Privacy Policy

We at Quasisoft Limited. (“Quasisoft”, “Company”, “we”, “us”, “our”) respect your privacy. This Privacy Policy (“Policy”) explains the privacy practices for the ZooBC mobile application (“App”). It also describes the rights and options available to you with respect to your information.

This Policy is combined into our User Agreement (the “Terms”) and is a part of them.

PERSONAL INFORMATION WE PROCESS

Initial Account Sign-up Information. To sign up to and create a user account on ZooBC, we may collect your email address.

Support Information. When you contact us for technical and customer support requests, we collect the information included in your request and in follow-up interactions we have with you. You do not have a legal duty to provide the above information. However, you will not be able to sign up to, and use the full functionalities of ZooBC, without providing the above information.

Survey Information. We may from time to time invite you to participate in surveys about your experience using ZooBC. If you agree to participate in a survey, we collect the information included in your answers to the survey.

Transaction Information. When you activate your ZooBC account, your public key and private key will automatically be created. They will be stored on your mobile device (“Device”). The blockchain will also collect information on all transactions connected to your public key created through ZooBC.

Device Information. We may collect information about your Device, including its model, its operating system, the browser you use, its version and language preferences, mobile network information, and the Internet Protocol (IP) address through which you accessed the App.

Analytics Information. We may use third-party tools to automatically record and collect analytics information about your use of ZooBC, including your session durations, the content you accessed on the App, your interactions and user-interface clicks, the frequency, and scope of your use of the App.

The overall personal information outlined above will be referred to as the “Information” or “Personal Information”.

CHILDREN’S PRIVACY

ZooBC is not intended for children under the age of 18. We do not knowingly or intentionally collect information about children who are under 13 years of age.

IF YOU ARE UNDER THE AGE OF 13 YOU MAY NOT USE THE APP IN ANY WAY.

HOW WE PROCESS AND USE PERSONAL INFORMATION

We may process your Information to operate ZooBC and provide you with its features and functionality.

We may use Analytics Information and Device Information to confirm your identity and prevent fraud.

We may process your Initial Account Sign-up Information, Transaction Information, and Analytics Information, to send you administrative notifications relating to ZooBC as well as promotional updates relating to ZooBC (“Promotional Communications”). You can control your notification settings and preferences through your Device setting.

Opt Out. You may also ‘opt-out’ of using your information for Promotional Communications at any time by sending an email to our support service at: info@zoobc.com. By doing so, we will only delete your Information from our mailing list, while we will continue to process your Information submitted to us which is necessary to provide you with our services.

We may process your Analytics Information to understand how users interact with ZooBC so that we can further develop and enhance ZooBC.

We may process your Initial Account Sign-up Information, Analytics Information, and Support information to provide you technical or customer support in response to inquiries on these topics.

We may process your information to contact you, from time to time, and invite you to participate in surveys about your experience using ZooBC. If you agree to participate in a survey, we use your answers to further enhance and develop ZooBC, or as otherwise explained in each particular survey.

WHEN AND HOW YOUR PERSONAL INFORMATION IS SHARED WITH OTHERS

We will not share your Information with third-parties, except in the events listed below or when you provide us your explicit and informed consent. 

We will share your Information with our service providers who assist us with the internal operations of ZooBC. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own promotional purposes. We do not sell your personal information to third parties.

If you use services provided by Third Party Platforms, such as purchasing crypto with fiat currency or locking funds into an interest bearing smart contract, ZooBC will share your digital wallet address with these Third Party Platforms in order to enable the transfer of crypto assets from and to your ZooBC wallet.

If you violated any applicable law, your Information will be shared with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling the violation.

If we are required to disclose your information by a judicial, governmental, or regulatory authority.

USE OF THIRD-PARTY PLATFORMS

ZooBC enables you to use services provided by Third Party Platforms, such as purchasing crypto with fiat currency or locking funds into an interest bearing smart contract. 

Your use of such Third Party Platforms and those Platforms’ use of your information are governed by their respective terms of use and privacy policy, not by this Policy. These platforms may go through the Know-Your-Client process with you, collect and process your information, execute their services, and send back the crypto assets to your ZooBC wallet. These services are fully operated by these Third Party Platforms, not ZooBC. Your personal data is collected by them and you will have to agree to their terms of service. They are the controller of your personal data that they process.

These Third-Party Platforms will not share the information you provide them with ZooBC. 

ZooBC will only share your digital wallet address with these Third PartyPlatforms in order to enable the transfer of crypto assets from and to your ZooBC wallet.

SECURITY AND INFORMATION RETENTION

We may retain Personal Information for the duration needed to support our ordinary business activities operating ZooBC. Thereafter, we will continue to retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims, and enforce our User Agreement.

We implement measures to reduce the risks of damage, loss of information, and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.

ADDITIONAL INFORMATION FOR USERS IN THE EU

Controller. Quasisoft Limited is the data controller of the personal data we process about you. Quasisoft’s address is 13/F., LKF 29, No. 29 Wyndham Street, Central, Hong Kong. 

EU Representative. Our European representative, for the purposes of this Policy, is Quasisoft Srl. If you are within the European Economic Area, you may contact our European representative at the following address: 

Quasisoft Srl Uninominale
Sestiere San Polo 2961
30125 Venezia (VE)

Legal Basis for Processing Your Data.

  • The legal basis under EU law for processing your Information for the purpose of operating ZooBC and providing its features is the performance of our Term of Use contract with you and our legitimate interests in the proper management and operation of ZooBC.
  • The legal basis under EU law for processing your Facial image Information is your explicit consent. 
  • The legal basis under EU law for processing your Information for the purpose of sending you notifications (including Promotional Communications) relating to ZooBC is our legitimate interests in informing users of administrative issues and encouraging user engagement with ZooBC.
  • The legal basis under EU law for processing your Information for the purpose of confirming your identity and preventing fraud is the performance of our Term of Use contract with you, our legitimate interests in keeping ZooBC free of fraudulent conduct, and our necessity for compliance with legal obligations.
  • The legal basis under EU law for processing Information to provide you technical or customer support is our legitimate interests in assisting our users on issues relating to their use of ZooBC.
  • The legal basis under EU law for processing Analytics Information to further develop and enhance ZooBC is our legitimate interests in fostering and advancing ZooBC.
  • The legal basis for collecting and processing Survey Information is your consent, as well as our legitimate interest in developing and enhancing ZooBC.
  • The legal basis for sharing your Information with competent authorities and with third parties for the purpose of handling violations is our legitimate interests in enforcing our legal rights.
  • The legal basis for disclosing your Information at the request of a judicial, governmental, or regulatory authority is our compliance with legal obligations to which we are subject. 
  • The legal basis for sharing your digital wallet address with Third Party Platforms is for the performance of your contract with these Third Party Platforms.
  • The legal basis for processing your Information for the purpose of notifying you or providing you with updates to this Policy is our necessity for compliance with legal obligations under the GDPR.

Cross-Border Data Transfers.

Information we collect from you will be processed by Quasisoft in Hong Kong. When we transfer your Information from within Europe to other jurisdictions outside Europe, we will do so by using adequate safeguards determined by the EU Commission.

EU Rights. If you are in the EU, you have the following rights under the GDPR:

  • Right to Access your Personal Information that we process and receive a copy of it. 
  • Right to Rectify inaccurate Personal Information we have concerning you and to have incomplete Personal Information completed.
  • Right to Data Portability, that is, to receive the Personal Information that you provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit this Information to another service provider. Where technically feasible, you have the right that your Personal Information is transmitted directly from us to the service provider you designate.
  • Right to Withdraw Consent to processing your Personal Information, at any time, where the processing is based on consent. If you do that, we will still process certain information on a legal basis other than consent, as described in this Policy. Withdrawing your consent will not affect the lawfulness of the data processing we carried out based on your consent before such withdrawal.
  • Right to Object, based on your particular situation, to use your Personal Information on the basis of our legitimate interests. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise, or defense of legal claims. You may also object at any time to the use of your Personal Information for direct marketing purposes.
  • Right to Restrict processing your Personal Information (except for storing it) if you contest the accuracy of your Personal Information, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the Personal Information and request instead to restrict its use; if we no longer need the Personal Information for the purposes outlined in this Policy, but you require them to establish, exercise or defend legal claims; or if you object to processing, pending the verification whether our legitimate grounds for processing overrides yours.
  • Right to be Forgotten. Under certain circumstances, such as when your right to object overrides our legitimate interests, you have the right to ask us to erase your Personal Information. However, we may still process your Personal Information if it is necessary to comply with a legal obligation, we are subject to under laws in EU Member States or for the establishment, exercise, or defense of legal claims.

If you wish to exercise any of these rights, contact us at info@zoobc.com.

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work, or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

CHANGES TO THIS PRIVACY POLICY

From time to time, we may change this Policy, in which case we will inform you of the updated Policy by emailing you if we have your email.

CONTACT US

Should you have any inquiries, complaints, or suggestions, you may contact us at info@zoobc.com. We will do our best to resolve your issue in a timely manner.

Last Update: January 8, 2021.