Privacy Policy for Z1 FINANCIAL

Last revised: 25 August 2022

This Privacy Policy describes how Z1 FINANCIAL collects and processes your personal information through the Z1 FINANCIAL websites and applications that reference this Privacy Notice.

Z1 FINANCIAL refers to an ecosystem comprising Z1 FINANCIAL websites (whose domain names include but are not limited to https://www.z1.finance), mobile applications, clients, applets and other applications that are developed to offer Z1 FINANCIAL services.

This Privacy Policy applies to all platforms, websites, and departments of Z1 FINANCIAL and Z1 FINANCIAL operators. By using Z1 FINANCIAL services, you are consenting to the collection, storage, processing and transfer of your personal information as described in this Privacy Policy.

Z1 FINANCIAL Holdings PTE. LTD. (Unique Entity Number: 202122316D, registered office address: 1 Paya Lebar Link, #06-08​ Paya Lebar Quarter, Singapore 408533​) is the Data Controller for personal information collected and processed in connection with the provision of Z1 FINANCIAL services.

1. THE PERSONAL INFORMATION WE COLLECT

Z1 FINANCIAL collects your personal information in order to provide and continually improve our products and services. Here are the types of personal information we collect: Information you give us: we receive and store any information you provide in relation to Z1 FINANCIAL. You can choose not to provide certain information but then you might not be able to use some Z1 FINANCIAL services. Examples of information that you give us include:

 1. Email address / Phone
 2. Name
 3. Gender
 4. Date of birth
 5. Occupation
 6. Home address
 7. Nationality
 8. Country code
 9. Passport / ID Card
 10. Other information to help us identify you

Automatically collected information: we automatically collect and store certain types of information about your use of Z1 FINANCIAL services including your interaction with content and services available through Z1 FINANCIAL services. Like many websites, we use cookies and other unique identifiers and we obtain certain types of information when your web browser or device accesses Z1 FINANCIAL services. Examples of the information we collect and analyze include:

 1. the Internet protocol (IP) address used to connect your computer to the Internet,
 2. login, e-mail address, password and location of your device or computer;
 3. Z1 FINANCIAL services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences);
 4. version and time zone settings;
 5. transaction history

Information from other sources: we may receive information about you from other sources such as credit history information from credit bureaus, which we use to help prevent and detect fraud.

2. Children cannot use Z1 FinancIAL Services

Z1 FINANCIAL does not allow anyone under the age of 18 to use Z1 FINANCIAL services.

If a user submitting personal information is suspected of being younger than 18 years of age, Z1 FINANCIAL will require the user to close his or her account and will not allow the user to continue using our services. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our services so we can take action to prevent access to our services.

3. HOW YOUR PERSONAL INFORMATION IS USED

We process your personal information to operate, provide, and improve the Z1 FINANCIAL services that we offer our users. These purposes include:

 1. Transaction services. We use your personal information to take and handle orders, process payments and communicate with you about orders and services and promotional offers.
 2. Provide, troubleshoot, and improve Z1 FINANCIAL services. We use your personal information to provide functionality, analyze performance, fix errors, and improve the usability and
  effectiveness of Z1 FINANCIAL services.
 3. Recommendations and personalization. We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalize
 your experience with Z1 FINANCIAL services.
 4. Comply with legal obligations. In certain cases, we collect and use your personal information to comply with laws and regulations. For instance, we collect bank account information for
  identity verification and other purposes.
 5. Communicate with you. We use your personal information to communicate with you in relation to Z1 FINANCIAL services.
 6. Fraud prevention and credit risks. We process personal information to prevent and detect fraud and abuse in order to protect the security of our users, Z1 FINANCIAL services and others.
  We may also use scoring methods to assess and manage credit risks.
 7. Purposes for which we seek your consent. We may also ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to
  our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop the processing of your data for that purpose.

4. Cookies and Other Identifiers

We use cookies and similar tools to enhance your user experience, provide our services, and understand how customers use our services so we can make improvements. To enable our systems to recognize your browser or device and to provide Z1 FINANCIAL services to you, we use cookies. We use operational cookies and similar tools (collectively, "cookies") to provide our services, for example:

 1. Recognizing you when you sign in to use our services.
 2. Providing customized features and services.
 3. Displaying features and services which might be of interest to you, including ads on our services.
 4. Preventing fraudulent activity.
 5. Improving security.
 6. Keeping track of your preferences such as currency and language.
 7. We also use cookies to understand how users use our services so we can make improvements.

The settings on your browser will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable and remove cookies, and when cookies will expire.

Operational cookies allow you to take advantage of some of Z1 FINANCIAL's essential features. If you block or otherwise reject operational cookies through your browser settings some features and services may not work.

5. International Transfers of Personal Data

Z1 FINANCIAL may transfer your data outside of the European Economic Area (“EEA”). Z1 FINANCIAL puts in place suitable safeguards to ensure that such transfer is carried out in compliance with applicable data protection rules, except where the country to which the data is transferred has already been determined by the European Commission to provide an adequate level of protection. Where Z1 FINANCIAL transfers personal data to affiliates or service providers, Z1 FINANCIAL relies on the standard contractual clauses approved by the European Commission.

Where Z1 FINANCIAL transfers personal data to affiliates or service providers, Z1 FINANCIAL relies on the standard contractual clauses approved by the European Commission.

6. How Secure is My Information?

We design our systems with your security and privacy in mind.  We work to protect the security of your personal information during transmission by using encryption protocols and software.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may ask you to verify your identity before we disclose personal information to you.

It is important for you to protect against unauthorized access to your account password. We recommend using a unique password for your Z1 FINANCIAL account that is not utilized for other online accounts. Be sure to sign off when you finish using a shared computer.

7. What About Advertising?

We may share your personal information with our marketing partners for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising.

8. What Information Can I Access?

You can access your information, including your name, address, payment options, profile information, and transaction history in the "Your Account" section of the website.

9. What Choices Do I Have?

If you have any questions or objections as to how we collect and process your personal information, please contact dpo@z1.finance

When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop any further processing of your data for that purpose.

In addition, subject to applicable law, you have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances. If you wish to do any of these things, please contact dpo@z1.finance

10. How Long Does Z1 FINANCIAL Keep My Personal Information?

We keep your personal information to enable your continued use of Z1 FINANCIAL services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, as may be required by law such as for tax and accounting purposes, or as otherwise communicated to you.

11. EU GDPR and UK Data Protection Laws - Legal Basis

The EU GDPR and UK data protection laws require a legal basis for our use of personal information. Our basis varies depending on the specific purpose for which we use personal information. We rely on:

 1. Performance of a contract when we provide you with products or services, or communicate with you about them. This includes when we use your personal information to take and handle orders, and process payments.
 2. Our legitimate business interests and the interests of our users when we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others.
 3. Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop the processing of your data for that purpose.
 4. Compliance with a legal obligation when we use your personal information to comply with laws. For instance, we collect bank account information for identity verification purposes.
 5. These and other legal bases depend on the purpose for which we use personal information.

12. Contact Information

Our data protection officer can be contacted at dpo@z1.finance, and will work to address any questions or issues that you have with respect to the collection and processing of your personal information.

13. Conditions of Use, Notices and Revisions

If you choose to use Z1 FINANCIAL services, your use and any dispute over privacy are subject to this Notice and our Terms of Use. If you have any concerns about privacy at Z1 FINANCIAL, please contact us with a thorough description, and we will try to resolve them. You also have the right to contact your local Data Protection Authority.

Our business changes constantly, and our Privacy Notice will change also. You should check our websites frequently to see recent changes. If you do not agree with the revised content, you shall stop accessing Z1 FINANCIAL immediately. When an updated version of the Privacy Policy is released, your continued access to Z1 FINANCIAL means that you agree to the updated content and agree to abide by the updated Privacy Policy. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account.