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Z Y L O Privacy Policy 

Introduction

Protecting your privacy is a top priority for us. We are dedicated to safeguarding the confidentiality, security, and privacy of the personal information we possess, adhering strictly to relevant laws and regulations. We also have a strong commitment to ensuring that each of our agents, service providers, and workers fulfils these duties. This policy outlines how we handle personal data within our organization, including processing user data related to our services and interactions on our website, zylo.digital (Fractal Digital Ventures LLP)​

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Before we offer our products and services to you or gather your personal data, we always refer to this Privacy Policy. By using Zylo services, providing personal data, or utilizing any of our products or services, you acknowledge and agree that:

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  • You understand and consent to our procedures for processing personal data as outlined in this Privacy Policy, subject to periodic updates.

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  • If you have provided us with personal data concerning another individual, you:

    • have a right to provide that information;

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  • If you have provided personal data regarding another individual, you must ensure that you have provided a copy of this privacy policy, as updated from time to time, to that person, as well as to us and;

    • each such person has agreed to those terms.

How is data collected?

We obtain personal data about you through the following means:

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  • You provide us with your personal data through several channels, including using Zylo's services on our website, submitting queries, requests, or job applications to us, responding to our surveys, or utilizing our products and services;

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  • We receive your personal data from third parties who are authorized to disclose that information to us;

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  • We obtain your data from public sources, including public blockchains, registries, and your publicly available social media profiles;

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  • We gather your personal data through automated methods, such as tracking your interactions with our websites and mobile applications.

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In some cases, we may be required by law to collect certain types of personal data about you.​

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Typically, we collect personal data directly from you. However, in certain instances, we may obtain personal data from third parties, including your representatives, contractors providing services to us, or third parties who refer you to us based on their belief that you may be interested in our products or services.

How do we use the data?

We handle your personal data based on the following legal grounds and for the following purposes:

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  • We process your personal data based on our contractual obligations to provide you with our products and services. This includes customer support, communication regarding the Website or our offerings, and activities necessary before entering into an agreement with you. For these purposes, we process the following personal data:

    • ​​Personal identification information we collect may include your full name (first, middle, last), date of birth, gender, ID documents like passport, Aadhaar, PAN, non-signature IDs, signature, photographs, tax ID, utility bills, nationality, employer, job title.​

    • ​Contact details (e.g. e-mail address, phone number, home and work address);

    • Financial information (e.g. bank account numbers, IFSC code and other banking-related details);​​​​

    • Communication data includes records of our interactions with you, encompassing any messages or communications you send to us.​

    • ​Blockchain-related information when applicable (e.g. blockchain identifiers, such as blockchain addresses and public keys);

    • ​Transaction information (e.g. transactions you make on our platform, including the name of the recipient, the amount of the transaction and the time stamp);

    • ​Online identifiers (e.g. geolocation, IP address, browser fingerprint, browser name and version and OS); and

    • Other information that may be present on documentation that we may ask you to provide for the purposes of proving your identity.

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  • Without this information, we may be unable to offer you our products or services, including all their features and functionality, or to address queries or requests you submit to us.

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  • We process your personal data based on our legal obligations, including fulfilling requirements under the law and our obligations related to Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) regulations. This may involve properly identifying you, monitoring your use of our website, products, and services, and transmitting data to regulatory authorities as required.

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  • We process data obtained from your use of Zylo services based on our legitimate interests. This includes enhancing user experience on the website and with our products and services. Activities such as improving our website, products, and services, conducting market analysis and research, providing education and training for our staff, and planning and forecasting business activities are part of this effort. Our legal basis is our legitimate interest in enhancing ZYLO Services and our business, resulting in improved user experience. We use the data in an aggregated manner, considering the nature of the information, and believe that your interests or fundamental rights and freedoms do not outweigh our legitimate interests.

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  • We may also process your personal data to protect our rights, such as establishing, exercising, and defending legal claims, as well as for debt collection purposes. The legal basis for this processing is our legitimate interest in safeguarding our legal rights and ensuring the fulfillment of agreements between us. In these instances, we believe that our legitimate interests outweigh any potential impact on your interests or fundamental rights and freedoms.

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  • According to applicable data protection regulations, you have the right to object to the processing of your personal data that is based on legitimate interests (refer also to the "Your Rights" section below).

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  • We may also process your personal data based on your consent, such as for direct marketing purposes, including sending you our newsletter. You can withdraw your consent at any time by using the ‘unsubscribe’ link provided at the end of each email. Please note that withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal. For specifics on how we use your personal data for direct marketing, please refer to the "Direct Marketing" section below.

People to whom we disclose personal data

We only share your personal data when we have a valid reason for it and when we are legally permitted to do so.

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  • Data processors. We use carefully selected service providers (data processors) in processing your personal data. We only use service providers that provide sufficient guarantees to implement appropriate technical and organizational security measures to protect your personal data. We have concluded appropriate data processing agreements with the service providers and shall remain responsible for their actions in respect of the processing of your personal data.

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  • Third parties. In some circumstances, we also share your personal data with third parties who act as independent data controllers as regards your personal data. We only share your personal data with third parties if stipulated herein, if required under the applicable law (e.g. when we are obliged to share personal data with the authorities), or with your consent.

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  • We also may need to share your personal data with third persons in relation to our need to protect our legal rights (e.g. attorneys and debt collection agencies). The legal basis for this is our legitimate interest to protect our legal rights and ensure the performance of the agreement. In such case, your interests or fundamental rights and freedoms do not override our legitimate interests.

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  • We may disclose your personal data to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. The legal basis for this is our legitimate interest to exercise our right to business. In such case, we make sure that your rights and conditions as a data subject shall not be decreased, in which case your interests or fundamental rights and freedoms do not override our legitimate interests.

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  • Additionally, we may share your personal data with other third persons in order to fulfil our legal obligations (e.g. auditors, authorities). The legal basis for such sharing is compliance with our legal obligations.

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  • Furthermore, we will share your data with your representatives, advisers and others you have authorised to interact with us on your behalf. Please note, that we consider such authorisation as your consent and therefore your request for such an activity must be present to us in a written form.

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  • We will never sell your personal data to any third party.

Direct Marketing

If you have consented to receive information about our products or services, and those of our partners, we may occasionally use your personal data for direct marketing purposes. We send materials and offers that we believe would be of interest to you. You can opt out of receiving marketing communications from us at any time by clicking the ‘unsubscribe’ link at the bottom of each email or contacting us at connect@zylo.digital.​

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To determine which offers would interest you, we create a profile based on the following information:

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  • Identity, such as your name and date of birth;

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  • Contact information, phone number, postal address and email address;

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  • Information regarding our products and services portfolio, as well as demographic data that we hold periodically.​

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We may use your personal data to promote the following products and/or services to you:​

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  • Purchasing and/or exchanging Virtual Digital Assets;

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  • Software and hardware wallets for holding Virtual Digital Assets;

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  • Other products or services related to Virtual Digital Assets.

Security

We implement suitable technical and organizational security measures to protect your personal data, considering factors such as the latest technology, implementation costs, the nature and scope of processing, and the risks posed to you.

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Retention of personal data​

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We keep your personal data for as long as needed to fulfill the purposes for which it was collected, to protect our rights, or as required by law. In some cases, we may retain your personal data for several years after our relationship ends to safeguard our rights or comply with legal obligations. If your personal data serves multiple purposes, we adhere to the longest applicable retention period.​

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In general, we store your personal data as follows:

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  • Information regarding legal transactions between us is retained for the duration of our agreement and for an additional 10 years from the date a claim arises, unless otherwise stipulated by law. We may occasionally request you to update your personal data during this period;

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  • We retain billing information for 7 years from the end of the financial year in which the information was provided to us;

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  • All other data is retained for 5 years.

 

 

​Access, correction and your other rights​

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Under applicable data protection regulations, you have various rights as a data subject regarding your personal data. These rights include:​

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  • Request access to your personal data;

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  • Obtain a copy of your personal data;

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  • Rectify inaccurate or incomplete personal data;

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  • Erase personal data;

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  • Restrict the processing of personal data;

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  • Portability of personal data;

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  • Object to processing of personal data which is based on legitimate interest and personal data which is processed for direct marketing purposes.​

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Please note that while you have rights as a data subject, these rights are not absolute and may be subject to limitations as permitted by applicable law.​

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To exercise your rights regarding your personal data, please contact us at legal@zylo.digital. Some rights, like reviewing and updating your information, can be managed by logging into your account. We have procedures in place to verify your identity to protect the security and confidentiality of your information. In certain circumstances and as permitted by law, we may charge an administration fee for providing access to requested information, and we will inform you of any charges beforehand. If we are unable to fulfill your request due to legal constraints, such as protecting the privacy of others or maintaining confidentiality, we will provide an explanation for our decision.

 

 

​Changes to this policy

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We may update this policy periodically to reflect changes in our practices, procedures, or to comply with new laws, regulations, case-law, or guidelines from competent authorities. If the changes are significant and affect you, we will notify you via email and through a pop-up on our website. The most recent version of this policy will always be accessible on our website.

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Governing law​

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If you are a data subject in India or the processing of your personal data takes place in the context of an agreement you have concluded with Fractal Digital Ventures LLP of India, the processing of your personal data shall be governed by the laws of the Republic of India.​​​

This Z Y L O Privacy Policy is effective from 14th June, 2024.

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