Privacy Policy

This Version of ZERO21 Privacy Policy is valid from 4th day of July 2024.

ZERO21 LTD is a Limited Company registered in Cyprus with a registered address MALEMA COURT, Floor 4, Flat/Office 41, Evangelistrias 16, 3031 Agias Zonis, Limassol (Hereinafter: ZERO21 or Company).

Company is committed to protect and respect your privacy in compliance with EU General Data Protection Regulation (GDPR) 2016/679 and also with applicable United States Privacy Act as amended from time to time. ”You” means you as a customer, a potential customer, our customer’s employee or other relevant person such as our customer’s authorized representative, director or beneficial owner as well as our customer’s customer when using our services. This Privacy Policy explains how the Company collects and uses your personal data. It also describes your rights towards Company and how to exercise them.

Company process individuals’ personal data for several reasons. Company processes your personal data in the capacity of the data controller.

Persons under the age of 16 cannot provide any personal data. If you are a person below the age of 16, before any activities on this site you must obtain the consent of your legal guardians (parents, adoptive parents, guardians, careers).

The terms used in this Privacy Policy are understood as defined in the EU General Data Protection Regulation (GDPR) 2016/679.

This Privacy Policy explains the following:

  1. What personal data we collect and how your personal data is collected
  2. How we may use your personal data and the lawful basis for doing so
  3. Who we may disclose your personal data to
  4. How we protect your personal data
  5. Your GDPR Rights
  6. Your USA Privacy Rights
  7. Cookies
  8. How long we keep your personal data
  9. Changes to this Privacy Policy
  10. How to contact us
  11. Do You Need Extra Help?
1. What personal data we collect and how your personal data is collected

In order to provide our services we need to process your personal data as described below. In the course of our business, we collect personal data in a variety of ways. We collect personal data directly from data subjects, via data subject’s usage of this site, of our service and through our customers. You may directly or indirectly give us information about yourself in a variety of ways, such as when you contact us, use our portal or any other service of ours where you submit personal data.

Personal data we collect:

  1. Personal and contact information: name, date of birth, national identification number, government identification numbers such as: driver’s license, state identification, passport, social security or tax identification number, address, e-mail address, mobile and landline telephone number, title, billing and shipping address. We are under legal obligation to collect documentation of such information, for example in the form of copies of your passport or driver’s license
  2. Payment information: bank account number, invoice information, credit and debit card data
  3. Historical information: your purchase and payment acceptance history
  4. Financial information: your income, turnover, negative payment remarks, type of agreement, transactional data
  5. Information on goods/services: details about the items you purchase
  6. Information related to legal requirements: country of taxation or foreign tax payer reference, customer due diligence and anti - money laundering requirements
  7. Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
  8. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number
  9. Geo-Location Information, some devices allow applications to access real-time location-based information (for example GPS). Our applications may collect such information from your device at any time while you download or use our services. We may use this information to optimize your experience

Special categories of data:

Company collects and processes biometric data (a photocopy of a passport or other personal document with a photo) as a special category of personal data only in the case we are under legal obligation to collect such data and when the data subject has given explicit consent to the processing of those personal data

Personal data we may collect from third parties:

We may collect your personal data from third party services either publicly available or engaged by us to verify you against sanction lists (EU, UN sanction lists or OFAC lists) and registers held by tax authorities, company registration agencies and other commercial or non-commercial information providers on beneficial owners and politically exposed persons. We also collect information from remitters, shops, banks, payment service providers and others. Our legal basis for collecting, processing, and sharing such information about you with third party services as explained in this paragraph is fulfilling our legal obligations, such as preventing, detecting and investigating money laundering, terrorist financing and fraud prevention.

2. How we may use your personal data and the lawful basis for doing so

We use your personal data for a variety of reasons and based on different legal basis.

Collecting personal data based on consent:

We may use your personal data to send you marketing communication which you requested. These may include information about our products and services, events, activities and promotions of our associated partners’ products or services. This communication is subscription based and requires your consent. The collection of personal data is based on consent, the data subject will give his/her consent by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consent will always be stored and documented in our system. If you have given consent to the processing of your personal data, you can always withdraw the consent by sending the e-mail to the e- mail address given below in the contact details (see “How to contact us” below). Withdrawal of consent does not affect the admissibility of processing before the withdrawal. In case of withdrawal of consent, we will not process your data, unless we have legal obligation for processing. We will respond to each request as soon as possible, and in any case no later than within 30 days of receiving the request.

Collecting personal data based on contractual necessity:

We use your personal data for fulfilling our contractual obligations towards you. It is impossible for us to perform our service to you without collecting and processing your personal data (contractual necessity as legal basis). Examples of contractual necessity as legal basis for your personal data collection and processing are opening an account with us, processing and/or initiating payment transactions using our services, receiving settlements from us, invoicing, etc.

Collecting personal data based on legal obligations:

In some cases we are under legal obligation to process your personal data as part of our KYC requirements, preventing, detecting and investigating money laundering, terrorist financing and fraud prevention, sanction screening, reporting to tax authority, police authorities, supervisory authorities, payment service requirements.

We may also send you information about the products and services that you have purchased from us, and replies to a “Contact me” or other web forms you have completed on our website. We will follow up on incoming requests (customer support, emails, chats or phone calls). We will notify you of every disruption to our services (system messages).

We also have a legitimate interest to use profiling when monitoring transactions in order to detect fraudulent transactions. Profiling is any form of automated processing of personal data in the form of analysis and assessment of specific aspects. Based on that analysis, some cases of atypical behavior can be established, which are then examined, one by one, in order to determine whether fraudulent transactions exists or not.

Please keep in mind that We will not be able to provide our services to you in case you fail to provide the necessary personal data as described in this Privacy Policy.

3. Who we may disclose your personal data to

We do not share, sell, rent or trade your personal data with any third parties without your consent, except from what is described below:

  1. Our affiliates, including companies within the Company group.
  2. Merchants

We may share with the merchant at which you made your purchase the personal data necessary for the merchant’s performance, support and administration of your order, including disputes. The personal data shared with the merchant will be subject to the merchant's privacy policies and practices.

  1. Third party service providers

We may pass your personal data on to our suppliers, acquirers, payment service providers, banks, clearing and settlement mechanisms and other business partners if necessary for providing our service to you. Before sharing your personal data, we will always ensure that we respect relevant financial industry secret obligation. For example, if you have asked us to transfer funds, we need to disclose certain information to fulfill such transfer.

  1. Authorities

We disclose personal data to authorities to the extent we are under statutory obligation to do so. Such authorities may include tax authorities, police authorities, AML authorities, law enforcement authorities and supervisory authorities in relevant countries.

  1. Sub-contractors (processors and sub- processors)

We may use sub-contractors (data processor) to process personal data on our behalf, we are responsible for making sure they commit themselves to adhere to this Privacy Policy and applicable data protection legislation (GDPR) by signing the Data Processing Agreement. You can obtain further information about specific companies indicated in this section that could be provided with your personal data by reaching us using the contact details provided in this Privacy Policy.

  1. Third country transfer

We may transfer personal data to organizations outside the EU/EEA area. If the sub-contractor (data processor) processes personal data outside the EU/EEA area, these transfers are subject to special rules under European and UK data protection law and such processing is done in accordance with the EU Standard Contractual Clauses for transfer to third countries. We may transfer personal data to organizations outside the USA area. If the sub-contractor (data processor) processes personal data outside the USA area, these transfers are subject to special rules and such processing is done in accordance with the Standard Contractual Clauses for transfer to third countries.

If you would like further information, please contact us (see “How to contact us” below).

4. How we protect your personal data

Company has taken a number of steps in order to provide an extremely secure service. We use appropriate technical, organizational and administrative security measures to protect any information we hold from loss, misuse, unauthorized access, disclosure, alteration and destruction. The information is encrypted using secure socket layer technology (SSL) and is stored with AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards. Where we have provided you (or where you have chosen) a password or access code which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share any passwords with anyone, you authorize the Company to act upon instructions and information from any person that enters your user ID or password. Please note that once you leave our website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy.

5. Your GDPR Rights

You have the following rights in regard to your personal data:

  1. Right of Access

You have the right to request information about whether we process your personal data, access to that data and all other data related to the processing of your data, in accordance with the regulations. In most of the cases this information is already presented to you in your online services from us. Your right to access may, however, be restricted by legislation and protection of other person’s privacy rights.

  1. Right to Rectification

You have the right to request from us to correct your personal data if inaccurate, incomplete, or out of date.

  1. Right to be Forgotten

You have the right to request that your personal data is deleted when it is no longer necessary for us to retain such data. Please note that due to the financial sector legislation we are in many cases under statutory obligation to retain personal data on you not only during the customer relationship but also for many more years after. For more details, please see Section 8. How long we keep your personal data.

  1. Right to Restriction of Processing

If you contest the correctness of the data which we have registered about you or lawfulness of processing, or if you have objected to the processing of the data in accordance with your right to object, you may request us to restrict the processing of this data to storing purposes only. The processing will only be restricted to storing until the correctness of the data can be established, or it can be checked whether our legitimate interests overwrite your interests. If you are not entitled to deletion of the data which we have registered about you, you may instead request that we restrict the processing of this data to storing purposes only. If the processing of the data which we have registered about you is solely necessary to assert a legal claim, you may also demand that other processing of this data be restricted to storing purposes only. We may process your data for other purposes if this is necessary to assert a legal claim or if you have granted your consent to this. We will inform you on any correction or deletion of personal data or limitation of their processing unless this is impossible or requires an excessive expenditure of time and resources.

  1. Right to Object

You have the right to object when the processing of your data is based on legitimate interest or when your data is processed for public interest. You can always object to the processing of your personal data for direct marketing band profiling in concern to such marketing.

  1. Right to Data Portability

You have the right to receive the personal data that you provided to us in a machine-readable format. This right applies to personal data processed only by automated means and on the consent or fulfilling a contract basis. Where secure and technically feasible the data can also be transmitted to another data controller by us.

  1. Right to Complain to Supervising Authority

If you are not satisfied with the way in which we process your personal data you may in the first instance contact us at privacy@zero21.eu. If you remain dissatisfied, then you have the right to apply directly to your national supervisory authority for a decision. To find your national supervisory body please go to this adress.

  1. Automated individual decision-making and profiling

Please be informed that you have the right not to apply to you a decision made solely on the basis of automated processing, including profiling, if that decision produces legal consequences for you or that decision significantly affects your position.

  1. Right to Withdraw your Consent

In the case you want to withdraw your consent, please make use of the link to manage your subscription included in our communication. Regarding the e-marketing please note that you may still receive system messages and notifications about your account activities.

  1. Personal data breach notification

Please be informed that we will notify you without undue delay of any breach of personal data if that breach may cause a high risk to your rights and freedoms.

Your request to exercise your rights as listed above will be assessed given the circumstances in an individual case. Please bare in mind that we may also retain and use your personal data as necessary to comply with legal requirements, resolve disputes and or enforce our agreements.

Any query about your Privacy Rights should be sent to privacy@zero21.eu

6. Your USA Privacy Rights

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge. All provisions of this Privacy Policy also apply to consumers who are residents of the United States of America (U.S.), unless otherwise provided in this chapter. If the provisions of this chapter relating to U.S. consumers and any provision in the rest of our Privacy Policy conflict, this chapter controls the processing of personal data of consumers in the U.S.

California:

If you are a consumer from California, this Privacy Policy for California (CA Privacy Policy) is designed to help you understand the categories of personal data we collect about you, where we obtain this personal data, why we process it, with whom we share it, and the rights you must know and control your personal data. If this CA Privacy Policy and any provision in the rest of our Privacy Policy conflict, this CA Privacy Policy controls the processing of personal data of Consumers in California. This CA Privacy Policy does not apply to employees of the Company, contractors, temporary workers, or job applicants.

Information on Collection:

For the purposes of CCPA, the Company generally acts as a "business" regarding your personal data. A business is similar to a data controller, meaning that the Company determines how and why it handles personal data collected from or about you. This CA Privacy Policy describes our practice of collecting personal data when we act as a business, including a list of categories of personal data we collect, the purposes for which we collect personal data, and the sources from which we collect personal data. CCPA requires from the Company to make certain disclosures using the categories of personal data used in the CCPA definition of personal data.

When the Company collects precise geolocation information for the purpose of providing the requested Service, it is considered that we collect data that is sensitive according to the California law. Our use of this data to perform the service you requested is in accordance with permissible business purposes in the California Civil Code § 1798.100 et seq. and implementing regulations. While we may disclose personal data to third parties, we do not sell or sharing such information about anyone under the age of 16.

Privacy Rights for a California Consumer:

  1. Right to Know: You have the right to request access to personal data collected about you and information about the source of that data, the purposes for which we collect it, and the third parties and service providers with whom we share it.
  2. Right to Deletion: You have the right to request the deletion of specific personal data we have collected about you.
  3. Right to Correction: You have the right to correct inaccurate personal data about you. Note that correction requests are subject to certain limitations, and in certain circumstances, we may choose to delete rather than correct your personal data.
  4. Right to Opt-Out of Sale of Personal Data to Third Parties: Our disclosure of your personal data to third-party advertising and analytics service providers may constitute a sale under certain state laws, and in California, it may also constitute "sharing" (a term used to refer to sharing information for advertising purposes). To the extent our use constitutes a sale or sharing of your personal data, you have the right to opt-out by (a) enabling the "Do Not Track" signal or global privacy control in your browser recognized by our U.S. websites, (b) disabling cookies in our cookie settings for U.S. websites, or (c) submitting an opt-out request at privacy@zero21.eu.
  5. Right to Non-Discrimination: You have the right to not be discriminated against by us because you exercised any of your rights. This means we cannot, among other things:
    1. Deny goods or services to you
    2. Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
    3. Provide a different level or quality of goods or services to you
    4. Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

To submit a request to exercise your privacy rights in California you may contact us in a way prescribed in section 10. How to contact us.

When submitting a request, include your name, email address, and place of residence, you can authorize another person (your agent) to submit a request on your behalf. Please note that we may (and in some cases are required to) verify your identity before acting on your request. Upon receiving and processing your request, we will contact you using the email address provided in your request with instructions on how to confirm your identity, after which we will verify the match of information in our records. Also, we may not fulfill your entire request or some part of it—e.g., certain information we collect may be exempt, such as public information available through government agencies or information covered by other privacy laws. In such situations, when we respond to you, we will explain why we cannot fulfill your request.

Colorado, Connecticut, Utah, Virginia, Oregon, Nevada and Texas:

Privacy laws in these states provide consumers with certain rights regarding their personal data. The Company will respect these rights for each U.S. resident. They include:

  1. Right to Access Information: You have the right to access your personal data and obtain a copy of it.
  2. Right to Request Deletion: You have the right to request the deletion of personal data provided or obtained about you.
  3. Right to Correction: You have the right to correct inaccuracies in your personal data.
  4. Right to Opt-Out: Our disclosure of your personal data to independent advertising and analytics vendors may constitute a sale under certain state laws. Additionally, we use cookies for targeted advertising. You have the right to opt-out of these activities by (a) enabling the Do Not Track signal or global privacy control on your browser recognized by our U.S. websites, (b) opting out of cookies in our cookie settings for U.S. websites, or (c) submitting an opt-out request at privacy@zero21.eu.
  5. Right to complaint: You may file a complaint regarding a decision on their consumer privacy requests by contacting us via email at privacy@zero21.eu.
  6. Right to Third-Party Disclosures List for Oregon Residents: If you are a resident of Oregon, you have a right to request a list of third parties to which the Company disclosed your personal data.

    Please note that in these states too the Company collects categories of personal data as stated in the section relating to California, table entitled Categories of Data Collected form U.S. resident.

    Please also note that the Company may deidentify your personal data and disclose this deidentified personal data to third parties as permitted by applicable law. The Company will take all reasonable measures to ensure that the data cannot be associated with an individual. The Company will maintain and use deidentified data only in deidentified form without attempting to reidentify the data.

    To submit a request to exercise your privacy rights in Colorado, Connecticut, Utah, Virginia, Oregon, Nevada and Texas you may contact us in a way prescribed in section 10. How to contact us.
7. Cookies

What the cookies are?

As is common practice on almost all professional websites, this website uses cookies. Cookies are small files that are stored on your computer in order to provide certain functionality and improve your experience on the site. This page describes what information they collect and how we use it. For general information about cookies, see the Wikipedia article on Wikipedia.



We collect, process and analyze data regarding the use of our webpages. This includes standard information from your web browser, such as browser type and browser language, your Internet Protocol (“IP”) address, the actions you take on our websites, such as the webpages viewed, and links clicked. We use cookies and similar technologies to deliver our services to you, provide a secure online environment, to manage marketing and provide a better online experience and to make our website content more relevant to you. If used alone, cookies do not personally identify you. You can set or amend your web browser controls to accept or reject cookies. If you choose to reject cookies, you may still use our sites and some services, however your access to some functions and or website areas might be restricted.

8. How long we keep your personal data

Your data will be kept as long as it is necessary for the purposes for which the data was collected and processed or as long as it is required by law. Please note that we are under legal obligation to retain your data for the following statutory retention period:

  1. Preventing, detecting and investigating money laundering, terrorist financing and fraud - minimum of 8 (eight) years from the date of termination of transactions or contractual relationship
  2. Bookkeeping regulation - up to ten years;
  3. Payment services requirement - five years
  4. This statutory retention period list is not complete and is given as an example only.
9. Changes to this Privacy Policy

We may change the Privacy Policy from time to time, we will not diminish your rights under this Privacy Policy. We kindly ask you to review our Privacy Policy from time to time, however if the changes we make are significant, we will provide you with prominent notice.

10. How to contact us

Please contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this Privacy Policy or the information we hold about you.

Our contact details are shown below:

MALEMA COURT, Floor 4, Flat/Office 41, Evangelistrias 16, 3031 Agias Zonis, Limassol
privacy@zero21.eu

11. Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).