Privacy Policy

1. Introduction

ZennaCoin (hereinafter referred to as "Company," "we," "us," or "our") is dedicated to upholding the privacy rights of our users and ensuring the security of your personal data. This Privacy Policy ("Policy") outlines our data protection practices regarding the collection, processing, usage, and disclosure of your Personal Information when you access our website, mobile application, or utilize our cryptocurrency trading and financial services (collectively, the "Services").

This Policy has been drafted in compliance with global data protection standards. By registering for, accessing, or using the Services, you consent to the data practices described in this Policy.

2. Information We Collect

We collect information required to provide our Services efficiently and to comply with applicable financial regulations, including Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws.

2.1 Information You Provide

• Identity Data: Full legal name, date of birth, nationality, gender, and government-issued identification (e.g., passport, driver’s license, national ID).
• Contact Data: Residential address, email address, and mobile telephone number.
• Financial Data: Bank account details, payment card information, and tax identification numbers.
• Employment & Wealth Data: Source of funds, source of wealth, occupation, and investment experience (required for compliance purposes).
• Biometric Data: Facial recognition data or selfies provided during the identity verification (KYC) process.

2.2 Information Collected Automatically

• Device Information: Hardware model, operating system, unique device identifiers (IMEI/UDID), MAC address, and mobile network information.
• Online Activity: IP address, browser type, access times, pages viewed, and the page you visited before navigating to our Services.
• Geo-Location Data: Real-time location data derived from your IP address or GPS (with your permission) to prevent fraud.

2.3 Blockchain and Transaction Information

• Transaction History: We collect details of transactions you carry out through the Services, including amounts, trade history, and timestamps.
• Wallet Information: Public wallet addresses and blockchain transaction hashes.

Note: Please be aware that blockchain transactions are public and immutable. We cannot conceal or delete data once it is written to the blockchain.

3. Legal Basis and Usage of Information

We process your personal data based on the following legal grounds:

• Contractual Necessity: To provide the Services you requested (e.g., executing trades, processing withdrawals).
• Legal Obligation: To comply with regulatory requirements (e.g., AML/KYC laws, tax reporting).
• Legitimate Interests: To improve our platform, prevent fraud, and ensure network security.

We use your information specifically to:

• Onboard users and verify identities in compliance with regulatory standards.
• Facilitate cryptocurrency transactions and fiat currency processing.
• Detect, prevent, and investigate fraudulent or illegal activities.
• Provide customer support and resolve technical disputes.
• Deliver service updates, security alerts, and administrative messages.
• Analyze usage trends to optimize platform performance.

4. Automated Decision Making and Profiling

We may utilize automated processing for certain functions, such as identity verification and transaction monitoring. For example, our systems may automatically flag suspicious transactions that deviate from your usual patterns. You have the right to request a manual review of any decision made solely based on automated processing that significantly affects you.

5. Disclosure of Information

We do not sell your Personal Information. We may share your data in the following strict circumstances:

• Third-Party Service Providers: With vendors who provide services such as identity verification (KYC), payment processing, data analytics, and cloud hosting. These providers are contractually obligated to protect your data.
• Legal and Regulatory Authorities: When required by a subpoena, court order, or similar legal procedure, or when we believe in good faith that disclosure is necessary to prevent physical harm or financial loss or to report suspected illegal activity.
• Corporate Affiliates: With our parent company, subsidiaries, or joint ventures for operational purposes.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, user data may be transferred as a business asset.

6. The Public Nature of Blockchain

You acknowledge that when you use our Services, certain information may be written to a public blockchain. Data stored on a blockchain is public, immutable, and indelible. ZennaCoin has no control over public blockchains and cannot delete or modify data once it has been confirmed on the network.

7. Data Security

We employ enterprise-grade security measures to protect your data, including:

• Encryption: Data is encrypted in transit (TLS/SSL) and at rest (AES-256).
• Access Controls: Strict role-based access controls for internal employees.
• Cold Storage: The majority of user funds are held in offline cold storage wallets.
• 2FA: Mandatory Two-Factor Authentication for sensitive account actions.

While we strive to use commercially acceptable means to protect your Personal Information, no method of transmission over the Internet is 100% secure.

8. Data Retention

We retain your Personal Information only for as long as is necessary for the purposes set out in this Policy.

• Regulatory Retention: We are required by law to retain financial and KYC records for a minimum period (typically 5 to 7 years) after you close your account, to comply with anti-money laundering and tax laws.
• Deletion: Once the retention period expires, your data is securely deleted or anonymized.

9. International Data Transfers

ZennaCoin operates globally. Your information may be transferred to, stored, and processed in countries outside your country of residence. We ensure that such transfers are conducted in compliance with applicable laws, utilizing safeguards such as Standard Contractual Clauses (SCCs) where necessary.

10. Your Data Protection Rights

Depending on your jurisdiction, you may have the following rights:

• Right to Access: Request copies of your personal data.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your data (subject to legal retention requirements).
• Right to Restrict Processing: Request that we limit the processing of your data.
• Right to Portability: Request transfer of your data to another organization.

To exercise these rights, please submit a formal request to our Data Protection Officer at the contact details below.

11. Cookies and Tracking

We use cookies and similar technologies to enhance user experience. For detailed information on the cookies we use and how to manage your preferences, please refer to our Cookie Policy.

12. Updates to This Policy

We reserve the right to modify this Privacy Policy at any time. Material changes will be communicated via email or a prominent notice on our platform. The "Last Updated" date at the top of this Policy indicates when the latest revisions were made.

13. Contact Us

If you have questions regarding this Policy or our data handling practices, please contact our Data Protection Office: