1.Overview 1.1 ZINEMX Exchange is committed to protecting the privacy of all users. You should carefully read and understand this Privacy Policy before you use the transactions and services operated or maintained by ZINEMX Exchange (including, but not limited to, the ZINEMX Exchange website, mobile apps, APIs, and any related software, forums, and social media pages). 1.2 Any natural person or other subject who accesses this website is a user of this website. For the purposes of this Privacy Policy, users are referred to as "you". 1.3 For the purposes of this Privacy Policy, you and we are referred to collectively as the "Parties" and individually as a "Party". 2.Purpose of the Privacy Policy This Privacy Policy describes what information we may collect about you (personal data), how we use it and how we protect it. 3. Your consent In order to ensure that you are confident in the way in which we process personal data, you are advised to read and understand the terms and conditions of this Privacy Policy in detail. In particular, by logging on to our website, whether or not you have registered on the site, you indicate that you accept, understand and acknowledge the following: 3.1 You consent to the disclosure of your personal data to us based on your own free will and necessary consent; 3.2 You will comply with all the terms and conditions of this Privacy Policy; 3.3 You agree that we may collect information about you by your access to any of the Websites, by registering on the Websites and/or by using the services we provide; 3.4 You agree to any changes and modifications we may make to the Privacy Policy in the future; 3.5 You agree that our branches, affiliates and employees may contact you about products and services which we reasonably believe may be of interest to you (unless you have indicated to us in writing that you do not wish to receive such information). 4. Information gathered 4.1 When you use the Website, you agree to allow us to use cookies to track each of your actions and to collect and retain all information you leave on the Website, including, but not limited to, your IP address, location and other information. For more detailed information about our use of cookies, please read our Cookie Policy. 4.2 If you wish to use the services provided by this website, you will need to complete and provide the following two types of information: 4.2.1 Identity Information. This type of information helps us verify that you are eligible to register as a user of our Site. This includes, but is not limited to, your name, residential address, postal address, other certificates issued by your country or government proving your identity information and their corresponding numbers, and all other information that helps us verify your identity (Identity Information). 4.2.2 Service Information. This type of information helps us to contact you and provide you with services, including, but not limited to, your telephone number, fax number, valid e-mail address, mailing address, and information about your debit card and/or other financial institution accounts (Service Information). 4.3 When you use any of the Sites or Services, we may collect additional information through our proprietary email address or other means that we believe meets the relevant requirements necessary to improve the functionality of the Sites, to enhance your experience of using our Sites as well as the Services and their security, or as may be required by any court order or by any applicable law, administrative regulation, or any order of any competent governmental agency or authority. 4.4 If you access any links to third party websites, pages, content or Exchange that can be accessed via a link from the Website or any link from any of our third party partners, you must, and will be required to, agree to and comply with the separate and independent privacy policies of such third parties. This Privacy Policy does not apply to any third party websites and we are not responsible for the content and activities of such websites operated by third parties. 5. How we collect personal data We collect your personal data in the following ways: 5.1 Information you provide directly to us when you contact us; 5.2 Information we receive from third parties (e.g. third party service providers); 5.3 Information we obtain in the course of our relationship and dealings with you; 5.4 Information collected through your use of our website and services; 5.5 Information gathered from open sources. 6. Residents of the European Economic Area (EEA) 6.1 In relation to personal data protected by the General Data Protection Regulation (GDPR), you have a range of legal rights in relation to the personal data you keep on our website, including: 6.1.1 Obtaining information about your processing of personal data and accessing personal data you have left on our website. Please note that in certain circumstances we have the right to refuse such requests to access copies of personal data (in particular information subject to legal professional privilege). 6.1.2 If your personal data is inaccurate or incomplete, you may request us to correct it. To do so, we may ask you to provide a copy of a valid identity document to prove the authenticity of your identification information. 6.1.3 In certain circumstances, you can ask us to delete your personal data. Please note that in some cases (e.g. for purposes of public interest, public health or scientific and historical research) we have the right to retain your personal data even if you ask us to delete it. 6.1.4 In some cases, you can object to the processing of your personal data and ask us to restrict the processing of your personal data. Similarly, in some cases, we have the right to refuse your request even if you object or ask us to restrict the processing of your personal data. 6.1.5 In certain circumstances, you can withdraw your consent to the collection and processing of your personal data. We also have the right to continue to use or process it without your permission if there are other legitimate reasons. 6.1.6 If you reside in the EEA and have a concern about our processing of your personal data that we are unable to resolve through our internal resolution process, you have the right to lodge a complaint with the data privacy authority in your place of residence. 6.2 We will assess all requests and complaints we receive and provide you with a timely response. We may ask you to provide copies of valid identification documents in order for us to comply with our security obligations and to prevent unauthorized disclosure of data. We have the right to charge you a reasonable administration fee if your request for access to data is manifestly unfounded or exceeds our obligations, or if you ask us to provide you with additional copies of your personal data. 6.3 In order to facilitate the provision of services to our customers located in the EEA, we request explicit consent for the transfer of personal data from the EEA outside of that area. If you are an individual located in the EEA and you refuse to consent to such transfers, you will no longer be able to use our website and services. You will still be able to withdraw your digital assets and fiat currencies from your account with us, but all other functionality will be disabled. 7. Cookie policy 7.1 When you visit our website, we record our performance and check the effectiveness of online advertising by using cookies, which are small pieces of data that are sent to your browser and stored on your computer's hard drive. Cookies are only sent to your computer's hard drive when you use your computer to access our website. 7.2 Cookies are commonly used to record the habits and preferences of visitors to our website. The information collected through cookies is non-registered collective statistical data and does not involve personal data. 7.3 Cookies enable our website or service provider's systems to recognize your browser and capture and remember information. They cannot be used to obtain data about your hard disk, your e-mail address or other personal data. Most browsers are set to accept cookies by default. you can choose to set your browser to refuse cookies or to notify you immediately when a cookie is loaded. However, if you set your browser to disable cookies, you may not be able to activate or use certain features of our website. 8. Purpose of use of information 8.1 We will use the information we collect for the following purposes or in the following ways: 8.1.1 To provide you with services through our website; 8.1.2 Verify and confirm your identity when you use our website or services; 8.1.3 Improving and upgrading services and websites (the information and feedback we receive helps us to improve our services and the functionality and performance of our websites so that we can respond more effectively to your queries and needs); 8.1.4 To keep statistical data related to the use of our website and for data analysis in cooperation with government agencies and public affairs organizations; 8.1.5 Personalize your experience (your information will help us better respond to your individual needs); 8.1.6 Facilitating Transactions (We will not sell, exchange, transfer, or otherwise make available your information, whether publicly available or not, to any other company without your consent, except expressly for the purpose of completing a transaction you have requested); 8.1.7 Regular emails (the email address you use to process your order may be used to receive information and updates about your order, as well as relevant newsletters, updates, information about related products or services, etc. that we may send you from time to time); 8.1.8 To contact you about matters relating to your account, including to request any additional information or documents; 8.1.9 Set up security measures to protect your account, including but not limited to two-factor authentication; 8.1.10 Assessing your credit risk; 8.1.11 Evaluate your risk score based on the parameters we determine; 8.1.12 Fraud risks are identified and mitigated; 8.1.13 Enforce/defend our rights; 8.1.14 Comply with applicable laws, regulations and/or orders as required by the competent authorities; 8.1.15 fulfillment of other purposes set forth in the Site User Agreement and all lawful means to fulfill such purposes. 8.2 We will not sell, trade or otherwise transfer your personal data, nor will we allow others to collect, use your personal data; however, we may disclose and transfer your personal data in the following circumstances: 8.2.1 Trusted third parties who manage our business or provide services to you, provided that those parties have agreed and taken appropriate measures to keep such information confidential; 8.2.2 When we believe that disclosure of the relevant information is appropriate or necessary in accordance with any applicable law, statute, regulation or order of a court or other competent authority, and is necessary to carry out the policies of our website and to ensure the proper operation of the website or related parties to provide the services or to protect ours or others' rights, property, or safety. 9. Protection of personal data 9.1 We take appropriate physical, electronic, managerial and technical measures to protect and maintain the security of your personal data. We will do our best to ensure that any personal data collected through our website is protected from nuisance by any third party not connected to us. The security measures we may take include, but are not limited to: 9.1.1 Physical measures: Your personal data records will be stored in a suitably locked place. 9.1.2 Electronic measures: Computer data containing your personal data will be stored on computer systems and storage media that are subject to strict log-in restrictions. 9.1.3 Regulatory measures: Only duly authorized staff members of our company have access to your personal data, and these staff members shall comply with our internal guidelines on the confidentiality of personal data. 9.1.4 Technical measures: Encryption techniques such as Secure Socket Layer encryption may be used to transmit your personal data. 9.1.5 Other measures: Our web servers are protected by appropriate "firewalls". 9.2 If you become aware of any security deficiencies on our website, please contact us immediately so that we can take appropriate action as soon as possible. 9.3 Despite the technical and security measures described above, we cannot guarantee the absolute security of the information transmitted via the Website and therefore we cannot guarantee that the personal data you provide to us via our Website will always be secure. We are not responsible for any loss or damage arising from any event that may occur as a result of unauthorized access to your personal data and we shall not be liable for such loss or damage. 10. Data retention 10.1 We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. 10.2 We will only retain personal data for as long as is reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements. We do not retain your personal data in a form that permits identification of the data subject for longer than is necessary for the legitimate purpose for which we originally collected the data, including the purpose of satisfying any legal, accounting or reporting requirements. 10.3 In order to determine the appropriate retention period for personal data, we take into account the volume, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes by other means, and applicable legal requirements. In some cases, we may anonymize your personal data so that it is no longer associated with you, in which case we will use such information without further notice to you. 10.4 At the end of the retention period, we will securely delete or destroy retained data and require our sub-processors or third party suppliers to do the same. 11. Minors 11.1 Our Site, Services and Products are not intended for persons who are defined as minors under applicable law. Accordingly, if you are under 18 years of age, please terminate all access to our Website and Services immediately. We reserve the right, but are not obligated, to request evidence for our review at any time to verify that you are 18 years of age or older. If you are under the age of 18, or if we reasonably suspect that you are under the age of 18 and you cannot prove otherwise, all purchases, if any, made by you from us through the use of our APIs, account registrations, website access, registrations, and subscriptions will terminate immediately and no refund of any kind will be provided to you. 11.2 It should be clarified that we do not knowingly collect personal data from minors, however, through the Internet, it is not possible for us to determine whether such persons are minors. It is therefore the responsibility of parents or guardians to ensure that their minors do not visit our website, use our website and/or services, download our apps, sign up for any of our events, download or access our related apps, send us e-mails, or provide us with personal data without the consent of their parents/guardians. If a parent or guardian discovers that his/her minor has accessed our website or provided us with personal data without his/her consent, he/she should contact us immediately at [email protected]. 12. Communication with us If you have any requests and comments, please e-mail us at [email protected] is the only valid and official email we have to communicate with you. Therefore, we cannot be held responsible for any losses arising from your failure to use valid contact information. 12.2 In the event of any dispute arising out of this Privacy Policy and your use of our website and services (dispute resolution and applicable law), you have to contact us at [email protected] so we can understand your concerns. We will do our best to resolve your concerns in a friendly and good faith manner.