Zarclays Privacy Policy

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This Privacy Policy describes how Zarclays collects and processes your personal information through the Zarclays websites and applications that reference this Privacy Notice. Zarclays refers to an ecosystem comprising Zarclays websites (whose domain names include but are not limited to, mobile applications, clients, applets and other applications that are developed to offer Zarclays Services, and includes independently-operated platforms, websites and clients within the ecosystem (e.g. Zarclays Crypto Exchange Platform, Zarclays Launchpad, Zarclays Academy, Zarclays DEX, ZLend, Zyber Wallet, and fiat gateways). "Zarclays Operators" refer to all parties that run Zarclays, including but not limited to legal persons, unincorporated organizations and teams that provide Zarclays Services and are responsible for such services. "Zarclays" as used in this Policy includes Zarclays Operators. This Privacy Policy applies to all platforms, websites, and departments of Zarclays and Zarclays Operators. By using Zarclays Services, you are consenting to the collection, storage, processing and transfer of your personal information as described in this Privacy Policy. 1. What Personal Information About Users Does Zarclays Collect? Zarclays collects your personal information in order to provide and continually improve our products and services. Here are the types of personal information we collect: Information you give us: we receive and store any information you provide in relation to Zarclays. You can choose not to provide certain information but then you might not be able to use some Zarclays Services. Examples of information that you give us include:

  • email address
  • name
  • gender
  • date of birth
  • home address
  • nationality
  • country code
  • other information to help us identify you
  • Automatically Collected information: we automatically collect and store certain types of information about your use of Zarclays Services including your interaction with content and services available through Zarclays Services. Like many websites, we use cookies and other unique identifiers and we obtain certain types of information when your web browser or device accesses Zarclays Services. Examples of the information we collect and analyse include: the Internet protocol (IP) address used to connect your computer to the Internet, login, e-mail address, password and location of your device or computer; Zarclays Services metrics (e.g. the occurrences of technical errors, your interactions with service features and content, and your settings preferences); version and time zone settings; transaction history. Information from other sources: We may receive information about you from other sources such as credit history information from credit bureaus, which we use to help prevent and detect fraud. 2. Can Children Use Zarclays Services? Zarclays does not allow anyone under the age of 18 to use Zarclays Services. 3. For What Purposes Does Zarclays Process My Personal Information? We process your personal information to operate, provide, and improve the Zarclays Services that we offer our users. These purposes include: Transaction services. We use your personal information to take and handle orders, process payments, and communicate with you about orders and services, and promotional offers. Provide, troubleshoot, and improve Zarclays Services. We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of Zarclays Services. Recommendations and personalisation. We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalise your experience with Zarclays Services. Comply with legal obligations. In certain cases, we collect and use your personal information to comply with laws and regulations. For instance, we can collect bank account information for identity verification and other purposes. Communicate with you. We use your personal information to communicate with you in relation to Zarclays Services. Fraud prevention and credit risks. We process personal information to prevent and detect fraud and abuse in order to protect the security of our users, Zarclays Services and others. We may also use scoring methods to assess and manage credit risks. Purposes for which we seek your consent. We may also ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose. 4. What About Cookies and Other Identifiers? We use cookies and similar tools to enhance your user experience, provide our services, and understand how customers use our services so we can make improvements. To enable our systems to recognise your browser or device and to provide Zarclays Services to you, we use cookies. We use operational cookies and similar tools (collectively, "cookies") to provide our services, for example: Recognising you when you sign-in to use our services. Providing customised features and services. Displaying features and services which might be of interest to you, including ads on our services. Preventing fraudulent activity. Improving security. Keeping track of your preferences such as currency and language. We also use cookies to understand how users use our services so we can make improvements. The settings on your browser will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable and remove cookies, and when cookies will expire. Operational cookies allow you to take advantage of some of Zarclays's essential features. If you block or otherwise reject operational cookies through your browser settings some features and services may not work. 5. Does Zarclays Share My Personal Information? Information about our users is an important part of our business and we are not in the business of selling our users' personal information to others. Zarclays shares users' personal information only as described below and with the subsidiaries or affiliates of Zarclays that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice. Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as only permitted by applicable data protection laws. Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). Also, in the unlikely event that Zarclays or substantially all of its assets are acquired, user information will be one of the transferred assets. Protection of Zarclays and others: We release account and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of Zarclays, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction. 6. International transfers of personal data Zarclays may transfer your data outside of the European Economic Area (“EEA”). Zarclays puts in place suitable safeguards to ensure that such transfer is carried out in compliance with applicable data protection rules, except where the country to which the data is transferred has already been determined by the European Commission to provide an adequate level of protection. Where Zarclays transfers personal data to affiliates or service providers, Zarclays relies on the standard contractual clauses approved by the European Commission. 7. How Secure is My Information? We design our systems with your security and privacy in mind. We work to protect the security of your personal information during transmission by using encryption protocols and software. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may ask you to verify your identity before we disclose personal information to you. It is important for you to protect against unauthorised access to your account password. We recommend using a unique password for your Zarclays account that is not utilized for other online accounts. Be sure to sign off when you finish using a shared computer. 8. What About Advertising? We may share your personal information with our marketing partners for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising. 9. What Information Can I Access? You can access your information, including your name, address, payment options, profile information, and transaction history in the "Your Account" section of the website. 10. What Choices Do I Have? If you have any questions or objection as to how we collect and process your personal information, please contact [email protected]. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop any further processing of your data for that purpose. In addition, subject to applicable law, you have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances. If you wish to do any of these things, please contact [email protected]. 11. How Long Does Zarclays Keep My Personal Information? We keep your personal information to enable your continued use of Zarclays Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Notice, as may be required by law such as for tax and accounting purposes, or as otherwise communicated to you. 12. EU GDPR and UK Data Protection Laws - Legal Basis The EU GDPR and UK data protection laws require a legal basis for our use of personal information. Our basis varies depending on the specific purpose for which we use personal information. We rely on: Performance of a contract when we provide you with products or services, or communicate with you about them. This includes when we use your personal information to take and handle orders, and process payments. Our legitimate business interests and the interests of our users when we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others. Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose. Compliance with a legal obligation when we use your personal information to comply with laws. For instance, we collect bank account information for identity verification purposes. These and other legal bases depending on the purpose for which we use personal information. 13. Contact Information Our data protection officer can be contacted at [email protected], and will work to address any questions or issues that you have with respect to the collection and processing of your personal information. 14. Conditions of Use, Notices and Revisions

    If you choose to use Zarclays Services, your use and any dispute over privacy is subject to this Notice and our Terms of Use. If you have any concerns about privacy at Zarclays, please contact us with a thorough description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority. Our business changes constantly, and our Privacy Notice will change also. You should check our websites frequently to see recent changes. If you do not agree with the revised content, you shall stop accessing Zarclays immediately. When an updated version of the Privacy Policy is released, your continued access to Zarclays means that you agree to the updated content and agree to abide by the updated Privacy Policy. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account.