zkSwap recognises the importance of protecting Personal Data and we are committed to complying with the EU GDPR and other applicable data protection laws. Please read this Policy so that you know and understand the purposes for which we collect, use, store and disclose Personal Data.
By accessing our Site or Services, interacting with us or providing your data to us, and subject to your rights at law, you accept and agree to these terms and conditions. If you do not agree with any aspect of this Policy, you should immediately discontinue access or use of the Site and Services.
This Policy supplements but does not supersede or replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which zkSwap may have at law to collect, use or disclose your Personal Data.
We may from time to time update this Policy to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time. Please check back regularly for updated information on the handling of your Personal Data.
For purposes of this Policy, "Personal Data" means any information that directly or indirectly identifies a particular individual, including any other information that is subject to applicable data protection laws.
This Policy applies to our collection, use and disclosure of Personal Data related to the Users of our Services, including on our Site or Platform. This Policy does not apply to job applicants or to zkSwap’s employees and non-employee contractors, whose Personal Data is subject to different privacy notices.
The Personal Data we collect varies depending upon the nature of the Services provided or used, and our interactions with individuals.
Types of Personal Data Collected. While the Personal Data we collect varies depending upon the circumstances and Services you use, we collect the following categories of information that may constitute Personal Data:
Sources of Personal Data. We may collect Personal Data:
We, and our authorised third parties, will only process your Personal Data where we have the legal grounds to do so. We may use Personal Data for a variety of purposes, as follows:
Where we have indicated above that we rely on legitimate interests for processing of Personal Data, we carry out assessments of likely adverse effects and if required a "balancing" test to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We may also carry out a data protection impact assessment for processing that is likely to result in a high risk to you. You can contact us for more details on our assessments using the details in the Contact Us section below.
Aggregate and De-identified Data.We may de-identify information and create anonymous and aggregated data sets and reports to assess, improve and develop our business, products and Services, prepare benchmarking reports on our industry and for other research and analytics purposes.
We may share or disclose the Personal Data we may collect as follows:
We ensure third parties who receive your Personal Data will handle your Personal Data as required by applicable data protection laws, such by putting in place appropriate contracts with third parties to protect your Personal Data.
Automated decisions are those made without human intervention that have a legal effect on you or other similarly significant effect. We do not carry out this type of processing activity.
You may indicate and choose your cookies preferences at any time through your browser settings, such as to accept certain cookies but reject others. Our policy relating to cookies complies with applicable laws. There are some internet activities that cannot take place without cookies collecting, using or disclosing Personal Data, such as those relating to security and network management. Necessary cookies also for example allow you to navigate back and forth between pages without losing your previous actions from the same session. For such necessary cookies, if you use our Site, you will be considered to have consented to the collection of Personal Data by such necessary cookies.
We will get your express consent where our cookies collect Personal Data in the course of internet activities which you have not clearly requested for, or where you have not voluntarily provided your Personal Data, or where Personal Data collected from such cookies are used for advertisements directed at you.
Following the Terms, our Services are restricted for Users under 18 years of age and they are not allowed to use our Services. zkSwap does not knowingly collect or maintain Personal Data from children we actually know at the time of collection are under the age of 18. Should we discover that we have collected Personal Data online from a child who is under 18, we will promptly delete that Personal Data. If you have concerns over the collection of children's Personal Data in our Services, please contact us at the information provided in the Contact Us section below.
The security of your Personal Data is important to us. We have put in place safeguards to protect the Personal Data we collect from unauthorised access, use and disclosure, and we take steps to ensure that all of our employees, agents, contractors and other third parties have similar adequate measures in place. We also have procedures to deal with any suspected Personal Data breach, and we will notify you and any applicable regulator when we are legally required to do so. However, we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your Personal Data safe, such as choosing a strong password and closing your web browser when you have finished using the Services.
We may transfer your Personal Data to countries outside of your home country. The privacy laws in countries outside your home country may be different from those in your home country.
For Users in EU. Where we transfer data to a country that has not been deemed to provide adequate data protection standards, we will always have security measures, approved EU model clauses or other adequate safeguards in place to protect your Personal Data.
For other Users. If we transfer your Personal Data to countries outside of your home country, we will take steps to comply with the requirements for such transfer in your home country as required by relevant law.
Our Services provide links to various websites operated by third parties including, but not limited to, third-party sites that display zkSwap trademarks. This Policy does not apply to third-party websites that are accessible through the Services, unless such website directs Users or visitors to this Policy. When you click on one of these links, you will be transferred out of the Services and connected to the website of the organisation or company that maintains that website. Even if an affiliation exists between our Services and a third-party website, we exercise no control over and assume no responsibility for linked websites. Each of these linked websites maintains its own independent privacy and data collection policies and procedures. We encourage you to read the privacy policies of those other websites to learn how they collect, use, share, and secure your information before providing any Personal Data.
Except to the extent prohibited by law, and subject to this Policy, we will retain and use your Personal Data for as long as it is needed to provide you with any Services, communications, information you have requested, or access to the Services, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. As soon as it is reasonable to assume your Personal Data is no longer needed or required, we will cease to retain your Personal Data.
By law, you have a number of rights when it comes to your Personal Data. Further information and advice about your rights can be obtained from the data protection regulator in your country. The rights you have depend on the jurisdiction in which you are based.
You may request for a copy of the Personal Data which we hold about you or information about the ways we use or disclose about your Personal Data. You may also ask us to correct or update your Personal Data, or withdraw your consent and request us to stop using or disclosing your Personal Data for any of the purposes stated in this Policy. You may do so by submitting your request in writing or via email at the contact details provided in the Contact Us section below. We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request in some circumstances.
We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.
Under Bulgarian regulations, your rights are:
This Policy is kept under regular review and may be updated from time to time. When we make changes to this Policy, we will change the "Updated" date above. If a material change is made to this Policy, we may choose to provide notice of such change, such as by providing notice through the Site or Platform, or through other communications.
It is important that the information we hold about you is accurate and current. Please keep us informed as soon as possible if your Personal Data changes or is inaccurate during your relationship with us by using the contact details set out below.
If you have any concern about our privacy practices, please contact us at [email protected].