Privacy Policy

ZENOFI UAB PRIVACY NOTICE

Welcome to the Privacy Notice for ZenoFi UAB

ZenoFi UAB respects your privacy and is committed to protecting your personal data.

1. About us

2. Purpose of this Privacy Notice

3. The data we collect about you

4. Lawful basis

5. Purposes for which we will use your personal data

6. Marketing

7. Automated Decision-Making and Data Profiling

8. Disclosures of your personal data

9. International transfers

10. Data security

11. Data retention

12. Your legal rights

13. Glossary

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1. About us

ZenoFi UAB (referred to as "we", "us" or "our" in this Privacy Notice) is the owner of this website, and the controller of the personal data processed through this website. SatoshiGroup Limited (a commonly owned UK entity) and ZenoFi UAB form a group of companies, together called the “ZenoFi Group”.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.

If you have any questions about this Privacy Notice, our privacy practices, or how to exercise your legal rights, please contact our DPO in the following ways:

Name: Benedict Fattorini

Email address: support@satoshideals.org

Telephone number: +447484265709

ZenoFi UAB address: Vilnius, Laisvės pr. 60, LT-05120, Lithuania

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk) or to the State Data Protection Inspectorate (https://vdai.lrv.lt/en/) (Valstybinė duomenų apsaugos inspekcija or VDAI in Lithuanian). We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so please contact us in the first instance.

2. Purpose of this Privacy Notice

This Privacy Notice explains how we look after your personal data, how we collect and process it through your use of our website or when you purchase one of our products or services. We might also collect personal data about you from other sources, such as other companies or publicly available information.

You can find out more in the The Data We Collect About You section below.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Notice together with any other Privacy Notice or fair processing Notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements other notices and privacy policies and is not intended to override them.

2.1 Changes to the Privacy Notice and your duty to inform us of changes.

We keep our Privacy Notice under regular review. This version was last updated on 6th November 2023. Please contact us for a copy of this notice, or for previous versions, by contacting us at support@satoshideals.org.

If we change the way we use your personal data, we’ll update this notice and, if appropriate, let you know through our website, or by email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2.2 Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.

3. The data we collect about you

3.1 What is personal data?

Personal data, or personal information, means any information which can be used to identify you. This includes:

information which is clearly about you (such as your name or your photo); or
different pieces of information which do not identify you when taken individually, but when combined together can identify you. An example is your phone number (or public key), as this does not directly identify you, but when used with a phone directory (or online research) does identify you; or
information which does not identify you, but can be used to identify you when technology is applied to the information. An example is encrypted information, which can be decrypted.

It does not include data where the identity has been removed (anonymous data).

3.2 Categories

We collect, use, store and transfer different kinds of personal data about you. We have grouped these under the headings: Contact, Financial, Identity, Marketing and Communications, Profile, Technical, Transactional, and Usage. More details about these categories are available in the Glossary: Categories of Personal Data.

3.3 Sources of personal data.

We might also collect personal data about you from different sources, as set out below.

Information you provide to us

When you open an account with us, correspond with us by post, phone, email, fill in forms, respond to surveys, take part in online discussions or contact us otherwise, you provide us with Contact Data, including information such as your billing address, email address and telephone number.

When you purchase our products or services, or pay for other products or services when using our systems or products or service, you might provide Financial Data such as your bank account, payment card details, wallet address, or tax information.

When you apply for or use our products or services, or register to use our website, you provide us with information about yourself including your name, date of birth, digital identity. You might also include your photo or video form, or other information we require to conduct KYC/AML such as your passport or driving license. We call this Identity Data.

You might also provide information about members of your family, or work, or ask us to contact third parties on your behalf, in order to conduct our KYC and AML checks.

In carrying out KYC and AML checks and a periodic review of that information we may collect Special Categories of Personal Data about you in so far as this identifies you as a politically exposed person. In this connection we may also collect information about criminal convictions and offences.

Where you have enabled location or GPS services, we will be able to see your location. We call this Location Data.

When you inform us of your marketing preferences or how you would like to receive information from us, or subscribe to our services, publications or social media, we call this Marketing Data.

When you register with us, you might create an account or profile using information such as a username and password. We call this Profile Data.

As you interact with our website, our systems automatically collect, information about your device, your platform, browser, and the other Technical Data described in the Glossary.

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Automated technologies or interactions

When your devices interact with our website, we may collect data by using cookies, pixels, tracking technologies, server logs and other similar technologies

Information about your transactions, such as payments or transfers made or received, assets held, transaction dates and times, the time taken to make the transfer/payment, currencies, exchange rates, messages sent and received, Technical Data about your device. We call this Transaction Data. We also collect details of the person or entity you are transacting with (including some of their Identity Data, Technical Data, Financial Data and Contact Data).

How you have used our website, products and services. This includes information about your visit, such as the links you’ve clicked on, through and from our website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page. We call this Usage Data.

Information stored on your device, such as your contacts, location, historic use of your device, any information stored on your device, and details of other software or apps you use.

Information about your device and how it connects to other devices and networks and how you connect with the device. This includes the internet protocol (IP) address used to connect your computer to the internet, your login information, the browser type and version, the time zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system and the type of mobile browser you use. We call this Technical Data.

We might also track your location if location services are enabled on your device. We call this Location Data.

We might also receive Technical Data about you if you visit other websites employing our cookies.

Our cookies will regularly collect this information in order to stay up to date (but only if you have given us permission). Please see our cookie policy below for further details.

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Information from publicly available sources

Companies House in the United Kingdom, and equivalent registers in other countries.
Tax authorities, including HMRC in the United Kingdom and potentially tax authorities in other countries (for details about tax information, eg, VAT numbers, social security numbers).
Electoral Registers in various countries
Online registers or directories in various countries
Social media, such as Telegram, Instagram, WhatsApp, Twitter, Facebook, Discord, Reddit, LinkedIn and others. We might use information from social media websites or apps to conduct due diligence or to create a profile about you.
Websites for enhanced due diligence, security and KYC purposes.

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Information from third parties

KYC/AML providers:

When you apply for our use our products or services, or create an account with us, we might receive certain background and identity check information or KYC/AML data from third parties such as credit reference agencies, financial or credit institutions, official registers and databases, fraud prevention agencies and partners who help us to provide our services.

This includes your information to help us check your identity, information about your spouse and family (if applicable in the context of an application) and information relating to your transactions.

Providers of financial or payment services

We might receive information about you during the course of the transactions you engage in by using our website, products or services, from counterparties such as:

regulated and unregulated financial or credit institutions including merchants, ATMs, custodians, wallets, exchanges, peer to peer ecosystems, in various countries globally
joint account holders
partners who help us to provide our services

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We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we might aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.‍

3.4 If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we might not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we might have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. Lawful basis

We use your personal data only when we have a ‘lawful basis’ (or valid legal justification) to do so. The lawful bases we commonly rely on are:

Where we need the personal data in order to perform the contract we are about to enter into or have entered into with you. For example, we cannot provide our services to you without knowing who you are.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation. For example, we might be required to gather information to comply with tax laws.
Where you have agreed we can collect your personal data, or sensitive personal data, and use it in a certain way. For example, you might given us consent by ticking a box. have ticked a box.

The Lawful Basis section in the Glossary below provides more details.

5. Purposes for which we will use your personal data

5.1 Purposes of Personal Data Use, and relevant Legal Basis

We have set out below how we plan to use your personal data, and the legal bases we rely on to do so. Note that we might process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data. Please contact us if you need additional details.

How we use your personal data

Providing our services and products ‍

Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Transaction

We use your personal data when providing our products and services to you, including:

Registering you as a customer, including confirming your identity and eligibility, and those of and any joint account holders
Accepting you as a customer, including setting you up as a customer on our systems
Processing and delivering your orders or transactions, including managing payments, fees and charges and transferring and receiving assets
Collecting and recovering money owed to us in relation to any agreement we have with you
Providing customer support services to you. We might record and monitor any communications between you and us, including phone calls, to maintain appropriate records, check your instructions, analyse, assess and improve our services, and for training and quality control purposes

Lawful basis for Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Transaction:

Performance of a contract with you
Legal obligations
Legitimate interest (ensuring our efficiency in providing our services to you, on how we meet our legal obligations).

2. Managing our relationship with you

Data categories: Contact, Identity, Marketing & Communications,

We will use your personal data to:

notify you about changes to our terms and conditions, our products or services, or our Privacy Notice
update you about your account
verify your identity if you contact our customer support or social media teams
allow you to take part in interactive features of our services
ask you to leave a review, take a survey, or provide feedback.

Lawful basis for Data categories: Contact, Identity, Marketing & Communications:

Performance of a contract with you
Legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

3. Administering and protecting our business and website

Data categories: Technical

We use your personal data to manage our website including,

troubleshooting, data analysis, testing, research, statistical and survey purposes, system maintenance, support, reporting and hosting of data
making sure that content is presented in the most effective way for you and your device
helping keep our website and systems safe and secure

Lawful basis for Data categories: Technical:

Keeping to contracts and agreements between you and us
Legitimate interests (to present content as effectively as possible for you, for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Legal obligation
Consent (where required by law)

4. Providing location-based services

Data categories: Location

Where you have enabled location-based services, we can

provide you with location-relevant advertising, products and services, (for example, information about nearby merchants)
protect against fraud

Lawful basis for Data categories: Location:

Keeping to contracts and agreements between you and us
Legitimate interests (to develop and market our products and keep to regulations that apply to us)
Consent (to track you when you have location services switched on)

5. Improving our products and services

Data categories: Contact, , Identity, Location, Transactional.

We use your personal data to help us develop and improve our current products and services. This allows us to continue to provide products and services that our customers want to use.

Lawful basis for Data categories: Contact, Identity, Location, Transactional:

Legitimate interests (to understand how customers use our products so we can develop new products and improve the products we currently provide)

6. Marketing and providing products and services that might interest you

Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Transactional.

We use your personal data to do the following:

to make suggestions and recommendations about our goods and services
deliver relevant website content and advertisements, personalise your experience and marketing messages about our products and services so they’re more relevant and interesting to you (where allowed by law). This may include analysing how you use our products, services and your transactions
if you agree, provide you with information about our partners’ promotions or offers which we think you might be interested in
if you agree, allow our partners and other organisations to provide you with information about their products or services
measure or understand the effectiveness of our marketing and advertising, and provide relevant advertising to you
ask your opinion about our products or services

Remember, you can ask us to stop sending you marketing information by adjusting your marketing choices (the How do you use my personal data for marketing? section below explains how to do this).

Lawful basis for Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Transactional:

Legitimate interests (to send direct marketing, ensure our direct marketing is relevant to your interests, develop our products and services, and to be efficient about how we meet our legal and contractual duties)
Consent (where we’re legally required to get your consent to send you direct marketing about our products or services, or partners’ promotions or offers, or for you to receive marketing from other organisations)

7. Helping with social interactions

Data categories: Contact, Identity, Location, Marketing & Communications

We use your personal data to help with social interactions through our services.

Lawful basis for Data categories: Contact, Identity, Location, Marketing & Communications:

Legitimate interests (to develop our products and services and to be efficient in meeting our obligations)
Consent (to access information held on your phone, for example, contacts in your contacts list, to track you when you have location services switched on)

8. Fraud prevention

Data categories: Contact, Identity,

We use your personal data to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your account.

Lawful basis for Data categories: Contact, Identity:

Legal obligation
Legitimate interest (to develop and improve how we deal with financial crime and meet our legal responsibilities)

9. Meeting our legal obligations, enforcing our rights and other legal uses

Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Technical, Transactional.

We use your personal data:

to share it with other organisations (for example, government authorities, law enforcement authorities, tax authorities, fraud prevention agencies) if required by law
to recover debts from you (for example, where you have a negative balance in your account)
if necessary, to meet our legal or regulatory obligations
to identify and support vulnerable customers by analysing your behaviour in the website, customer support communications and through transactions (for example, we will try to identify whether you are potentially vulnerable so we can provide you with enhanced support. Identifying and supporting vulnerable customers is a legal requirement for us in some countries)
in connection with legal claims
to help detect or prevent crime

You can find out more in the Do you share my personal data with anyone else? section below.

Sometimes, we’re legally required to ask you to provide information about other people. For example, we might ask you to explain:

your relationship with a joint account holder or somebody who pays money into your account
how somebody got the money in the first place to pay into your account

Lawful basis for Data categories: Contact, Financial, Identity, Location, Marketing & Communications, Technical, Transactional:

Legitimate interests (for example, to protect us during a legal dispute)
Substantial public interest (if we process your sensitive personal data to keep to legal requirements that apply to us)
Legal obligations

10. Preparing anonymous statistical datasets

We prepare anonymous statistical datasets about our customers’ transaction patterns:

for forecasting purposes
to understand how customers use our website, products and services
to comply with governmental requirements and requests

These datasets may be shared internally or externally with others. We produce these reports using information about you and other customers. The information used and shared in this way is never personal data and you will never be identifiable from it. Anonymous statistical data cannot be linked back to you as an individual.

For example, some countries have laws that require us to report spending statistics and how money enters or leaves each country.

We’ll provide anonymised statistical information that explains the broad categories of merchants that customers in that country spend their money with. We’ll also provide information about how customers top up their accounts and transfer money. However, we won’t provide any customer-level information. It will not be possible to identify any individual customer.

Lawful basis for Preparing anonymous statistical datasets:

Legitimate interests (to conduct research and analysis, including to produce statistical research and reports)
Legal obligations

5.2 Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we might process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Marketing

6.1 Promotional offers from us

You will receive marketing communications (by post, push notification, email and text message ) from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. Where national laws require us to get your consent to send marketing messages, we’ll do so in advance.

We might use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you might want or need, or what might be of interest to you. This is how we decide which products, services and offers might be relevant for you (we call this marketing).

You can object to profiling for direct marketing purposes.

6.2 Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can find out more in the Do you share my personal data with anyone else? section below.

6.3 Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

6.4 Our legal basis for marketing is:

consent (where we are required by law to collect your consent); or
legitimate interests (to send you marketing and to provide information relevant to your interests).

6.5 Cookies

We use cookies to analyse how you use our website. For more information about the cookies we use, please see our Cookie Notice below.

We may also use pixels or web beacons in the direct marketing emails that we send to you. These pixels may track whether our email was delivered and opened, and whether links within the email were clicked. They may also allow us to collect information such as your IP address, browser, email client type and other similar details. We use this information to measure the performance of our email campaigns, and for analytics. You can control whether you receive direct marketing emails by contacting us.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website might become inaccessible or not function properly.

7. Automated Decision-Making and Data Profiling

We might make automated decisions about you. This means that we might use technology that can evaluate your personal circumstances and other factors to predict risks or outcomes. This is sometimes known as profiling. We do this for the efficient running of our services and to ensure decisions are fair, consistent, and based on the right information.

Where we make an automated decision about you, you have the right to ask that it is manually reviewed by a person. You can find out more about this in the What are my rights? section below.

For example, we might make automated decisions about you that relate to:

Opening accounts: conducting KYC, anti-money laundering and sanctions checks and identity and address checks
Detecting fraud: monitoring your account to detect fraud and financial crime

Our legal basis is one or more of the following:

keeping to contracts and agreements between you and us
legal obligations
legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities

8. Disclosures of your personal data

We might share your personal data with the parties set out below, for the purposes set out in the Purposes for which we will use your personal data section above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Internal: We share your personal data within the ZenoFi Group where they act as processors and joint controllers, to the extent systems, resources and operations are shared. This is to provide you with the best service, send you information about our products and services we think you’ll be interested in hearing about, or to comply with our regulatory requirements. Our legal bases are contract, legal obligation and legitimate interest. The ZenoFi Group has offices in the United Kingdom and Lithuania.

People, wallets or entities you transfer money or assets to: Where you make a payment or transfer from your account, we’ll provide the recipient with your details alongside your transfer (for example, your name, IBAN, wallet address, unique identifier). This is because, like all financial institutions, we’re required by law to include certain information with transfers. Our legal bases are contract and legal obligation. These entities might be located globally, and outside the United Kingdom.

People, wallets or entities who send you money or assets: When you receive a payment or transfer into to your account, we’ll provide the payer or sender with your details (for example, your name, IBAN, wallet address, unique identifier). Our legal bases are contract and legal obligation. These entities might be located globally, and outside the United Kingdom.

Credit reference agencies: when conducting KYC/AML checks or when you apply for credit from us, these agencies might act as processors or joint controllers. Our legal bases are contract and legal obligation. If you are in the United Kingdom, these include Equifax and Experian.

Financial crime prevention service providers, acting as processor and joint controllers. These include identity verification service providers, fraud prevention and financial crime agencies, or other entities required by law or in connection with an investigation. Our legal bases are contract and legal obligation. The entities are located in the UK and elsewhere.

Professional advisors: acting as processor or joint controller including lawyers, bankers, auditors and insurers based in the United Kingdom, Lithuania and elsewhere who provide consultancy, banking, legal, insurance, payroll management and accounting services. Our legal bases are contract and legal obligation.

Government bodies, such as regulators, law enforcement authorities, competition authorities, and tax authorities, acting as processor or joint controller, to check your identity, protect against fraud, keep to laws (including tax laws, anti-money laundering laws, data protection or cyber security laws or any other laws), and confirm that you’re eligible to use our products and services. Our legal basis is legal obligation. These bodies include HMRC (the UK Tax Authority), the FCA (the UK financial authority), the ICO (the UK data regulator), and similar authorities in other countries.

Social media and advertising companies. When we use social media for marketing purposes, we might share your personal data (limited to only your name, email address) to check if you also hold an account with them; to send your our adverts, where we think that one of our new products or services might interest you; to send our adverts to people who have a similar profile to you. When we use advertising partners, we might share your personal data with them as described above, but we hash the personal data before we send it, and the social media platform we share it with is only allowed to use that hashed personal data as described above. Our legal basis is legitimate interests (to ensure our advertising is as effective as possible). The recipients can be located inside and outside the UK, including Ireland and the USA.

Where you ask us to share your personal data with a third party. For example, you might authorise third parties to act on your behalf (such as a lawyer, accountant or family member or guardian under a power of attorney). Our legal basis would be contract, legal obligation or legitimate interest. The entity would be located wherever you had sourced them.

Purchasers of our portfolio or assets: third parties to whom we might sell, transfer or merge parts of our business or our assets. Alternatively, we might seek to acquire other businesses or merge with them. Our legal basis would be contract and legitimate interest.

Suppliers: service providers, including but not necessarily limited to:

IT service providers, acting as processors, who provide email/messaging services (Google Workspace, in Ireland, Google LLC, in the USA, Slack Technologies, LLC, in the USA), Cloud Computing and Web Hosting (Webflow, Inc., in the USA, Wix.com Ltd, in Israel, Google LLC, in the USA, Github, Inc., and Render.com, both in the USA), system administration, error monitoring (Osano Inc in the USA), storage (Google Workspace, in Ireland, Google LLC, in the USA), hosting, network services, software developers.
Software application providers, acting as processors, who provide software that we use to deliver our products and services, such as document management systems (DocuSign, Inc. in the USA, Google Workspace, in Ireland)) workspace and project management (Slack Technologies, LLC, in the USA), accounting systems, marketing database, internal document storage systems.
Mailing service providers, acting as processors, who ship our products and mail to you.
Financial services providers and partners, acting as processor or joint controllers, who offer audit services, payment networks, custodians, staking services, wallet providers, payment processors, banking and financial services partners and payments networks such as Visa, Mastercard, Clear Junction Limited, BCB Payments Ltd in the UK).
Analytics providers, acting as processors, who offer services such as KYC/AML analysis (Sum and Substance Ltd, in the UK, Chainalysis, Inc, in the USA, Safelement Limited, in China), surveys and statistical analysis.
Customer-service providers, acting as processors, who offer marketing and customer assistance services (Webflow, Inc., in the USA, Wix.com Ltd, in Israel, Crisp, in France).
Communications services providers, acting as processors, who offer video and meeting facilities (Zoom, in the USA, Google Meets, in Ireland, Microsoft Teams in the USA), community, communications and correspondence services (such as sending emails, push notifications and text messages, creating a community for customers to interact (Discord Inc., in the USA, Telegram Messenger Inc., in the British Virgin Island and in the UAE, WhatsApp Ireland Limited, in Ireland, and WhatsApp LLC in the USA).

9. International transfers

Many of our business processes are international, and the parties we interact with are based outside the UK, so your personal data will involve a transfer of data outside the UK.

For example, if you make (or receive) an international transfer, we’ll send (or receive) funds or assets to (or from) banks or wallets outside the United Kingdom.

We might also send your personal data outside the United Kingdom to abide by global legal and regulatory requirements, to provide ongoing support services, to credit reference agencies, fraud prevention agencies, law enforcement authorities or to enable us to provide you with products or services you have requested.

Whenever we transfer your personal data outside the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

the transfer is to a country that has been deemed to provide an adequate level of protection for personal data by the Information Commissioner’s Office.
the use of specific contracts approved for use in the UK which give personal data the same protection it has in the UK. These include Standard Contractual Clauses, International Data Transfer Agreements and Data Processing Agreements.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

10. Data security

We have implemented appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These measures include:

Limiting access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Implementing procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.
Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means.
Our staff receives data protection and information security training.
We have detailed security and data protection policies which staff are required to follow when they handle your personal data.

While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorised access, we cannot guarantee it will be secure during transmission by you to our website or other services.

We use HTTPS (HTTP Secure), where the communication protocol is encrypted through Transport Layer Security for secure communication over networks, for all our web and payment-processing services.

If you use a password for our website, you will need to keep this password confidential. Please do not share it with anyone.

When you use our public services, which includes our social network accounts and our community forum, do not share any personal data that you don't want to be seen, collected or used by other customers, as this personal data will become publicly available.

11. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We might retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes and AML purposes.

In some circumstances you can ask us to delete your data. See the section below Your Legal Rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we might use this information indefinitely without further notice to you.

12. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Right to information about how your personal data is used.

You have the right to be told how we use your personal data. This Privacy Notice is one way in which we provide this information to you. If you ask, we’ll provide a copy of the personal data we hold about you. We can’t give you any personal data about other people, personal data which is linked to an ongoing criminal or fraud investigation, or personal data which is linked to settlement negotiations with you. We also won't provide you with any communication we've had with our legal advisers.

Right to access

You have the right to access your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we might need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data.

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.

You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we might have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Note, however, that we might not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

As a regulated financial services provider, we must keep certain customer personal data even when you ask us to delete it. If you've closed your account, we might not be able to delete your entire file because these regulatory responsibilities take priority. We’ll always let you know if we can't delete your personal data.

Object to processing of your personal data

You can object to your personal data being processed where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we might demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. If you object to us using personal data which we need in order to provide our services, we might need to close your account as we won’t be able to provide the services.

Request restriction of processing of your personal data.

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party.

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data

This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Request a review by a person of an automated decision

You can request that a human person review any automated decision we made about you, where that automated decision significantly affects you.

12.1 Exercising your rights

If you wish to exercise any of the rights set out above, please contact us at support@satoshideals.org.

Your ability to exercise these rights will depend on a number of factors. Sometimes, we won’t be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).

12.2 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we might charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

12.3 What we might need from you

We might need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We might also contact you to ask you for further information in relation to your request to speed up our response.

12.4 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. Glossary

LAWFUL BASIS

Legitimate Interest

means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation

means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

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CATEGORIES OF PERSONAL DATA

Contact Data

billing address, delivery address, email address, telephone numbers, wallet address

Financial Data

bank account details, including the name of the account holder, account number, sort code and IBAN
payment card details, such as the card number, and name of the card owner, including the card number, expiry date and CVC (the last three digits of the number on the back of the card)
data extracted from documents provided as proof of source of funds/wealth
your country of residence, tax residency information, and tax identification number
wallet addresses and wallet details
details of tokens/currencies/assets purchased and sold
credit record (including information about late payments)
we might also collect personal data from accounts you hold with third parties such as financial institutions, custodians, wallets, exchanges and DeFi ecosystems.

Identity Data

first name, maiden name, last name, title, marital status, date of birth, gender, sex
your image in photo or video form (where required as part of our Know-Your-Customer (KYC) checks, to verify your identity if you contact us when logged out of your account, or where you upload a photo to your account), videos, sound recordings,
biometric data such as facial features
place of birth, citizenship or nationality
identity document data, such as document type (eg passport or driving license), issuing country, number, expiry date, MRZ, information embedded into document barcodes (may vary depending on the document), security features, and any other information you provide to prove you are eligible to use our services
information about other people (such as a joint account holder, your spouse or family) when we ask you to give us this information to enable us to comply with our obligations under KYC, anti-money laundering laws and to assist with fraud monitoring. If you give us personal data about other people (such as a joint account holder, your spouse or family), or you ask us to share their personal data with third parties, you confirm that you have sought their consent beforehand.
your registration information, username or similar identifier, passwords, unique identifiers such as public keys, wallet addresses and other identifiers
details of the device you use (for example, your phone, computer or tablet)

Location Data

We might track your location using GPS technology, or collect this data from your device

Marketing Data.

preferences in receiving marketing from us and our third parties
records of your consent regarding our marketing with you
records of our discussions, if you contact us or we contact you (including records of phone calls)

Profile Data

username and password
your purchases or orders
your interests and preferences, and your online and offline behavioural patterns
feedback
survey responses

Technical Data

internet protocol (IP) address
login data, including username, password, public keys and private keys
browser type and version, browser plug-in types and versions
time zone setting and location
operating system and platform you are using
the type of device you use
a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device)
mobile network information
your mobile operating system
the type of mobile browser you use

Transaction Data

Information on transactions and your use of our services and products and details about payments and transfers to and from you, including:

the date
time
amount
currencies, tokens, assets
exchange rate
beneficiary details
details of the entities associated with the transaction (including the locations and other details of the entities, such entities being merchants, ATMs, custodians, wallets, exchanges, and individuals on peer to peer exchanges)
IP address and wallet address of sender and receiver
sender's and receiver's names, registration information, wallet addresses and identifiers
messages sent or received
details of device used to arrange the payment or transfer
the payment method used

Usage Data

Information about how you use our website, products and services, including:

the links you’ve clicked on, through and from our website (including date and time)
services you viewed or searched for
page response times
download errors
length of visits to certain pages
page interaction information (such as scrolling and clicks)
methods used to browse away from the page

ZENOFI UAB COOKIE NOTICE

Last Updated: 6th November 2023

Welcome to the Cookie Notice for ZENOFI UAB

1. What are cookies:

Cookies are text files that are placed on websites. Each cookie includes the name of the website and a unique ID. They can be stored on your browser or the hard drive of your computer if you agree.

Cookies track things like how long a visitor spends on our website and what visitors do on our website (which pages they visit and which buttons they click on, for example). Cookies collect this information and share it with the website owner.

2. How we use cookies:

Our website may use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Some of the cookies we may use on our website are 'persistent' cookies. This means that they remain on your device until you erase them or they expire. The rest of these cookies are 'session' based which are more temporary in duration. This means they will be erased when you close your internet browser.

3. Types of cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.
Analytical or performance cookies. These allow websites to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps website owners to improve the way their website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to a website. This enables website owners to personalise their content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to a website, the pages you have visited and the links you have followed. Website owners will use this information to make their website and the advertising displayed on it more relevant to your interests. [Website owners may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.

4. The cookies we use

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

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Cookie name: Marketing & Analytics Cookies

Type: Targeting

Purpose:

Estimates our audience size and demonstrates how our website it used.
Used to track advertising effectiveness to provide a more relevant service and deliver better ads to suit your interests.
These cookies help us to understand how visitors interact with our website, discover errors and provide a better overall analytics.
Stores information about your browsing preferences, and so allow us to customise our site and to provide you with offers that are targeted to your individual interests.
Speeds up your searches.
Recognises you when you return to our site.
Allows you to use our site in a way that makes your browsing experience more convenient, for example, by allowing you to store items in an electronic shopping basket between visits. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim.

More information

Time limit: 21 years

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Cookie name: Functional Cookies

Type: Functional

Purpose:

We use this to restore the chat session and messages of a chatbox user when browsing between website pages and/or coming back on the website a few days after.
These cookies collect data to remember choices users make to improve and give a more personalised experience.

More information

Time limit: No time limit

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Cookie name: Necessary Cookies

Type: Strictly necessary

Purpose:

We need this to keep track of the user visited locale, currently the only option is `en-gb`. If the user is on `/en-gb/whatever-page` and they navigate to `/another-page`, we need to prefix it with the last visited locale.

More information

Time limit: Length of visit

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We share the information collected with our website hosting service, Webflow, Inc. located in the USA.

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5. Cookie Preferences

You can manage your cookies preferences by emailing us at support@satoshideals.org.

You can also manage your preferences by changing your browser settings on your device to refuse the use of all or some cookies. However, if you block all cookies (including necessary cookies), you may not be able to use all or some parts of our website. You may also find that you are shown information on our website that is less interesting to you.

6. Third party cookies

Please note, other organisations, such as advertising networks, may also use cookies to track you across different websites. We have no control over these cookies.

They might include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

Sum & Substance (3rd Party KYC Tool) is utilised by ZenoFi UAB in order to verify and identify customer identities. They have a separate website to ZenoFi UAB and therefore may present with separate cookies.

To deactivate the use of third party cookies, you may visit the relevant page on their website in order to manage the use of these types of cookies.

7. Changes to our cookies

If we change the cookies we use, we will update this Cookies Policy. You always can find the latest version of this Policy on our website.

If you have any questions or concerns about our use of cookies, please send us an email at support@satoshideals.org

COMPANY DETAILS:

ZENOFI UAB

Company Number: 305919366

Address: Vilnius, Laisvės pr. 60, LT-05120, Lithuania

Privacy Policy

ZENOFI UAB COOKIE NOTICE

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Authorised