What data we collect
To the fullest extent permitted under applicable Data Protection Laws, we collect the following data and information (collectively, “ Personal Data ”):
- Full name, date of birth, gender, country of residence, username, passwords, tax numbers, and data included in government-issued identification documents;
- Financial information, sources of wealth or funds or income, level of activity anticipated, distributed ledger network wallet addresses;
- Personal Documents such as government-issued IDs, passport, bank statements, utility bills, internet bills, income, account balances, financial transaction history, credit history, tax information, and credit scores, and other forms of identification, address verification and source of funds and wealth verification;
- Corporate information such as legal entity name, doing business as name, legal domicile, fiscal domicile, object;
- Corporate documents such as certificate of registration, constitution, memorandum & articles of association, bylaws, statues, incumbency certificate, register of directors, register of shareholders, register of authorized signatories, registry excerpts, financial statements;
- Information about how you access and use our Services, such as your actions on the Services, including your interactions with others on the Services, photos or media you upload to the Services, your username, and other Customer Content you provide. We may access your device camera roll and camera with your permission. If you need to update your permissions, you can do so in your device’s settings;
- Contact lists on your mobile device or in your email accounts so that you can identify your contacts on the Services and direct the invitation of your contacts. We only access your contact list information with your explicit permission;
- Communications between Zignaly and you including emails, social media messages, job applications, customer support inquiries;
- Information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), and other similar information.
We may monitor, record, and store your personal information in order to protect your safety or the safety of other Customers, comply with relevant laws, to assist with regulatory or law enforcement efforts, to protect and defend our rights and property, or for other reasons relating to our provision of the Services. By using the Services, you consent to the recording, storage, and disclosure of such information you send or receive for these purposes.
The Services are not available to anyone under the age of eighteen (18) (“ Minors ”). Zignaly has implemented the appropriate controls to ensure that Minors do not use or have access to our Services. Therefore, Zignaly will never knowingly and intentionally collect Personal Data from Minors. If you are a parent or guardian of a Minor and you believe or are aware that a Minor has provided us with Personal Data, please contact us immediately. If we become aware that we have collected Personal Data from Minors with or without verification of parental consent, we will take measures to delete that information from our systems.
To the fullest extent permitted under applicable Data Protection Laws, we collect Personal Data about you and any other party whose details you provide to us when you:
- Access or use our Services;
- Create an Account;
- Complete online forms (including call back requests), take part in surveys, post on any forums, download information such as white papers or other publications or participate in any other interactive areas that appear within our Services;
- Interact with us using social media;
- Provide your contact details to us when registering to use or access any services we make available or when you update those details; and
- Contact us or otherwise connect with us, online or offline.
We will also collect Personal Data where you only partially complete and/or abandon any information inputted through our Services and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.
We may also collect information from your devices (including mobile devices) and applications you or your users use to access and use our Services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the Services, referral URL, ad data, your Internet Protocol (IP) address, your browsing history and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies (as described below).
How we use your Personal Data
To the fullest extent permitted under applicable under Data Protection Laws, we use your information to:
- Provide any information or Services that you have requested or ordered;
- Compare information for accuracy and to verify it with third parties;
- Provide, maintain, protect and improve our Services;
- Manage, monitor, and administer your use of the Services and provide an enhanced, personal, user experience;
- Manage our relationship with you (for example, customer services and technical support activities);
- Undertake internal testing of the Services or systems to test and improve their security and performance (in these circumstances, we would de-identify any information used for such testing purposes);
- Provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
- Comply with applicable Know Your Customer, Anti-Money Laundering, Counter-Terrorism Financing, and Anti-Corruption laws and regulations;
- Detect, prevent, investigate or remediate, crime, illegal or Prohibited Activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
- Contact you to see if you would like to take part in our customer research (for example, feedback on your use of our Services);
- Monitor, carry out statistical analysis and benchmarking (provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual);
- Deliver advertising, marketing (including but not limited to in-product messaging) or information which may be useful to you;
- Deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers); and
- In addition to the legal and commercial uses listed above, we may be required to provide any and all of your Personal Data to governmental authorities as necessary to comply with the law. To the extent required by Data Protection Laws, or where we have a legitimate and lawful purpose for doing so, we retain information about you after your withdrawal of funds through the Services, the closure of your Account, if the registration of an Account is declined or if you decide not to proceed with the registration of an Account.
Our Services may contain technology that enables us to:
- Check specific information from your device or systems directly relevant to your use of the Services, applications or Services against our records to make sure the Services services are being used in accordance with our end-user agreements and to troubleshoot any problems;
- Obtain information relating to any technical errors or other issues with our Services;
- Collect information about how you use the features of our Services; and
- Gather statistical information about the operating system and environment from which you access our Services.
Zignaly will treat your Personal Data in order to correctly manage your presence in the social network, inform him of Zignaly activities, Services, as well as for any other purpose that the rules of the social networks allow.
In no case will Zignaly use the profiles of followers in social networks to send advertising individually.
Parties with whom we may share your Personal Data
We may share your Personal Data with:
- Third-Party Internet and Marketing Services Vendors including but not limited to MailChimp, Active Campaign, Facebook, Twitter, Discord, Telegram, GoogleCloud, Google Analytics;
- Government and State Authorities to respond to subpoenas, court orders, legal process, law-enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, and security of Zignaly, our affiliates, Customers, or the public;
- Zignaly Entities and Zignaly’s Affiliated Entities;
- Third-Parties in connection to corporate transactions such as the sale of a website, a merger, consolidation, reorganization, financing, change or control or acquisition of all or a portion of our business by another company or third party, asset sale, initial public offering, or in the unlikely event of bankruptcy or similar proceeding.
We will retain your Personal Data for as long as it is necessary for the purposes of performing a contract, comply with our legal and regulatory obligations, and protecting our legitimate interests. Specifically, we reserve the right to retain your Personal Data for the purposes of complying with applicable Know Your Customer, Anti-Money Laundering, Counter-Terrorism Financing, and Anti-Corruption laws and regulations for a period of at least seven (7) years, and for the purposes of legal proceedings, complaints and disputes for as long as this is necessary to protect our legitimate interests.
Persons who may access your Personal Data
Zignaly’s authorized personnel, including but not limited to our Compliance Officers, shall have access to your Personal Data on a need-to-know basis. Our Compliance Officers and other authorized personnel are bound to confidentiality and non-disclosure agreements, and subject to strict company policies related to the access and use of the data.
We may engage from time to time to third-party service providers to assist Zignaly with the implementation of the KYC/AML & CTF Policy as well as the compliance with applicable Know Your Customer, Anti-Money Laundering, Counter-Terrorism Financing, and Anti-Corruption laws and regulations. Where applicable, we will enter into a data processing agreement with these third-parties to ensure data security and protection of your Personal Data against Data Beaches. Such Data Processors will only process your Personal Data to the extent required for the provision of services for which they are engaged.
We may provide your Personal Data to competent authorities upon their request to the extent legally required or to the extent necessary to defend our rights in legal proceedings or investigations.
To protect your Personal Data, Zignaly takes all reasonable precautions and follows the best practices of the industry to prevent the loss, misuse, improper access, disclosure, alteration or destruction of the same.
In addition to the purposes described in this section, we may also use information we gather to deliver targeted and interest-based advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the Services or any other information we have about you (depending on the Services, you may able to configure these features to suit your preferences).
Legal basis for processing in the EU
In the EU, we collect your Personal Data for the following purposes:
- Based on your consent, for marketing purposes, which can be revoked at any time;
- Where necessary to perform any contract we enter into, or have entered into, with you to provide Services or provide access to our Services;
- Where necessary for our legitimate business interests (or those of a third party) when your interests and fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation either in the EU or elsewhere.
You have the following rights:
- The right to access your own Personal Data;
- The right to have your Personal Data rectified if it is inaccurate or incomplete;
- The right to request deletion or removal of your Personal Data where there is no good reason for processing to continue;
- The right to restrict processing of your Personal Data where there is no good reason for processing to continue;
- The right to data portability to enable moving, copying or transferring of Personal Data from one platform to another;
- The right to object to the processing of your Personal Data in certain circumstances; and
- Rights relating to profiling and automated decision making resulting from the processing of your Personal Data.
The exercise of these rights is personal and therefore must be exercised directly by the interested party, requesting it directly to Zignaly, which means that any Customer, user, subscriber or collaborator who has provided their data at any time can contact Zignaly and request information about the data that it has stored and how it has been obtained, request the rectification of the same, request the portability of your Personal Data, oppose the processing, limit its use or request the cancellation of that data in Zignaly’s files.
To exercise the rights of access, rectification, cancellation, portability and opposition, you must send an email to the Data Protection Officer of Zignaly [email protected] together with a valid proof of identity such as a Government-issued ID document.
The Services may include embedded content (for example, videos, images, articles, etc.). The embedded content of other internet websites behaves in exactly the same way as if you had visited other internet websites.
- About cookies
Cookies are files, often with unique identifiers, that web servers send to Internet browsers and can then be sent back to the server each time the browser requests a page from the server.
Cookies can be “persistent” cookies or “session cookies”. A persistent cookie consists of a text file sent by a web server to an Internet browser, which is stored by the browser and remains valid until the defined expiration date (unless the user deletes it before the expiration date ). On the other hand, a session cookie expires at the end of the user’s session, when the Internet browser is closed.
- Cookies from the Services
On our Services, including our Website, and mobile applications, we use session and persistent cookies.
We will send you the following cookies:
- Session Cookies
- Google Analytics: This cookie allows us to identify unique users, unique sessions, regulate the rate of requests and store information about user sessions and campaigns.
Cookie 1 is a session cookie, while Cookie 2 is a persistent cookie.
Cookies do not contain personally identifiable information, but we have the possibility of linking the Personal Data we store about you with the information obtained and stored from cookies.
We use the information we obtain from the use of our cookies for the following purposes:
- Recognize your computer when you access and/or use our Services.
- Improve the usability of the Services.
- Analyze the use of our Services.
- Manage the Services.
- Third party cookies
When you use the Services, you may also be sent third-party cookies.
Our service providers can send you cookies. They use the information they obtain through their cookies for the following purposes:
- Track your browser on different Services.
- Create a profile of your Internet browsing.
- Select specific ads that may be of interest.
- Deletion and blocking of cookies
- https://support.google.com/chrome/answer/95647 (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-Services-preferences (Firefox);
- https://help.opera.com/en/latest/security-and-privacy/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/en-gb/guide/safari/manage-cookies-and-Services-data-sfri11471/mac (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
When accessing and/or using the Services, non-identifying data may be collected, which may include the IP address, geolocation, a record of how services and Services are used, browsing habits and other data that cannot be used to identify the User.
The Services use the following third-party analysis services: Google Analytics
Zignaly uses the information obtained to obtain statistical data, analyze trends, administer the Services, study navigation patterns and to gather demographic information.
You agree that the information provided to Zignaly is correct, complete, accurate and current. You are solely responsible for the veracity and correctness of the data you submit when access and/or using the Services, exonerating Zignaly from any responsibility in this regard.
To exercise the rights of access, rectification, cancellation, portability and opposition, you must send an email to [email protected] along with your valid proof of ID such as a Government-issued identification document. The exercise of your rights do not include any Personal Data that Zignaly is obliged to keep for administrative, performance of contracts, legal or security purposes.
In case of incorporation, acquisition, merger or any other causes that cause the change of Operatorship of the Services, you expressly consent that your registration data and information are transferred by Zignaly to the new Operator. When and if this occurs, Zignaly will comply, in any case, with the duty of information to you.
The Services are operated by Highend Technologies LLC, a Saint Vincent and the Grenadines limited liability company with its office address at First Floor, First St. Vincent Bank Ltd Building, James Street, Kingstown, Saint Vincent and the Grenadines..