1. General Clauses

1.1. Present privacy policy (hereinafter “Privacy Policy”) describes how Zolvus Ltd. (hereinafter “Company”, “we”, “our”, or “us”) collects, uses, shares, and stores personal data of users of our website/-es: Website.

1.2. By using the Services, you accept the terms of this Privacy Policy and our Terms of Use, and consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy.

1.3. If you have not done so already, please also review our Terms of Use available on the Website.

1.4. This Privacy Policy explains how we will process personal data when providing our Services.

1.5. The up-to-date Privacy Policy is accessible at any time on the Website and prevails over any previous versions.

2. Data Controller

2.1. Zolvus Ltd (Reg. Nr.: 239047; Reg. Address: 103 Sham Peng Tong Plaza, Victoria, Mahé, Republic of Seychelles) is the data controller and responsible for User’s personal data.

2.2. Concerning any questions or requests, including any requests to exercise legal rights as a data subject, please use the details set out below:

2.2.1. Full name of the legal entity: Zolvus Ltd.
2.2.2. E-mail Address: [email protected]
2.2.3. Postal Address: 103 Sham Peng Tong Plaza, Victoria, Mahé, Republic of Seychelles

3. Personal Data Collected, Purposes and Legal Basis for data processing.

3.1. When You use the Website, Company processes Personal Data for purposes, each of them being duly legitimated by a valid legal basis.

3.2. Provision of Service. Company collects and processes your Personal Data for the use of the Service. This processing requires Company to collect and process the following Personal Data for the transfer and exchange of cryptocurrencies: username and information regarding the crypto asset transaction, including public key, exchanged through the Service or via an Application Programming Interface giving access to the Service to Third-Party end users. The legal basis on which Company relies for this purpose is the performance of a contract to which You are a party.

3.3. Review of Users Interaction with Service. Company is willing to understand how Users interact with its Service and need to process various browsing information resulting from Cookies which qualify as Personal Data, for the performance of analytic operation related to the Service use. The legal basis Company relies upon its legitimate interest which consists of (i) understanding the way its Website is browsed by Users and visitors (including You); and (ii) improving the Website, if needed.

3.4. Management of Requests. Company collects and processes your Personal Data for managing and following up any questions and/or requests You may submit. As such, please note that this processing is only carried out in the event You submit a question and/or request. Otherwise, your Personal Data is not processed for this purpose. This processing requires Company to collect and process the following categories of Personal Data: (i) identification data (i.e., your contact details) and (ii) the content of the message(s) You sent to Company as part of your question/request. While processing your Personal Data for this purpose, Company relies on its legitimate interest, which consists in duly managing its relationships with You.

3.5. You are under no obligation to provide the requested Personal Data. Nevertheless, Company draws to Your attention that, in such case, access to the Service may be altered, if not impossible.

3.6. To use the Service, You shall connect your own cryptocurrency wallet to the Service. However, your wallet stays under your sole control. Consequently, You acknowledge that the Service cannot collect any information from it. Moreover, You may, at any time, log off your Wallet from the Service.

3.7. In any event, and disregarding the processing purpose at stake, please note that Company will comply with a strict data minimization principle and will thus only collect and process Personal Data which is necessary for the above purposes.

4. Data Recipients

4.1. Company shares your Personal Data with Third-Party Service providers and suppliers which assist Company for fulfilling the purposes specified in this Privacy Policy. The service providers and suppliers may have access to Personal Data for the sole and exclusive purpose of carrying out the tasks assigned to them. Company ensures that the service providers and suppliers have sufficient guarantees for the performance of the tasks and comply with the applicable laws and regulations.

5. Data Storage

5.1. Company stores Personal Data for a limited duration, not exceeding the fulfilment of purposes described in Section 3 of this Privacy Policy.

5.2. For Provision of Service, Company will retain your Personal Data until the log-off of your wallet from the Service. Nevertheless, if Company needs to retain your Personal Data for evidence purpose beyond the date on which your wallet is logged off, the maximum retention period applicable will then be in line with the statute of limitation and will not exceed the period during which Company is required to retain evidence.

5.3. For Review of Users Interaction with Service, the cookies retention period is indicated below in this Privacy Policy.

5.4. For Management of Requests, Company will not retain your Personal Data for more than five (5) years following the last contact on your initiative.

5.5. Where Company considers it does not need to retain your Personal Data in its active database, it will archive it and will ensure that access thereto is restricted to a limited number of persons who have an actual need to access your Personal Data.

6. Data Transfer

6.1. Personal Data may be processed outside the European Union territory. In that situation, Company shall take all necessary precautions and alternatively or cumulatively ensure that an adequacy decision has been taken by the European Commission regarding the country of destination; that contractual clauses adopted by the European Commission or the supervisory authority have been signed with the recipient; that the recipient adheres to an approved code of conduct or certification mechanism.

7. Rights of Data Subject

7.1. As a data subject, You benefit from various rights regarding the processing of your Personal Data. These are as follows:

7.1.1. The Right to Opt-out. Stop sending You direct marketing communications which You have previously consented to receive (if any). Company may continue to send You Service-related and other non-marketing communications.

7.1.2. The Right to Access. Provide You with information about processing of Your personal data and give You access to your personal information.

7.1.3. The Right to Rectification. Update or correct inaccuracies in Your personal data.

7.1.4. The Right to Erasure. Erase Your personal data under certain conditions.

7.1.5. The Right to Restrict Processing. Restrict the processing of Your personal data under certain conditions.

7.1.6. The Right to Object to Processing. Object to our reliance on our legitimate interests as the basis of our processing of Your personal data that impacts Your rights.

7.1.7. Right to Transfer. Transfer a machine-readable copy of Your personal information to You or a third party of your choice.

7.1.8. Right to withdraw consent.

7.2. You can submit these requests by email [email protected]. Kindly note that none of these data subject rights are absolute and must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override a data subject request, the user will be informed of this by us along with the reasons for our decision.

7.3. Company may request specific information from You to help us confirm Your identity and process Your request.

7.4. Users normally don’t have to pay a fee to exercise their rights as a data subject. However, Company may charge a reasonable fee if a request is clearly unfounded, repetitive, or excessive. Alternatively, Company may refuse to comply with requests in the above circumstances.

7.5. We try to respond to all legitimate requests within the period of one month from receipt of the request. Occasionally, it may take us longer than a month if a request is particularly complex or a number of requests have been made. In this case, we will give notification within four weeks and keep customers updated on the handling of their request.

8. Cookies

8.1. A cookie (hereinafter “Cookies”) is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the Cookie to you. Some of the Cookies will only be used if you use certain features or select certain preferences, and some Cookies will always be used.

8.2. Web beacons, tags, and scripts may be used in the Website or in emails to help us deliver Cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our service/analytics providers on an individual and aggregated basis.

8.3. We may link the information collected by Cookies with other information we collect from you pursuant to this Privacy Policy and use the combined information as set forth herein. Similarly, the third parties who serve cookies on our Website may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information.

8.4. The maximum storage period for Cookies is thirteen (13) months from the time they are placed on your browser or Equipment. At the end of this period, new consent will be required.

8.5. You can always set your browser not to accept cookies or even remove Cookies from your browser. However, in a few cases, some of the Website features may not function properly or even may become inaccessible as a result.

To learn more about how to control cookie settings through your browser:

For more information about cookies, please visit: https://www.aboutcookies.org/.

Third-party advertising networks, like Google and others, permit users to opt out of or customize preferences associated with your internet browsing. To learn more about this feature from Google, click here.

Flash Cookies, which from time to time may be used by Website, are not controlled by your browser and relevant settings. In order to manage Flash Cookies settings, click here.