Privacy Policy
Last updated
October 20, 2023
This privacy notice for
ZK INNOVATION LIMITED
(doing business as
ZK Wallet
)
(
'we', 'us', or 'our'
), describes how and why we might collect, store, use,
and/or share (
'process'
) your information when you use our services (
'Services'
), such as when you:
- Visit our website
at https://www.zkinnovations.com , or any website of ours that links to this privacy notice
- Download and use
our mobile application ( ZK WALLET) , or any other application of ours that links to this privacy notice
- Engage with us in other related ways, including any
sales, marketing, or events
Questions or concerns? Reading
this privacy notice will help you understand your privacy rights and choices. If you do not agree
with our policies and practices, please do not use our Services. If you still have any questions
or concerns, please contact us at
[email protected]
.
SUMMARY OF KEY POINTS
This summary provides key points from our
privacy notice, but you can find out more details about any of these topics by clicking the link
following each key point or by using our table of
contents below to find the section you are looking
for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how
you interact with us and the Services, the choices you make, and the products and features you use.
Learn more about personal information you disclose to us.
Do we process any sensitive personal
information?
We do not process sensitive personal information.
Do we receive any information from third
parties?
We do not receive any information from third parties.
How do we process your information? We
process your information to provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process your information for
other purposes with your consent. We process your information only when we have a valid legal reason
to do so. Learn more about how we process your
information.
In what situations and with which
parties do we share personal information?
We may share information in specific situations and with specific
third parties. Learn more about
when and with whom we share your personal
information.
How do we keep your information safe? We
have
organisational
and technical processes and procedures in place to protect your personal information. However, no
electronic transmission over the internet or information storage technology can be guaranteed to be
100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorised
third parties will not be able to defeat our security and improperly collect, access, steal, or
modify your information. Learn more about
how we keep your information safe.
What are your rights? Depending on where
you are located geographically, the applicable privacy law may mean you have certain rights
regarding your personal information. Learn more about your privacy
rights.
How do you exercise your rights? The
easiest way to exercise your rights is by
submitting a
data subject access
request
, or by contacting us. We will consider and act upon any request in accordance with applicable data
protection laws.
Want to learn more about what we do with any information we
collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In
Short: We collect personal
information that you provide to us.
We collect personal information that you voluntarily
provide to us when you
register on the Services,
express an interest in obtaining information
about us or our products and Services, when you participate in activities on the Services, or
otherwise when you contact us.
Sensitive Information.
We do not process sensitive information.
Application Data. If you use our
application(s), we also may collect the following information if you choose to provide us with
access or permission:
We will
use and retain the collected personal
information as needed to provide the
Services or for:
To submit a
request to
exercise
these
rights described
above, please
email
[email protected]
or
submit
a data
subject access
request
.
To submit a request to
exercise
these
rights described above,
please email
[email protected]
or
submit a data
subject access
request
.
To submit a request to
exercise
these
rights described
above, please email
[email protected]
or
submit a data
subject access
request
.
'Consumer'
means a natural
person who is a
resident of the
Commonwealth acting
only in an
individual or
household context.
It does not include
a natural person
acting in a
commercial or
employment context.
'Personal
data'
means any
information that is
linked or reasonably
linkable to an
identified or
identifiable natural
person.
'Personal data'
does not include
de-identified data
or publicly
available
information.
'Sale
of personal data'
means the exchange
of personal data for
monetary
consideration.
You
may contact us by
email at
[email protected]
or
submit a data
subject access
request
.
ZK
INNOVATION
LIMITED
International
House, 64 Nile St,
London N1 7SR, UK
London
,
England
N1 7SR
United Kingdom
You have the right
to request access
to the personal
information we
collect from you,
change that
information, or
delete it.
To request to
review, update, or
delete your
personal
information,
please
fill out and
submit a
data
subject
access
request
.
- Mobile Device Data. We automatically collect
device information (such as your mobile device ID, model, and manufacturer), operating system,
version information and system configuration information, device and application
identification numbers, browser type and version, hardware model Internet service provider
and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using
our application(s), we may also collect information about the phone network associated with
your mobile device, your mobile device’s operating system or platform, the type of mobile
device you use, your mobile device’s unique device ID, and information about the features of
our application(s) you accessed.
- Push Notifications. We may request to send
you push notifications regarding your account or certain features of the application(s). If
you wish to opt out from receiving these types of communications, you may turn them off in
your device's settings.
This information is primarily needed to maintain the
security and operation of our application(s), for troubleshooting, and for our internal
analytics and reporting purposes.
All personal information that you provide to us
must be true, complete, and accurate, and you must notify us of any changes to such personal
information.
Information automatically collected
In
Short: Some information —
such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our
Services.
We automatically collect certain information when
you visit, use, or navigate the Services. This information does not reveal your specific
identity (like your name or contact information) but may include device and usage information,
such as your IP address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, information about how and when
you use our Services, and other technical information. This information is primarily needed to
maintain the security and operation of our Services, and for our internal analytics and
reporting purposes.
Like many businesses, we also collect information
through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data
is service-related, diagnostic, usage, and performance information our servers automatically
collect when you access or use our Services and which we record in log files. Depending on
how you interact with us, this log data may include your IP address, device information,
browser type, and settings and information about your activity in the
Services (such as the date/time stamps associated with your usage, pages
and files viewed, searches, and other actions you take such as which features you use),
device event information (such as system activity, error reports (sometimes called
'crash dumps' ), and hardware settings).
- Device Data. We collect device data
such as information about your computer, phone, tablet, or other device you use to access
the Services. Depending on the device used, this device data may include information such as
your IP address (or proxy server), device and application identification numbers, location,
browser type, hardware model, Internet service provider and/or mobile carrier, operating
system, and system configuration information.
- Location Data. We collect location data
such as information about your device's location, which can be either precise or imprecise.
How much information we collect depends on the type and settings of the device you use to
access the Services. For example, we may use GPS and other technologies to collect
geolocation data that tells us your current location (based on your IP address). You can opt
out of allowing us to collect this information either by refusing access to the information
or by disabling your Location setting on your device. However, if you choose to opt out, you
may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process
your information to provide, improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply with law. We may also process
your information for other purposes with your
consent.
We process your personal information for
a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and
authentication and otherwise manage user accounts. We may process your
information so you can create and log in to your account, as well as keep your account in
working order.
- To
save or protect an individual's vital
interest. We may process your
information when necessary to save or protect an
individual’s vital interest, such as to prevent
harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In
Short: We only process your
personal information when we believe it is
necessary and we have a valid legal reason (i.e.
legal basis) to do so under applicable law, like
with your consent, to comply with laws, to provide
you with services to enter into or
fulfil
our contractual obligations, to protect your
rights, or to
fulfil
our legitimate business interests.
If you
are located in the EU or UK, this section
applies to
you.
The General
Data Protection Regulation (GDPR) and UK GDPR
require us to explain the valid legal bases we rely
on in order to process your personal information. As
such, we may rely on the following legal bases to
process your personal information:
- Consent. We
may process your information if you have given us
permission (i.e.
consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Legal
Obligations. We may process your
information where we believe it is necessary for
compliance with our legal obligations, such as
to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal
rights, or disclose your information as evidence
in litigation in which we are involved.
- Vital
Interests. We may process your
information where we believe it is necessary to
protect your vital interests or the vital
interests of a third party, such as situations
involving potential threats to the safety of any
person.
If
you are located in Canada, this section
applies to you.
We may
process your information if you have given us
specific permission (i.e.
express consent) to use your personal information
for a specific purpose, or in situations where
your permission can be inferred (i.e.
implied consent). You can
withdraw your
consent at any
time.
In some
exceptional cases, we may be legally permitted
under applicable law to process your information
without your consent, including, for
example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For
investigations and fraud detection and
prevention
- For
business transactions provided certain
conditions are met
- If it is
contained in a witness statement and the
collection is necessary to assess, process, or
settle an insurance claim
- For
identifying injured, ill, or deceased persons
and communicating with next of kin
- If we
have reasonable grounds to believe an individual
has been, is, or may be victim of financial
abuse
- If it is
reasonable to expect collection and use with
consent would compromise the availability or the
accuracy of the information and the collection
is reasonable for purposes related to
investigating a breach of an agreement or a
contravention of the laws of Canada or a
province
- If
disclosure is required to comply with a
subpoena, warrant, court order, or rules of the
court relating to the production of records
- If it
was produced by an individual in the course of
their employment, business, or profession and
the collection is consistent with the purposes
for which the information was produced
- If the
collection is solely for journalistic, artistic,
or literary purposes
- If the
information is publicly available and is
specified by the regulations
In
Short: We may share
information in specific situations described
in this section and/or with the following
third parties.
We
may need to share your personal information in the
following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- When we
use Google Maps Platform APIs. We may
share your information with certain Google Maps
Platform APIs (e.g.
Google Maps API, Places API). We obtain and store on your device ( 'cache' ) your location for three (3) months. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.
In
Short: We may
use cookies and other tracking
technologies to collect and store your
information.
We may use
cookies and similar tracking
technologies (like web beacons and
pixels) to access or store information.
Specific information about how we use
such technologies and how you can refuse
certain cookies is set out in our Cookie
Notice
.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In
Short: We
keep your information for as long as
necessary to
fulfil
the purposes outlined in this privacy
notice unless otherwise required by
law.
We will
only keep your personal information for
as long as it is necessary for the
purposes set out in this privacy notice,
unless a longer retention period is
required or permitted by law (such as
tax, accounting, or other legal
requirements).
No purpose in this notice will require
us keeping your personal information for
longer than
the period of time in which users have
an account with us
.
When we
have no ongoing legitimate business need
to process your personal information, we
will either delete or
anonymise
such information, or, if this is not
possible (for example, because your
personal information has been stored in
backup archives), then we will securely
store your personal information and
isolate it from any further processing
until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In
Short: We aim
to protect your personal information
through a system of
organisational
and technical security measures.
We have
implemented appropriate and reasonable
technical and
organisational
security measures designed to protect
the security of any personal information
we process. However, despite our
safeguards and efforts to secure your
information, no electronic transmission
over the Internet or information storage
technology can be guaranteed to be 100%
secure, so we cannot promise or
guarantee that hackers, cybercriminals,
or other
unauthorised
third parties will not be able to defeat
our security and improperly collect,
access, steal, or modify your
information. Although we will do our
best to protect your personal
information, transmission of personal
information to and from our Services is
at your own risk. You should only access
the Services within a secure
environment.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In
Short:
In
some regions, such as
the European Economic Area (EEA),
United Kingdom (UK), Switzerland, and
Canada
, you have rights that allow you
greater access to and control over
your personal
information.
You
may review, change, or terminate your
account at any time.
In some
regions (like
the EEA, UK, Switzerland, and Canada
), you have certain rights under
applicable data protection laws. These
may include the right (i) to request
access and obtain a copy of your
personal information, (ii) to request
rectification or erasure; (iii) to
restrict the processing of your personal
information; (iv) if applicable, to data
portability; and (v) not to be subject
to automated decision-making. In certain
circumstances, you may also have the
right to object to the processing of
your personal information. You can make
such a request by contacting us by using
the contact details provided in the
section
'
HOW CAN
YOU CONTACT US ABOUT THIS
NOTICE?
'
below.
We will
consider and act upon any request in
accordance with applicable data
protection laws.
If you are
located in the EEA or UK and you believe
we are unlawfully processing your
personal information, you also have the
right to complain to your
Member
State data protection
authority
or UK
data protection
authority.
If you are
located in Switzerland, you may contact
the Federal
Data Protection and
Information
Commissioner.
Withdrawing
your consent: If we are
relying on your consent to process your
personal information,
which may be express and/or implied
consent depending on the applicable law,
you have the right to withdraw your
consent at any time. You can withdraw
your consent at any time by contacting
us by using the contact details provided
in the section
'
HOW CAN
YOU CONTACT US ABOUT THIS
NOTICE?
'
below
.
However,
please note that this will not affect the
lawfulness of the processing before its
withdrawal nor,
when applicable law allows,
will it affect the processing of your
personal information conducted in reliance
on lawful processing grounds other than
consent.
Account Information
If you
would at any time like to review or change
the information in your account or
terminate your account, you can:
-
Log in to your account settings and update your user account.
Upon your
request to terminate your account, we will
deactivate or delete your account and
information from our active databases.
However, we may retain some information in
our files to prevent fraud, troubleshoot
problems, assist with any investigations,
enforce our legal terms and/or comply with
applicable legal
requirements.
Cookies
and similar
technologies: Most Web
browsers are set to accept cookies by
default. If you prefer, you can usually
choose to set your browser to remove
cookies and to reject cookies. If you
choose to remove cookies or reject
cookies, this could affect certain
features or services of our Services.
If you
have questions or comments about your
privacy rights, you may email us at
[email protected]
.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web
browsers and some mobile operating
systems and mobile applications include
a Do-Not-Track (
'DNT'
) feature or setting you can activate to
signal your privacy preference not to
have data about your online browsing
activities monitored and collected. At
this stage no uniform technology
standard for
recognising
and implementing DNT signals has been
finalised
. As such, we do not currently respond
to DNT browser signals or any other
mechanism that automatically
communicates your choice not to be
tracked online. If a standard for online
tracking is adopted that we must follow
in the future, we will inform you about
that practice in a revised version of
this privacy notice.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In
Short: If you
are a resident of
California
, Colorado
,
Connecticut
, Utah
or Virginia
, you are granted specific rights
regarding access to your personal
information.
What
categories of personal information do
we
collect?
We have
collected the following categories of
personal information in the past twelve
(12) months:
| Category | Examples | Collected |
|
A.
Identifiers
|
Contact
details, such as real name,
alias, postal address, telephone
or mobile contact number, unique
personal identifier, online
identifier, Internet Protocol
address, email address, and
account
name
|
|
|
B.
Personal information as defined
in the California Customer
Records
statute
|
Name,
contact information, education,
employment, employment history,
and financial
information
|
|
|
|
Gender
and date of
birth
|
|
|
|
Transaction
information, purchase history,
financial details, and payment
information
|
|
|
|
Fingerprints
and
voiceprints
|
|
|
|
Browsing
history, search history, online
|
|
|
|
Device
location
|
|
|
|
Images
and audio, video or call
recordings created in connection
with our business
activities
|
|
|
|
Business
contact details in order to
provide you our Services at a
business level or job title,
work history, and professional
qualifications if you apply for
a job with
us
|
|
|
|
Student
records and directory
information
|
|
|
|
Inferences
drawn from any of the collected
personal information listed
above to create a profile or
summary about, for example, an
individual’s preferences and
characteristics
|
|
|
|
|
|
- Category B
-
As long as the user has an account with us
We
may also collect
other personal
information
outside of these
categories through
instances where
you interact with
us in person,
online, or by
phone or mail in
the context
of:
- Receiving
help through our
customer support
channels;
- Participation
in customer
surveys or
contests;
and
- Facilitation
in the delivery
of our Services
and to respond
to your
inquiries.
How
do we use and
share your
personal
information?
Learn
about how we use your
personal information
in the section,
'
HOW
DO WE PROCESS YOUR
INFORMATION?
'
Will
your information
be shared with
anyone
else?
We
may disclose your
personal
information with
our service
providers pursuant
to a written
contract between
us and each
service provider.
Learn more about
how we disclose
personal
information to in
the section,
'
WHEN
AND WITH WHOM DO
WE SHARE YOUR
PERSONAL
INFORMATION?
'
We
may use your
personal
information for
our own business
purposes, such as
for undertaking
internal research
for technological
development and
demonstration.
This is not
considered to be
'selling'
of your personal
information.
We
have not
disclosed, sold,
or shared any
personal
information to
third parties for
a business or
commercial purpose
in the preceding
twelve (12)
months.
We will
not sell or share
personal
information in the
future belonging
to website
visitors, users,
and other
consumers.
California Residents
California
Civil Code Section
1798.83, also known as
the
'Shine The Light'
law permits our users
who are California
residents to request
and obtain from us,
once a year and free
of charge, information
about categories of
personal information
(if any) we disclosed
to third parties for
direct marketing
purposes and the names
and addresses of all
third parties with
which we shared
personal information
in the immediately
preceding calendar
year. If you are a
California resident
and would like to make
such a request, please
submit your request in
writing to us using
the contact
information provided
below.
If
you are under 18 years
of age, reside in
California, and have a
registered account
with the Services, you
have the right to
request removal of
unwanted data that you
publicly post on the
Services. To request
removal of such data,
please contact us
using the contact
information provided
below and include the
email address
associated with your
account and a
statement that you
reside in California.
We will make sure the
data is not publicly
displayed on the
Services, but please
be aware that the data
may not be completely
or comprehensively
removed from all our
systems (e.g.
backups, etc.).
CCPA
Privacy
Notice
This
section applies only
to California
residents. Under the
California Consumer
Privacy Act (CCPA),
you have the rights
listed
below.
The
California Code of
Regulations defines
a
'residents'
as:
(1)
every individual who
is in the State of
California for other
than a temporary or
transitory purpose
and
(2)
every individual who
is domiciled in the
State of California
who is outside the
State of California
for a temporary or
transitory
purpose
All
other individuals
are defined as
'non-residents'.
If
this definition of
'resident'
applies to you, we
must adhere to
certain rights and
obligations
regarding your
personal
information.
Your
rights with
respect to your
personal
data
Right
to request
deletion of the
data — Request
to
delete
You
can ask for the
deletion of your
personal
information. If
you ask us to
delete your
personal
information, we
will respect your
request and delete
your personal
information,
subject to certain
exceptions
provided by law,
such as (but not
limited to) the
exercise by
another consumer
of his or her
right to free
speech, our
compliance
requirements
resulting from a
legal obligation,
or any processing
that may be
required to
protect against
illegal
activities.
Right
to be informed —
Request to
know
Depending
on the
circumstances, you
have a right to
know:
- whether
we collect and
use your
personal
information;
- the
categories of
personal
information that
we collect;
- the
purposes for
which the
collected
personal
information is
used;
- whether
we sell or share
personal
information to
third
parties;
- the
categories of
personal
information that
we sold, shared,
or disclosed for
a business
purpose;
- the
categories of
third parties to
whom the
personal
information was
sold, shared, or
disclosed for a
business
purpose;
- the
business or
commercial
purpose for
collecting,
selling, or
sharing personal
information;
and
- the
specific pieces of
personal information
we collected about
you.
In
accordance with
applicable law, we
are not obligated
to provide or
delete consumer
information that
is de-identified
in response to a
consumer request
or to re-identify
individual data to
verify a consumer
request.
Right
to
Non-Discrimination
for the Exercise
of a Consumer’s
Privacy
Rights
We
will not
discriminate
against you if you
exercise your
privacy
rights.
Right
to Limit Use and
Disclosure of
Sensitive Personal
Information
We
do not process
consumer's sensitive
personal
information.
Verification
process
Upon
receiving your
request, we will
need to verify
your identity to
determine you are
the same person
about whom we have
the information in
our system. These
verification
efforts require us
to ask you to
provide
information so
that we can match
it with
information you
have previously
provided us. For
instance,
depending on the
type of request
you submit, we may
ask you to provide
certain
information so
that we can match
the information
you provide with
the information we
already have on
file, or we may
contact you
through a
communication
method (e.g.
phone or email)
that you have
previously
provided to us. We
may also use other
verification
methods as the
circumstances
dictate.
We
will only use
personal
information
provided in your
request to verify
your identity or
authority to make
the request. To
the extent
possible, we will
avoid requesting
additional
information from
you for the
purposes of
verification.
However, if we
cannot verify your
identity from the
information
already maintained
by us, we may
request that you
provide additional
information for
the purposes of
verifying your
identity and for
security or
fraud-prevention
purposes. We will
delete such
additionally
provided
information as
soon as we finish
verifying
you.
Other
privacy
rights
- You
may object to
the processing
of your personal
information.
- You
may request
correction of
your personal
data if it is
incorrect or no
longer relevant,
or ask to
restrict the
processing of
the
information.
- You
can designate an
authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
- You
may request to
opt out from
future selling
or sharing of
your personal
information to
third parties.
Upon receiving
an opt-out
request, we will
act upon the
request as soon
as feasibly
possible, but no
later than
fifteen (15)
days from the
date of the
request
submission.
To
exercise these
rights, you can
contact us
by submitting
a
data
subject access
request,
by email at
[email protected]
,
or
by referring to the
contact details at the
bottom of this
document. If you have
a complaint about how
we handle your data,
we would like to hear
from
you.
Colorado Residents
This
section applies only
to Colorado
residents. Under the
Colorado Privacy Act
(CPA), you have the
rights listed below.
However, these
rights are not
absolute, and in
certain cases, we
may decline your
request as permitted
by law.
- Right
to be informed
whether or not we
are processing
your personal
data
- Right
to access your
personal
data
- Right
to correct
inaccuracies in
your personal
data
- Right
to request
deletion of your
personal
data
- Right
to obtain a copy
of the personal
data you
previously shared
with us
- Right
to opt out of the
processing of your
personal data if
it is used for
targeted
advertising, the
sale of personal
data, or profiling
in furtherance of
decisions that
produce legal or
similarly
significant
effects (
'profiling' )
If
we decline to take
action regarding
your request and you
wish to appeal our
decision, please
email us at
[email protected]
. Within forty-five
(45) days of receipt
of an appeal, we
will inform you in
writing of any
action taken or not
taken in response to
the appeal,
including a written
explanation of the
reasons for the
decisions.
Connecticut Residents
This
section applies only
to Connecticut
residents. Under the
Connecticut Data
Privacy Act (CTDPA),
you have the rights
listed below.
However, these
rights are not
absolute, and in
certain cases, we
may decline your
request as permitted
by law.
- Right
to be informed
whether or not we
are processing
your personal
data
- Right
to access your
personal data
- Right
to correct
inaccuracies in
your personal
data
- Right
to request
deletion of your
personal
data
- Right
to obtain a copy
of the personal
data you
previously shared
with us
- Right
to opt out of the
processing of your
personal data if
it is used for
targeted
advertising, the
sale of personal
data, or profiling
in furtherance of
decisions that
produce legal or
similarly
significant
effects (
'profiling' )
If
we decline to take
action regarding
your request and you
wish to appeal our
decision, please
email us at
[email protected]
. Within sixty (60)
days of receipt of
an appeal, we will
inform you in
writing of any
action taken or not
taken in response to
the appeal,
including a written
explanation of the
reasons for the
decisions.
Utah Residents
This
section applies only
to Utah residents.
Under the Utah
Consumer Privacy Act
(UCPA), you have the
rights listed below.
However, these
rights are not
absolute, and in
certain cases, we
may decline your
request as permitted
by law.
- Right
to be informed
whether or not we
are processing
your personal
data
- Right
to access your
personal
data
- Right
to request
deletion of your
personal
data
- Right
to obtain a copy
of the personal
data you
previously shared
with us
- Right
to opt out of the
processing of your
personal data if
it is used for
targeted
advertising or the
sale of personal
data
Virginia Residents
Under
the Virginia
Consumer Data
Protection Act
(VCDPA):
If
this definition of
'consumer'
applies to you, we
must adhere to
certain rights and
obligations
regarding your
personal data.
Your
rights with
respect to your
personal
data
- Right
to be informed
whether or not we
are processing
your personal
data
- Right
to access your
personal
data
- Right
to correct
inaccuracies in
your personal
data
- Right
to request
deletion of your
personal
data
- Right
to obtain a copy
of the personal
data you
previously shared
with us
- Right
to opt out of the
processing of your
personal data if
it is used for
targeted
advertising, the
sale of personal
data, or profiling
in furtherance of
decisions that
produce legal or
similarly
significant
effects (
'profiling' )
Exercise
your rights
provided under the
Virginia
VCDPA
If
you are using an
authorised
agent to exercise
your rights, we may
deny a request if
the
authorised
agent does not
submit proof that
they have been
validly
authorised
to act on your
behalf.
Verification
process
We
may request that you
provide additional
information
reasonably necessary
to verify you and
your consumer's
request. If you
submit the request
through an
authorised
agent, we may need
to collect
additional
information to
verify your identity
before processing
your request.
Upon
receiving your
request, we will
respond without
undue delay, but in
all cases, within
forty-five (45) days
of receipt. The
response period may
be extended once by
forty-five (45)
additional days when
reasonably
necessary. We will
inform you of any
such extension
within the initial
45-day response
period, together
with the reason for
the
extension.
Right
to
appeal
If
we decline to take
action regarding
your request, we
will inform you of
our decision and
reasoning behind it.
If you wish to
appeal our decision,
please email us at
[email protected]
. Within sixty (60)
days of receipt of
an appeal, we will
inform you in
writing of any
action taken or not
taken in response to
the appeal,
including a written
explanation of the
reasons for the
decisions. If your
appeal is denied,
you may contact the
Attorney
General to
submit a
complaint.
11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In
Short: You
may have
additional rights
based on the
country you reside
in.
Australia and New Zealand
We
collect and process
your personal
information under
the obligations and
conditions set by
Australia's Privacy
Act 1988
and
New Zealand's
Privacy Act 2020
(Privacy Act).
This
privacy notice
satisfies the notice
requirements defined
in
both Privacy Acts
, in particular:
what personal
information we
collect from you,
from which sources,
for which purposes,
and other recipients
of your personal
information.
If
you do not wish to
provide the personal
information
necessary to fulfill
their applicable
purpose, it may
affect our ability
to provide our
services, in
particular:
- offer
you the products
or services that
you want
- respond
to or help with
your
requests
- manage
your account with
us
- confirm
your identity and
protect your
account
At
any time, you have
the right to request
access to or
correction of your
personal
information. You can
make such a request
by contacting us by
using the contact
details provided in
the section
'
HOW
CAN YOU REVIEW,
UPDATE, OR
DELETE THE DATA
WE COLLECT FROM
YOU?
'
If
you believe we are
unlawfully
processing your
personal
information, you
have the right to
submit a complaint
about
a breach of the
Australian Privacy
Principles to the Office
of the
Australian
Information
Commissioner
and
a breach of New
Zealand's Privacy
Principles to the Office
of New Zealand
Privacy
Commissioner
.
Republic of South Africa
At
any time, you have
the right to request
access to or
correction of your
personal
information. You can
make such a request
by contacting us by
using the contact
details provided in
the section
'
HOW
CAN YOU REVIEW,
UPDATE, OR
DELETE THE DATA
WE COLLECT FROM
YOU?
'
If
you are unsatisfied
with the manner in
which we address any
complaint with
regard to our
processing of
personal
information, you can
contact the office
of the regulator,
the details of which
are:
General
enquiries: [email protected]
12. DO WE MAKE UPDATES TO THIS NOTICE?
In
Short: Yes,
we will update
this notice as
necessary to
stay compliant
with relevant
laws.
We
may update this
privacy notice
from time to time.
The updated
version will be
indicated by an
updated
'Revised'
date and the
updated version
will be effective
as soon as it is
accessible. If we
make material
changes to this
privacy notice, we
may notify you
either by
prominently
posting a notice
of such changes or
by directly
sending you a
notification. We
encourage you to
review this
privacy notice
frequently to be
informed of how we
are protecting
your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If
you have questions
or comments about
this notice, you
may
email us at
[email protected]
or
contact us
by post
at:
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Talk to us
Customer Support
We take pride in offering excellent customer support. Should you have any questions or need assistance, our dedicated support team is here to help. You can reach us through: