This Privacy Policy (this "Policy") is intended to explain how the operator, GTECH INTERNATIONAL GROUP LTD (the "Operator"), collects, uses, shares, discloses, and processes your personal data when you visit and use ZONE Wallet and other relevant services, including but not limited to the application (ZONE Wallet), this website (https://zonewallet.io) (this "Website"), any related APIs and third-party applications that rely on such API, or any other services provided by the Operator (collectively, the "Products and Services").
The Operator has the right to review, revise, and update this Policy regularly from time to time. You have an obligation to frequently check this Policy to ensure that you clearly understand the most updated version hereof. Should any revisions or updates be made hereto in accordance with any legal requirements, the Operator will amend this Policy in compliance with the law and notify you thereof in an appropriate manner.
Terms and phrases not defined in this Policy shall have the same meanings as defined in the ZONE Wallet User Terms.
1. Acceptance of this Policy
- By registering, accessing, or using the Products and Services or this Website, you acknowledge that you have carefully read and accept all terms and conditions set out in this Policy. If you access or use the Products and Services or this Website continuously or without interruption after any amendments and updates to this Policy become effective, it signifies that you are cognizant of and consent to accept all contents of such amended and updated Policy.
- You have the right to determine whether to provide your personal data and whether to exercise the rights described in "5. Your Choices and Rights Regarding Your Personal Data" of this Policy. However, if you choose not to provide your personal data or provide it incompletely, the Operator may be unable to offer or continue to provide the Products and Services or this Website to you, or may be unable to provide an enhanced product, service, or experience, or to conduct necessary audits and processing, resulting in the inability of the Operator to achieve the purposes of collecting your personal data (including but not limited to providing you with business dealings, accounts, or services in connection with the Operator and recommending and providing the Operator's products or services to you).
- If you have any concerns regarding the Operator's collection, processing, and use of your personal data, you may contact us directly through the contact information provided in Clause 12.
2. Categories and Purposes of Data Collection, Processing, and Use
- Categories of Personal Data Collected
In the course of your use of the Products and Services, the Operator will collect, process, use, and cross-border transfer data transmitted to the Products and Services from your computer, mobile phone, or other receiving devices, for the purposes set forth in this Policy. The data collected, processed, used, and cross-border transferred by the Operator includes, but is not limited to, the following categories:- Data provided by users for the purpose of identifying individuals, finance, or data related to personal descriptions, property, agreements, or contracts, etc., including but not limited to the following categories:
- Account Information: Your email address and password, etc.;
- Personal Data: Name, nationality, country of residence, date of birth, address, telephone number, etc.;
- Identity Verification Information: photos of National ID Card number, government-issued identity documents, passport, driver's license, selfies with the aforementioned identity documents, and other information required for tax or regulatory purposes, etc.;
- Financial Data: Bank account details, relevant billing information, sources of funds, property, income, earnings, assets, and investments, etc.;
- Automatically Collected Data
When you access or use the Products and Services via the Internet, the Operator may collect the following information:- Technical Information: IP address, browser information, login data, operating system and platform, time zone settings, etc.;
- Your Browsing Information: Includes the full clickstreams (with date and time) of uniform resource locators (URLs) that enter, pass through, and leave this Website; pages you viewed or searched for; browsing time for specific pages; page response times, download errors, interaction information on web pages (such as mouse scrolling, mouse clicking, and mouse hovering), and methods used to browse away from the page, etc.
When you browse this Website, the Operator may also use Cookies and web beacons to collect, process, use, or cross-border transfer related information; and - Geolocation Information: When you use or download the Products and Services, the Operator will receive real-time location information from your device.
- Social Media
You may choose whether to grant the Operator access to your certain personal data stored by third parties, such as social media websites (e.g., Facebook, Instagram, Google, Twitter, and any other third party). The data accessible to the Operator and ZONE Wallet may vary on each third-party website, depending on your privacy settings on the individual website or your authorization. If you connect a third-party managed account to your ZONE Wallet account and authorize the Operator to access such data, you acknowledge and agree that the Operator may collect, process, use, cross-border transfer, and store related data in accordance with this Policy. - Other
The Operator may also collect, process, use, or cross-border transfer your feedback on the Products and Services and any responses. When you use the Products and Services, for the purposes of preventing fraud, monitoring potential misuse of accounts, and identifying malware or other activities that may harm the Operator, the Products and Services, and their users, the Operator may also collect, process, use, or cross-border transfer data about your use of the Products and Services, your transactions and other activities on this Website, and may continue to collect, process, use, or cross-border transfer information about the name and type of the computer, mobile device, or other accessing devices you use. Furthermore, to the extent permitted by law, the Operator may collect, process, use, or cross-border transfer any other data you voluntarily provide to the Operator and the ZONE Wallet customer team, and other data detailed in, among others, the contracts/agreements (including but not limited to ZONE Wallet User Terms), application forms, declarations, terms of agreement, notices, consent letters, certificates, authorizations, confirmation letters, and confirmations (including written or electronic forms thereof) in connection with the Operator's services within its business scope, or any other categories of personal data required to be collected falling within the data collection purposes.
The aforementioned categories of personal data include, but are not limited to: 001 (identifiers of individuals), 002 (identifiers of finance), 003 (identifiers in government data), 011 (individual descriptions), 031 (home and facilities), 032 (property), 035 (leisure activities and interests), 036 (lifestyle), 083 (credit ratings), 102 (agreements or contracts), other personal data categories contained in the ZONE Wallet User Terms and this Policy, and any other personal data that falls within the scope of the specific purposes of data collection, processing, use, or cross-border transfer and within the categories of personal data under other related contracts, declarations, consent letters and the Taiwan Personal Data Protection Act or other applicable regulations.
- Under its know-your-customer (KYC) policy, the Operator will obtain your personal identification data from generally available sources such as third-party services or searches on the Internet, in a manner compliant with legal requirements.
- Data provided by users for the purpose of identifying individuals, finance, or data related to personal descriptions, property, agreements, or contracts, etc., including but not limited to the following categories:
- Personal data will be collected, processed, used, or cross-border transferred for the following specific purposes:
- To provide you with business dealings, accounts, or services in connection with the Operator, including but not limited to the Products and Services and this Website;
- To market and promote products or services offered by the Operator to you;
- In accordance with the laws of Taiwan, the Republic of China ("Taiwan") and the laws of the countries/jurisdictions of the Operator's group members (including laws, administrative orders, rulings and directives from competent authorities, regulations of relevant trade associations, or regulations, directions, and self-regulatory rules of exchanges, trading platforms, and similar institutions), as well as for the regulatory requirement to supervise financial, money laundering, and counter-terrorism financing activities, the personal data collected, processed, used, and cross-border transferred under statutory obligations, contracts or contract-like relationships, or other legal relations;
- The business as set forth in the registered business items or articles of incorporation of the Operator or for any other purposes as permitted by other laws;
- For the purposes necessary for the business or operational management of the Operator or its group management (including but not limited to user and customer management and service, marketing, providing information and communication services, database management, information security and management, e-commerce services, administrative research, customer background checks, surveys, statistical and research analysis, auxiliary and logistical support, risk management, joint marketing, execution of anti-money laundering operations, and cooperation with global counter-terrorism investigations);
- To conduct KYC procedures;
The aforementioned specific purposes include: 036 (deposits and remittances), 040 (marketing, including joint marketing activities of financial holding companies), 063 (collection, processing, and use of personal data by non-governmental agencies in accordance with statutory obligations), 069 (matters relating to contract, contract-like, or other legal relations), 090 (consumer and customer management and services), 094 (property management), 135 (information and communication services), 136 (information and database management), 137 (information security and management), 148 (online shopping and other e-commerce services), 154 (credit checks), 157 (surveys and statistical and research analysis), 181 (other business operations in accordance with registered business items or organizational bylaws), and any such other specific purposes as stipulated in the Personal Data Protection Act of Taiwan or other applicable laws (including but not limited to the Specific Purposes and Categories of Personal Data under the Personal Data Protection Act) and as required by the legal relationship created by you concerning the use of the Products and Services (including ZONE Wallet User Terms, this Policy, and other related documents such as contracts, declarations, and consent letters), in order to exercise and perform relevant rights and obligations, legal compliance, statutory obligations, detection and prevention of illegal activities, as well as any other specific purposes.
- You particularly understand and agree that the specific purposes for which the Operator collects, processes, uses, or cross-border transfers your personal data also include, but are not limited to, the following activities or actions:
- To provide the Products and Services and requested customer support;
- To assess and process your applications or transactions and send transaction-related notifications;
- To analyze your usage of the Products and Services;
- To develop and tailor the contents of the Products and Services based on your preferences;
- To resolve disputes, collect fees, and troubleshoot issues;
- To provide you with the handling, operation, use, management of, and the access to, the Products and Services;
- To send targeted marketing materials, updates on the Products and Services, and promotional offers based on your communication preferences;
- To dispose of de-identified personal data;
- To cross-reference your personal data with third-party databases to verify your identity;
- To comply with legal requirements (including but not limited to anti-money laundering and counter-terrorism financing purposes, or the purpose of performing agreements as per your arrangement with the Operator) ;
- To enhance the public interest as necessary;
- To avert danger to the life, body, liberty, or property of a data subject;
- To prevent serious harm to the rights of others;
- Where a public authority or academic research institution conducts statistical or academic research for the public interest as necessary, by using the data that has been processed by the provider or disclosed by the collector in a manner that does not identify any specific data subjects; and
- To carry out two or more of the foregoing activities in combination.
3. Processing and Use of Personal Data: Processers/Users, Duration, Region, and Method
- Users of Personal Data
- The Operator and its branches, subsidiaries, affiliates, other members of its group, and outsourced organizations, companies, and entities engaged by the Operator, as well as the organizations, companies and entities delegated by them;
- Institutions, companies, and entities with which contracts are entered into based on business needs (including but not limited to those specified in the ZONE Wallet User Terms, this Policy, other contracts, declarations, and consent letters);
- Competent authorities, administrative authorities, judicial authorities, tax authorities agencies, and institutions or other government authorities that are legally authorized to conduct investigations, with jurisdiction over the institutions, companies, and entities referred to in 3.1.1 and 3.1.2;
- Any recipients not restricted or prohibited by competent authorities from receiving cross-border transmitted data;
- Any other parties with whom the Operator has or intends to have transactions thereby necessitating the collection, processing, cross-border transfer, and use of personal data.
- Duration of Use of Personal Data
The longest of the following periods shall apply:- The duration for which the specific purposes for collecting personal data persist;
- The retention period prescribed by applicable laws;
- The retention period necessary for the performance of duties or business operations;
- The retention period stipulated in individual contracts or agreements regarding data preservation.
- Regions Where Personal Data Will Be Used
The locations of the aforementioned users of personal data (either inside or outside Taiwan). - Methods of Using Personal Data
In accordance with the Personal Data Protection Act of Taiwan or other applicable laws, as well as under the legal relationship created by you concerning the use of the Products and Services (including but not limited to the ZONE Wallet User Terms, this Policy, and other contracts, declarations, and consent letters, etc.), personal data shall be collected, processed, cross-border transferred, and used through automated or non-automated means (such as the use of electronic and paper documents, or other methods appropriate to then-current technological standards).
4. Storage and Protection of Personal Data
- The Operator may contract with third-party service providers to collect, process, use, cross-border transfer, store, and protect your personal data on its behalf.
- The Operator will store and process your personal and transaction information and data, including but not limited to payment information within Taiwan, at locations that may change from time to time based on the service providers used by the Operator ("Storage Locations"). The standards for privacy or personal data protection at Storage Locations may differ from those applicable to your place of residence, and according to local regulations, government authorities, courts, law enforcement, or competent authorities may access your personal data.
- The Operator will adopt appropriate security measures in accordance with relevant laws and regulations to prevent personal data from being stolen, altered, destroyed, lost, or leaked. However, please note that the Operator does not guarantee that the personal data you provide to us or we collect from you will be completely immune from any potential malicious attacks by hackers or computer experts, which could result in unauthorized access, disclosure, alteration, or destruction of personal data. In the event of any security incident such as a data breach that results in your personal data being stolen, leaked, altered, or otherwise compromised, the Operator will notify you of such incident in an appropriate manner after it has been identified and investigated in accordance with relevant laws and regulations.
- For the purpose of maintaining transaction security and other purposes relating to the provision of the Products and Services, the Operator should ensure the accuracy of the personal data you provide to us. If any inaccuracies are found in such data, the Operator will request your assistance in providing accurate information for supplementation and correction. Alternatively, the Operator may proactively search for data to correct and supplement any inaccuracies in a legal manner, and will notify you in an appropriate manner following such supplementation and correction.
- If the Operator ceases to use your personal data at your request or for other reasons (such as the termination of the Products and Services or the cessation of the Operator's business), except for the data that cannot be deleted due to legal requirements or the need for identity verification (such as mobile phone numbers or email addresses collected for KYC purposes), the Operator will delete the relevant personal data from the date it is no longer used.
5. Your Choices and Rights Regarding Your Personal Data
- With respect to your personal data collected, processed, and used by the Operator, you may exercise the rights set forth in this Clause in accordance with relevant laws and regulations or at your discretion. You may also decide to delete your account, which, however, may result in your inability to continue using the Products and Services and this Website, or may prevent the Operator from providing an enhanced product, service, or experience. Subject to applicable laws and other provisions of this Clause, you have the following rights:
- To inquire about or request access to, obtain a copy of, supplement, or correct personal data collected by the Operator;
- To request cessation of the collection, processing, or use of personal data collected by the Operator; and
- To request the Operator to delete all collected personal data, except for certain personal data that may not be deleted upon request under relevant laws and regulations.
- Requests to Inquire about Personal Data
- Within 15 days of receipt of a request for inquiry about or access to the relevant personal data it collects from you, or a request to obtain a copy thereof, the Operator will inform you whether it consents to such request and may charge you any necessary fees, unless such request might:
- Interfere with national security, diplomatic and military secrets, overall economic interests, or other significant national interests;
- Interfere with the execution of statutory duties by public authorities; or
- Affect material interests of the Operator or a third party.
- If necessary, the Operator will notify you in writing (either electronically or in paper form) of any extension of the aforementioned response period and the reasons for such extension; provided, however, that the period so extended shall not exceed 15 days from the end of the original period.
- Within 15 days of receipt of a request for inquiry about or access to the relevant personal data it collects from you, or a request to obtain a copy thereof, the Operator will inform you whether it consents to such request and may charge you any necessary fees, unless such request might:
- Supplementing and Correcting Personal Data
- You should appropriately elucidate the reasons for and facts about your request to supplement or correct relevant personal data collected from you by the Operator. Within 30 days of receipt thereof, the Operator will inform you whether it consents to such request.
- If necessary, the Operator will notify you in writing (either electronically or in paper form) of any extension of the aforementioned response period and the reasons for such extension; provided, however, that the period so extended shall not exceed 30 days from the end of the original period. You may contact the Operator using the contact information provided in this Policy to exercise the aforementioned rights.
6. Protection for Privacy of Minors
The Products and Services are not applicable to minors, and the Operator will not intentionally collect their personal data. If any such data is ever collected, it will be promptly deleted upon discovery.
7. Third-Party Analytics and Advertising
- To develop or improve the Products and Services, the Operator may contract with third-party service providers to research into and analyze your usage of the Products and Services on its behalf. Such third parties may obtain information relating to your use of the Products and Services by using Cookies and any other technologies.
- The Operator may allow third-party ad servers or ad networks to provide advertisements for the Products and Services as well as third-party services. These third-party ad servers or ad networks will use specific technologies to send advertisements and links related to the Products and Services directly to your browser, and therefore they will automatically receive your IP addresses. Such third parties may also use other technologies to assess the effectiveness of their advertisements and to provide personalized advertising contents.
- The Operator has no control over the Cookies and any other technologies used by the aforementioned third parties and whether they fully comply with this Policy. Except as otherwise provided by applicable law, this Policy does not apply to the behavior of these third parties in collecting, processing, and using your personal data, which should be governed by their own applicable privacy policies. You should gain your own access to these third parties' privacy policies to understand their terms.
- The Operator will not respond to "Do Not Track" signals and has no control over whether third parties will respond to such signals.
- The categories and purposes of the collection, processing, and use of the relevant personal data herein should be the same as those set forth in "2. Categories and Purposes of Data Collection, Processing, and Use."
8. Other Third Parties
In order to facilitate your use of and our improvement on the Products and Services, without infringing your rights and interests and in compliance with relevant regulations, the Operator may provide, share, or transfer your personal data for, with, or to the following third parties under the following circumstances:
- To deliver the Products and Services, it may be necessary for the Operator to share or transfer your personal data with or to certain third parties, including but not limited to its affiliates assisting it with operations such as payment collection, marketing, customer identity verification/KYC procedures, and technology services, or any other service providers determined at its reasonable discretion (i.e., not limited to its affiliates). By registering for or accessing the Products and Services, you shall be deemed to have consented to the sharing of your personal data with such entities by the Operator.
- In response to requests for administrative, judicial, or similar proceedings, the Operator may be required to disclose your personal data.
- Should the Operator intend to sell its business to or engage in mergers or acquisitions with a third party, resulting in the purchase, acquisition, or merger by such third party of or with the Operator and/or the business of the Products and Services, the Operator may share, transfer, or disclose your personal data with or to such third party. In the event of any merger, spin-off, dissolution, or other similar circumstances, the Operator may also transfer or assign such personal data to other third parties.
- The Operator may deem it necessary to disclose personal data in order to prevent physical harm or property damage, report suspected illegal activities, or investigate violations of the Operator's terms of service.
9. Links to Third-Party Websites
- The Operator has no control over the information security and privacy policies of other third-party websites or online resources linked by the Products and Services and thus cannot ensure their compliance with this Policy. This Policy applies only to the privacy and relevant policies and practices of ZONE Wallet, without covering other third-party websites or online resources outside of this Website. The Operator shall not be held accountable for the privacy policies and/or practices of such other websites or online resources. The security protection of your personal data on these third-party websites or online resources (or the lack thereof) shall, unless otherwise provided by applicable law, be governed by the applicable privacy or personal data protection policies of those third parties according to their use of your personal data, rather than by this Policy; therefore, you shall solely assume the risk of choosing to access such websites.
- To protect the information security and privacy of users of the Products and Services; if you have any relevant concerns, you are welcome to provide us with relevant comments and feedback regarding such websites.
10. Governing Law and Jurisdiction
This Policy shall be governed by, and construed in accordance with, the laws Taiwan, with respect to, including but not limited to, the validity, interpretation, performance, and enforcement of this Policy, or any dispute or controversy arising from or in connection with this Policy. Any dispute, controversy, inconsistency, claim, or issue regarding the breach, termination, or voidance of this Policy shall be subject to the exclusive jurisdiction of the Taiwan Taipei District Court as the court of first instance.
11. Miscellaneous
- The headings of each clause of this Policy are for convenience of reference only and shall not represent the interpretation of the substantive content of any clause.
- To the fullest extent permitted by law, the Operator may revise, update, suspend, or terminate this Policy at any time without giving prior notice to you.
- Revisions and updates to this Policy shall be made by means of posting on this Website, provided that the Operator may also make an announcement about it in such other ways as the Operator deems appropriate.
- If any relevant revisions hereto materially alter your rights, the Operator may also notify you thereof by posting them on this Website or by any other means permitted by applicable law (either electronically or in paper form).
- This Policy is made in Chinese. In the event of any discrepancy between the Chinese version and any other language version of this Policy, the Chinese version shall prevail.
12. Contact Information
If you have any questions about this Policy, please inform us by sending a message through the customer service system on this Website, or by writing to us at service@zonewallet.io.
(This English translation is for reference only. The Chinese version of the Privacy Policy shall prevail if there is any discrepancy between the English translation and the Chinese version of the Privacy Policy.)
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