ZoidPay website usage, and improve our website and website offerings.
Help us respond to your customer service requests and support needs.
Verify your identity in accordance with the Money Laundering applicable Regulations
Preventing and detecting crime
Carrying out research and statistical analysis
The data will not be used to make automated decisions.
Contact me about ZoidPay services. The information you provide may be used to communicate information and updates related to your use of the ZoidPay services. We may also occasionally communicate company news, updates, promotions, and related information relating to similar products and services provided by ZoidPay.
Promoting our services. Administer a contest, promotion, survey, or other site features as will be more explained on the website.
We do not perform behavioral tracking of a customer's activities on our Website or across different Websites, nor do we allow third-party data collection through our Service.
What Is Our Legal Basis for Processing Your Personal Data?
We are processing your personal data because is necessary for:
Compliance with legal obligations such as fiscal laws, regulations concerning anti-money laundering and counter-terrorism financing;
The performance of the contract with you;
In addition to the above cases, we are processing your personal data when you consented, in an unequivocally way. For example, we need your free and express consent for promoting our services.
If you give your consent, you have the right to withdraw your consent at any time.
If you do not give us your consent on a specific case, we will not use your personal data for that specific case.
If you withdraw your consent or if you do not consent that will not affect your access to our services.
However, we do not need your consent when processing your personal data is necessary for compliance with a legal obligation and for the performance of the contract with you.
Disclosing and Transferring Personal Data
We may disclose your Personal Data to third parties and legal and regulatory authorities, and transfer your Personal Data outside your jurisdiction, as described below.
- Disclosures to Third Parties
In processing your transactions, we may share some of your Personal Data with third-party service providers who help with our business operations.
Your information will not be sold or exchanged.
Your information will not be shared with any third parties without your consent, except to provide ZoidPay Services or as required by law. By using our Services and accepting our Terms of Service, you consent to the disclosure of your Personal Data as described in this Data Protection Policy.
Non-personally identifiable visitor information may or may not be provided to third parties for marketing, advertising, or other uses.
ZoidPay’s third-party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms no less protective than those described in this Data Protection Policy, or those we are subject to under applicable data protection laws.
- Disclosures to Legal Authorities
We may share your Personal Data with law enforcement, data protection authorities, government officials, and other authorities when:
Compelled by subpoena, court order, or other legal procedure.
We believe that disclosure is necessary to prevent physical harm or financial loss.
Disclosure is necessary to report suspected illegal activity.
Disclosure is necessary to investigate violations of this Data Protection Policy or our Terms of Service.
However, if we have to reveal your personal data, we will inform you when the personal data is first disclosed to the recipient.
External Websites
Occasionally, the ZoidPay website may provide references or links to other websites ("External Websites"). We do not control these External Websites’ third-party sites or any of the content contained therein. You agree that we are in no way responsible or liable for External Websites referenced or linked from the ZoidPay website, including, but not limited to, website content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to, or arising from those sites.
External Websites have separate and independent privacy policies. We encourage you to review the policies, rules, terms, and regulations of each site that you visit. We seek to protect the integrity of our site and welcome any feedback about External Website information provided on the ZoidPay website.
Security of Personal Data
You acknowledge that no data transmission over the Internet is totally secure. Accordingly, ZoidPay does not warrant the security of any information which you transmit to it. Any information which you transmit to ZoidPay is transmitted at your own risk. However, once ZoidPay receives your transmission, ZoidPay will take reasonable steps to protect your Personal Information from misuse, loss, and unauthorized access, modification, and disclosure
We use a variety of security measures to ensure the confidentiality of your Personal Data, and to protect your Personal Data from loss, theft, unauthorized access, misuse, alteration, or destruction. These security measures include, but are not limited to:
Randomly created passwords protect accounts, directories, and databases.
Encrypted and processed on secure infrastructure Secure Sockets Layer (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely.
PCI Scanning to actively protect our servers from hackers and other vulnerabilities.
A very limited number of trained personnel have access to sensitive data
Personal data that you provide during payments and transactions are governed by the payment processor’s privacy/data policy, and not by this Data Protection Policy.
Zoidpay’s employees, agents, and contractors are required to maintain the confidentiality of Your Personal Information.
Retention of Personal Data
We retain Personal Data for as long as necessary to fulfill purposes described in this Data Protection Policy, subject to our own legal and regulatory obligations. In accordance with our record-keeping obligations, we will retain Account and other Personal Data for at least five years after an Account is closed.
Updates to this Data Protection Policy
The information posted on bulletin boards or communicated within a social media environment (for example, Facebook, Twitter, Chat Rooms) becomes public information. ZoidPay cannot guarantee the security of this type of disclosed information.
We take seriously the responsibility to exclude children from access to our services. We will not accept their information for the purposes of accessing or using the Service. It is, however, ultimately the responsibility of parents or guardians to monitor their children’s Internet activities including where appropriate by using Internet screening software.
Remember to always log out of your account when you have completed your time on the website. This is particularly important if you share a computer with another person. You are responsible for the security of and access to your own computer, mobile device, or any other handset used to access the website.
Ultimately, you are solely responsible for maintaining the secrecy of your username, password, and any account information. Please be careful whenever using the Internet and our website.
Office of the Commissioner for Personal Data Protection
Address
1 Iasonos St., 1082 Nicosia,
P.O. Box 23378, CY-1682 Nicosia, Cyprus
Tel: +357 22818456.
http://www.dataprotection.gov.cy//
We would be glad to help
If you still have questions or comments about our Data Protection Policy, please, send us a message at dpo@zoidpay.com and we would be glad to help.