PRIVACY POLICY

ZEST PROTOCOL LABS

Last Updated: 14th August 2024

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Thank you for visiting https://zestprotocol.com/ (the “Site“). The Site is owned and operated by Zest Protocol Labs Ltd (“Zest Protocol Labs”, “we,” “our,” or “us”).

This privacy notice (“Privacy Statement”) sets out the basis on which any Personal Information we collect from you (“you”, “your”, or “customer”), or that you provide to us, will be processed by us. By “Personal Information”, we mean any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your name, email address, username, contact details or any unique identifier such as an IP address, device ID or other online identifier.
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Capitalised terms that are not defined in this Privacy Statement shall have the meaning ascribed in our Terms of Service.

Please read the following carefully to understand what Personal Information we collect, how it is used and the ways it can be shared by us.

The data controller of your Personal Information is Zest Protocol Labs, an exempted company incorporated in the Cayman Islands.

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  1. Our Processing of Your Personal Information
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| Purpose | Personal Information From You | Personal Information From Devices | Legal Basis | |---|---|---|---| | Establish and maintain a commercial relationship with you (creation and management of your account with us, including dealing with your request to make account changes) | First name, last name, email address, username, password, country of residence, state/province, time zone | Technical information, including the Internet Protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform Information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site IP addresses, logs history | You are using us (Performance of a contract) | | Understand your needs and eligibility for products and services | Contact details | | | | Deliver our Services to you | User name, email address, digital wallet addresses, deposit and withdrawals, deposits addresses, balance history, bank statements, bank account numbers, personal information posted by user. | | | | Inform you about developments and products | Contact details | N/A | | | Administer the website, system administration and detecting usage patterns (including broad demographic information for aggregated use) | N/A | IP address, browser type, access times, URL requested and referral URL | We think we can (legitimate interest) | | Detection for troubleshooting purposes | N/A | Technical information, including the Internet Protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform Information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site | | | Comply with industry self-regulatory, audit and security requirements | Username, email address, full name and contact details, 2 forms of ID, picture signature, skype pseudo and call, bank accounts numbers, proof of residence, utility bill, tax statement, service bill, employment status, employer name and address, certificate of incorporation, business registration, article of association, ownership and control structure, directors, authorised signatories, authorised signature list, board minutes, officer and director list, name of UBO, certificate of good standing. | | | | Protect the right, property, safety of us, our clients or others | Any of the Personal Information in this table, talking into account necessity and data minimisation | N/A | | | Conduct surveys and get feedback from you | Contact details | N/A | | | Provide you with news and other matters of general interest to you as a Zest Protocol Labs customer | Email address | IP address, other technical information through cookies and other tracking technologies | You agree to it (Consent) | | Meet our legal and regulatory requirements, including checking your identity against money laundering and terrorist financing or answering your requests | Username, email address, full name and contact details, 2 forms of ID, picture, signature, skype pseudo and call, bank accounts numbers, proof of residence, utility bill, tax statement, service bill, employment status, employer name and address, certificate of incorporation, business registration, article of association, ownership and control structure, directors, authorised signatories, authorised signature list, board minutes, officer and director list, name of UBO, certificate of goods standing. | Technical information, including the Internet Protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform Information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site | Compliance with a legal requirement |


When we say that we think we can process your data, it is because we considered we have a legitimate interest (for ourselves or of a third party) to do so; it is in the interest of our organisation to conduct and manage our business; this includes protecting our interests and enforcing agreements with others, as well as comply with industry self-regulatory requirements. We might have legitimate interest to process Personal Information in other contexts. We ensure that we balance any potential impact on you and your rights before we process your Personal Information on that basis. 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. Please also consult the section “Your rights” below.
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It is important that the Personal Information We collect from You is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us. You can do so by lodging a customer support ticket. We will endeavour to effect those changes within a reasonable timeframe.

If you do not wish for your Personal Information to be used in the ways described within this Privacy Statement then you should not use the Site or use the services, functions, or features offered from time to time on the Site (“Services”). Where we need information from you to offer our Services, failure to provide such information will mean that you will not get access to the Services.
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  1. Security and Confidentiality
    1. Zest Protocol Labs is committed to protecting your privacy. Internally, only people with a business need to know Personal Information, or whose duties reasonably require access to it, are granted access to customers’ Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality. We audit our personal compliance regularly.
    2. The Site’s systems and data are reviewed periodically to ensure that you are getting a quality service and that leading security features are in place. We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
    3. Zest Protocol Labs takes all reasonable endeavours to protect and safeguard Personal Information, but there are protective measures you should take, as well. Do not share your Personal Information with others unless you clearly understand the purpose of their request for it and you know with whom you are dealing. Do not keep sensitive Personal Information in your e-mail inbox or on Webmail. If you are asked to assign passwords to connect you to your Personal Information, you should use a secure password and always use two-factor authentication (2FA), where available. You should change your password regularly.
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  2. What and with whom we share your Personal Information

As necessary, we will share your Personal Information with:

  1. Any member of our group, which means our direct or indirect subsidiaries, our ultimate holding company and any other subsidiary of that holding company, including their respective shareholders, directors, officers, affiliates, employees, contractors, agents, partners, insurers, and attorneys or representatives.
  2. Our service providers, to the extent necessary to supply the Services to you.
  3. Selected third parties, including analytics and search engine providers that assist us in the improvement and optimisation of the Services.
  4. Authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us (please refer to our Law Enforcement Requests Policy available here).
  1. We also disclose your Personal Information to third parties:some text
    1. If Zest Protocol Labs or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.
    2. If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of us, our clients, or others, including to defend ourselves from legal claims.
  2. You can find more information on the actual parties we are sharing your data with here. The list is updated regularly.
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  1. Transfers
    1. Your Personal Information will be stored in the Cayman Islands.
    2. Personal Information and other data may therefore be exported outside of the jurisdiction in which you reside. Your Personal Information may be processed and stored in a foreign country or countries. Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.
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  2. Data Retention

We have data retention and deletion policies designed to retain Personal Information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business needs. Because of those retention requirements, we might not be able to honour erasure requests.
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  1. Your rights
    1. All Customers

You may access and verify your Personal Information held by Zest Protocol Labs by submitting a customer support ticket or email to admin@zestprotocol.com or a written request to: admin@zestprotocol.com.

  1. No fee usually required

You will not have to pay a fee to access your Personal Information or to exercise any of your other rights. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

  1. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  1. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.
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  1. Changes to this Privacy Statement

Any changes we make to our Privacy Statement in the future will be posted on this page and, where material, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Statement.
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  1. Contact
    1. Questions, comments and requests regarding this Privacy Statement should be addressed to our customer support service or by email to admin@zestprotocol.com.
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  2. List of Third-Party Service Providers with whom Personal Information may be shared:

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| Party Name | Purpose | Data Disclosed | |---|---|---| | Cloud providers | For storage purposes. | User names, corporate documentation, dates of birth, identifying documentation, correspondence, transactional activity and analysis, financial information. | | Legal counsel | As part of attorney-client relationships, legal counselling and litigations | Any relevant account information, as the case may be. | | Wallet screening service | As part of their provision of money laundering reporting officers under the laws of the Cayman Islands | Any relevant account information, as the case may be. |