Last modified 10. July, 2018
CoinZero XXI Ltd and its affiliates (hereinafter, “CoinZero”, or “we”, “us” or “our”) are committed to protecting and respecting your privacy. This privacy notice describes how we handle your personal information when you download, install, register with, access or use the CoinZero mobile app or any of our associated websites or APIs (together, the “CoinZero App”), and informs you about your privacy rights and how the law protects you.
- Who we are.
- The nature of the personal information we may collect about you.
- How we collect your personal information.
- How we use your personal information.
- How we may share your personal information.
- How we secure your personal information.
- How long we keep your personal information.
- Your legal rights.
CoinZero App is not intended for children and we do not knowingly collect information relating to children.
We may modify this policy from time to time. When required by law, we will notify you of the modifications. If we make any material changes, we will notify you by email (we will use the email address you provide when you register for your CoinZero Account) or by other appropriate means before the changes become effective.
It is important that the personal information we hold about you is accurate, current, and complete. Please keep us informed if your personal information changes during your relationship with us.
Who we are
CoinZero XXI Ltd (“CoinZero,” “we,” “our,” “us”), is a private company incorporated in England and Wales, with company number 11006592 and registered office at 201 Haverstock Hill, C/O Fkgb Second Floor, London, NW3 4QG, UK.
CoinZero is the data controller for the conversion services enabling you to buy and sell digital assets, also known as cryptocurrencies (“CoinZero Services”). CoinZero Services are not regulated by the FCA. CoinZero is not a regulated financial services provider. CoinZero is based in, and provides services from, the UK.
Personal Information that we collect
We may ask you to provide personal information when you create an account with CoinZero, use CoinZero Services, or anytime you are in contact with CoinZero. Personal data or personal information means any information about an individual from which that person can be identified. Personal information does not include anonymized data where the identity has been removed.
When we require certain personal information from users, it is because such information is relevant for specified purposes, such as fulfilling your requests and providing CoinZero Services. Any information that you provide to us that is not required is voluntary.
We may collect, use, store, and transfer different kinds of personal information about you which we have grouped together as follows:
- Identity information, which includes: first name, maiden name, last name, username or similar identifier, marital status, date of birth, and gender.
- Contact information, which includes: billing address, email address, and telephone numbers.
- Financial information, which includes: bank account and payment card details.
- Transaction information, which includes: details about your purchases and sales of digital assets.
- Technical information, which includes: IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and any other technology on the devices you use to access CoinZero App.
- Profile information, which includes your CoinZero username and password and any other information contained in your profile.
- Usage information, which includes information about how you use CoinZero App.
- Marketing and communication information, which includes: your preferences in receiving marketing from us and our partners and your communication preferences.
For example, we collect personal information when you use or request information about CoinZero Services, subscribe to marketing communications, request support, complete surveys, or sign up for a CoinZero event or webinar. We may also collect personal information from you offline, such as when you contact customer support.
We also collect, use, and share Aggregated Data, such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information because it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Information to calculate the percentage of users accessing a specific feature of CoinZero App.
We do not collect special categories of personal information about you, such as your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic, or biometric data, or your criminal convictions and offenses.
How We Collect Personal Information
We may use different methods to collect information from you and about you, including:
- Direct interactions. You may give us your identity, contact, and financial information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:
- Apply for or create a CoinZero Account.
- Use CoinZero Services.
- Interact with our customer support.
- Give us feedback.
- Automated technologies or interactions. As you interact with CoinZero App, we may automatically collect Technical Data about your equipment, browsing actions, and patterns.
- Public databases, credit bureaus, and ID verification partners. We obtain information about you from public databases and ID verification partners to verify your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. The information includes your name, address, job title, public employment profile, credit history, status on any list of sanctioned persons maintained by public authorities, and other relevant data. We obtain this information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you based on public interest grounds to ensure CoinZero Services are not used fraudulently or for other illicit activities.
- Resellers, channel partners, joint marketing partners, and social media platforms. We collect information from your publicly available social media profile, including interests or preferences, and page-view information. There are multiple purposes for collecting this information. First, we process such information to better understand you and/or maintain and improve the accuracy of the records we hold about you as well as to position, promote or optimise our Services. We may also use this information in conjunction with your browsing habits and preferences (obtained from our data partners) and your contact details, professional information and CoinZero transaction history to deliver targeted advertising and marketing to you, where permitted by applicable law. Second, we also process such information to provide support to you as part of our contractual obligations to you. Third, we collect such information because it helps us monitor, prevent and detect fraud.
How We Use Your Personal Information
Provided the applicable law allows us, we collect your personal information primarily to develop, deliver, improve, and operate CoinZero Services, our content and advertising, and for loss prevention and anti-fraud purposes. Examples of how we may use your personal information include:
- Providing you with CoinZero Services and customer support.
- Processing transactions and send you applicable notices.
- Comparing your personal information against third-party databases to verify your identity.
- Sending administrative or account-related information to you.
- Better understanding our customers and how they use CoinZero Services and CoinZero App.
- Providing a more personalized experience and implementing your preferences.
- Customizing, measuring, and improving CoinZero Services and the content and layout of CoinZero App.
- Enhancing security, preventing fraud, monitoring and verifying identity and access to CoinZero Services, combat spam or other malware or security risks.
- Delivering targeted marketing, service update notices, and promotional offers based on your communication preferences, where allowed by law.
- Communicating with you about our events or our partner events,
- Preventing and investigating potentially prohibited or illegal activities, or violations of CoinZero Terms and Conditions.
- Resolving disputes, collecting fees, and troubleshooting problems.
- Complying with our legal obligations.
- Enforcing our agreements with third parties.
- Quality control and staff training.
We will not use your personal information for purposes other than the purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. Where we rely on consent as the lawful basis for processing your personal information, you may choose not to have your personal information shared with third parties or not to allow us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to limit the use of your personal information, certain features of CoinZero App or ConZero Services may not be available to you.
How we Disclose your Personal Information
We share your personal information with third parties only when those parties have a legitimate need to access it, such as to perform their contractual tasks and duties with us. We will never sell or rent your personal information. We may share your personal information in the following circumstances:
- When we need to confirm your identity by comparing the information you give us with public records and third party databases, we may share your personal information with third party identity verification services.
- We may share your information with service providers with whom we contract to help us with business operations, such as collection, marketing, and technology services. Our contracts require these service providers to use your information only in connection with services they perform for us and prohibit them from selling your information to anyone else.
- We share your personal information with financial institutions with which we partner to process payments that you authorize.
- We may share your information with any third parties where we are required to do so by the applicable law or order by court or another authority. We may also share your information where we believe the disclosure is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Terms and Conditions or other agreements or policies.
- We may share your information with third parties with your consent or direction to do so.
While CoinZero is based in the United Kingdom, which is within the European Economic Area (EEA), many third parties with which we do business are based outside of EEA. When we share your information with these parties, therefore, their storing, transferring, and otherwise processing of your information will involve a transfer of data outside of EEA.
When we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that the European Commission has deemed as providing an adequate level of personal data protection.
- Where we use certain service providers based outside the EEA, we may use specific contracts or contractual clauses the European Commission has approved to give personal information the same protection it has in Europe.
- Where we use providers based in the United States, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protections to personal information shared between Europe and the US.
Please contact us at email@example.com if you would like further information about the specific mechanisms we use when we transfer your personal information outside the EEA.
Information Storage and Security
We have put in place appropriate security measures to prevent your personal information from begin accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. For example, we use firewalls and data encryption, we maintain physical access restrictions to our buildings and files, and we authorise access to personal information only to those employees who need it to perform their jobs.
We transfer credit card information securely to a payment vendor that hosts it off-site in compliance with Payment Card Industry Data Security Standards (PCIDSS). This information is not accessible to CoinZero staff.
We also limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know. They will process your personal information only in accordance with our instructions and they are subject to duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach in accordance with our legal obligations.
However, we cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Recognise that you play an important role in protecting your own personal information. When creating a CoinZero account, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to notify us immediately if you become aware of any unauthorised access to or use of your account.
We retain your information for as long as necessary to fulfill the purposes for which we collected it, including to perform our contractual obligations to you and to meet our legal, accounting, and regulatory requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the risk of harm from unauthorised use or disclosure, the purposes for which we process the information, and the applicable legal requirements.
We maintain internal policies for the deletion of information from user accounts following account termination.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to access your personal information that we hold. You also have the right to request that any inaccurate personal information be corrected or deleted.
In addition, you have the right to object to our use of your personal information for direct marketing purposes and, in some circumstances, to our processing or transferring of some or all of your personal information.
If you wish to exercise any of these rights, please contact us at firstname.lastname@example.org.
Finally, you can complain about our processing of your personal information to the relevant data protection authority in the EU member state where you live or work, or where the alleged violation of data protection law has taken place. In the UK, the relevant data protection authority is the Information Commissioner’s Office (ICO):
Information Commissioner’s Office
Tel: 0303 123 1113