Privacy Policy

Privacy Policy  

 

At Zeal Fintech Limited (hereinafter referred to as “ZealFin”, “We”, or “Us”), we take your privacy seriously. We are committed to protecting your personal data and any non-public information you share with us (hereinafter collectively referred to as “Data”). 

 

This Privacy Policy is designed to give you a clear understanding of how we collect, use, and safeguard your Data when you engage with our services and/or products (hereinafter collectively known as “Services”). We want you to feel confident that your information is handled with care and confidentiality. 

 

We recognize the importance of trust in our relationship with you, and we are dedicated to ensuring that your Data is treated responsibly. In this policy, we’ll explain the types of Data we collect, how we use it, and the measures we take to keep it secure. 

 

If you have any questions or concerns about our practices, please don’t hesitate to reach out. Your privacy is our priority! 

 

This Privacy Policy is to bring to your attention the following: 

 

1. What Data Do We Collect? 

 

2. How Do We Gather Your Data? 

 

3. How Will We Utilize Your Data? 

 

4. How Do We Safeguard Your Data? 

 

5. Marketing Practices 

 

6. What Are Your Data Protection Rights? 

 

7. What Are Cookies? 

 

8. How Do We Employ Cookies? 

 

9. What Types of Cookies Do We Use? 

 

10. How Can You Manage Your Cookie Preferences? 

 

11. Privacy Policies of Other Websites 

 

12. Updates to Our Privacy Policy 

 

13. How to Reach Us? 

 

14. How to Contact the Relevant Authorities? 

 

 

1. WHAT DATA DO WE COLLECT? 

 

Before ZealFin provides any services to you, ZealFin may collect the following Data from you: 

 

1. Personal Identification Information: 

1. Full legal name; 

2. Nationality; 

3. Gender; 

4. Date of birth; 

5. Photo; 

6. Social Security Number or comparable identification number; 

7. Proof of identity (e.g., driver’s license, passport, or government-issued identity card);  

8. Employer identification number (or comparable government-issued number); and/or 

9. Personal identification information for all material beneficial owners of your business (if applicable). 

 

2. Contact Information: 

1. Home address, including country of residence; 

2. Email address;  

3. Proof of address (e.g., utility bills) and/or 

4. Mobile phone number. 

 

3. Financial Information: 

1. Employment information (e.g., company name); 

2. Personal/business bank account details; 

3. Other personal information for eligibility verification; 

4. Other personal information for compliance with AML obligations; and/or 

5. Other personal information required by court orders or applicable laws. 

 

4. Proof of Source of Funds/Wealth: 

1. Employment information (e.g., company name); 

2. Total annual income; 

3. Bank statements; 

4. Pay stubs/Salary slips; 

5. Tax returns; 

6. Investment statements; 

7. Sale agreements; 

8. Inheritance documentation; 

9. Loan Agreements; 

10. Business financial statements; 

11. Gift letters; and/or 

12. Proof of ownership. 

 

5. Location and Log Information: 

1. Location Information: Automatically collected data via analytics (e.g., IP address, domain name, browser type, time zone setting); and/or 

2. Log Information: Data generated from using our Services, including device-specific info, location info, and activity logs (e.g., URLs visited, interaction details). 

 

6. User Account Information 

1. Information generated from ZealFin account activities (e.g., funding instructions, orders, trades, account balances). 

 

7. Correspondence 

1. Information provided in written or oral communication, including account opening and customer support interactions (via email, in-app messages or phone calls). 

 

8. Public Database Information 

1. Data obtained from public databases (e.g., United Nations Sanctions List, SEC EDGAR), including name, address, gender, national ID number, job role, and sanctions listing. 

 

9. Blockchain Data 

1. Public blockchain data analysis (e.g., transaction timestamps, IDs, amounts, wallet addresses). 

 

10. Marketing and Analytics Information 

1. Information from Marketing and Advertising Partners: Name and contact info received from marketing partners; 

2. Information from Analytics Providers: Data about website usage and interactions; and/or 

3. Information from Cookies and Similar Technologies: Data collected through cookies. 

 

11. Merchant and Third-Party Information 

1. Retail Merchant Information: Data received from merchants for transactions (e.g., name, contact details); and/or 

2. Other Third-Party Information: Data from banks or financial institutions used for transactions 

 

12. Our platform’s performance (includes both our company website and mobile application) 

1. Crash log and diagnostics; and/or 

2. Mobile application performance data. 

 

To ensure you fully benefit from ZealFin’s services, we may collect additional data as needed to enhance your experience and effectively deliver our offerings. While you have the right to decline providing the requested data, please note that this may limit your ability to access the full range of our Services. 

 

 

2. HOW DO WE GATHER YOUR DATA? 

 

You directly provide us with most of the Data we collect. We collect and process Data when you: 

 

1. Register for Our Services: When you create an account or sign up for our services, you provide your Data to us. 

 

2. Participate in Surveys or Feedback: You may voluntarily complete customer surveys or provide feedback through various communication channels. This information helps us understand your needs and improve our offerings. 

 

3. Use Our Website: We collect Data when you visit or interact with our website, including through your browser’s cookies. Cookies help us analyze user behavior, enhance site functionality, and tailor your experience to better meet your preferences. 

 

4. Engage with Our Customer Support: When you contact our support team for assistance, we collect information about your inquiry, which helps us resolve your issues more effectively. 

 

5. Interact with Marketing Communications: If you respond to our marketing emails, click on links, or engage with our social media posts, we may collect data related to your interactions to better tailor our communications. 

 

6. Conduct Transactions: When you make purchases or transactions through our services, we collect relevant financial information to process those transactions securely. 

 

7. Use Device Features: If you enable features on your device (such as location services), we may collect information to provide enhanced services based on your preferences. 

 

 

3. HOW WILL WE UTILIZE YOUR DATA?  

 

When you use our services, your personal information may be utilized in various ways by ZealFin, including: 

 

1. providing the Services you request from ZealFin, or contacting you about Services we believe may interest you, with your consent; 

 

2. verifying your identity; 

 

3. managing and administering the Services offered to you; 

 

4. keeping you informed as a client regarding changes to ZealFin’s Services and related matters; and/or 

 

5. fulfilling our obligations arising from any contracts between you and ZealFin. 

 

 

Additionally, your personal information may be used for the following purposes: 

 

6. to develop and enhance our Services; 

 

7. to send push notifications about our Services and other relevant information; 

 

8. to evaluate and improve the effectiveness of our promotions; 

 

9. to invite you to participate in surveys assessing our Services; 

 

10. to assess potential risks related to our Services; and/or 

 

11. For other purposes, upon your authorization. 

 

 

ZealFin carefully considers the use of the Data we collect for the following business purposes, benefiting our users: 

 

12. creating and maintaining your ZealFin user account; 

 

13. providing our Services and customer support; 

 

14. identifying and confirming your identity when using our Services; 

 

15. determining your legal eligibility for certain regulated products; 

 

16. customizing your experience and improving our Services based on user feedback and service requests; 

 

17. maintaining and analyzing usage statistics, and collaborating with governmental and academic institutions; 

 

18. enabling device-based settings, such as accessing your GPS location or camera, to enhance service features; 

 

19. facilitating transactions while ensuring your information remains private and secure, without being shared with third parties without your consent, except as necessary to complete the transaction; 

 

20. transmitting information to any affiliated third parties, including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Europe or no EU jurisdictions, for the aforementioned purposes in this section; 

 

21. sending regular updates, newsletters, promotions, and other service communications to the email address you provide, unless you specify otherwise; 

 

22. conducting research and innovation; 

 

23. promoting the safety, security, and integrity of our Services; 

 

24. complying with legal and regulatory obligations by sharing information with law enforcement and other authorities when necessary; and/or 

 

25. meeting other purposes as specified in the Terms and Conditions on the ZealFin website. 

 

We provide our services in collaboration with companies that provide services on our behalf, such as handling the processing and delivery of information, publication of information in the applications, delivery of content and services provided by the applications and services of our websites, or performing statistical analysis on the use of the applications and the aforementioned services. These service providers will be given limited access to your information as is reasonably necessary to deliver the Service, and we will require that such third parties comply with this Privacy Policy, or operate under a similar privacy policy. 

 

4. HOW DO WE SAFEGUARD YOUR DATA? 

 

We prioritize the security of your Data, which we store in a combination of secure electronic systems and physical files. We take significant steps to protect this Data from misuse, loss, unauthorized access, modification, or disclosure. Access to personal information is limited to employees or partners who need it to fulfill the agreements between us. 

 

We do not store any credit or debit card data. Our procedures require that our affiliates and employees maintain the confidentiality of your Data. We will retain your personal information only for as long as necessary. While certain data must be kept for extended periods due to legal requirements, we will securely remove or destroy identifying details when they are no longer needed. 

 

Although we implement robust security measures, including physical, electronic, technical, and managerial safeguards, you acknowledge that internet usage is not entirely secure. Therefore, we cannot guarantee the absolute security or integrity of any personal data transmitted to or from you over the internet. 

 

Security Measures 

 

1. Physical Measures: Data records are securely stored in locked facilities to prevent loss, theft, unauthorized access, disclosure, or modification. 

 

2. Electronic Measures: Data containing your personal information is stored in encrypted systems and storage media with strict access restrictions. 

 

3. Technical Measures: We utilize advanced encryption techniques. 

 

4. Managerial Measures: Only authorized personnel can access your Data, and these individuals are trained and monitored to adhere to our internal data protection policies. 

 

5. Additional Measures: We may implement other necessary measures to ensure the safety of your Data. 

 

User Responsibility 

 

6. To further protect your Data, it is essential to keep your login ID and password confidential. We cannot be held liable for any damage or loss resulting from your failure to maintain the secrecy of your login credentials. 

 

 

5. MARKETING PRACTICES  

 

We would love to provide you with information about services that we think you may find appealing. 

 

If you have agreed to receive marketing communications, you can choose to withdraw your consent at any time in the future. 

 

You have the right to request that we cease all marketing communications or refrain from sharing your information with other entities within our corporate group. 

 

 

6. WHAT ARE YOUR DATA PROTECTION RIGHTS? 

 

You have the right to request that we refrain from processing your Data for marketing or other specific purposes. We will require your consent before collecting your Data if we intend to use it for such purposes or disclose it to any third parties. 

 

You can exercise this right by checking the appropriate boxes on our Data collection forms or by contacting us at infoHK@zfintechhk.com to learn more about how your Data is processed. Additionally, you have the right to obtain a copy of the Data we hold about you and to notify us of any inaccuracies. Please note that some data protection law of different jurisdiction includes certain exceptions to this right. To make a request, please write to us, verifying your identity and specifying the information you need. 

 

You also have the right to request the deletion of your Data that we hold. Please reach out to us for more information on this process. We may charge an administrative fee to cover the costs of verifying your request and retrieving, reviewing, and copying any requested materials. 

 

Depending on your jurisdiction, you may have the following rights regarding your Data under this Privacy Policy. Keep in mind that exercising these rights may impact our ability to provide Services.  

 

For inquiries, please email us at infoHK@zfintechhk.com, and we will make reasonable efforts to accommodate your request within fourteen (14) business days.  

 

However, we reserve the right to impose certain restrictions and requirements as allowed by applicable laws. Processing your request may take some time in accordance with legal guidelines. 

 

Your Rights Include: 

 

1. Right to Access and Portability: You may request a copy of your Data held by us by emailing infoHK@zfintechhk.com. 

 

2. Right to Rectification: You may request updates or corrections to any incomplete or inaccurate personal information we hold by contacting infoHK@zfintechhk.com. 

 

3. Right to Deletion: You may ask us to erase your Data unless prohibited by applicable law.  

 

4. Right to Withdraw Consent: If the processing of your Data is based on your consent, you can withdraw it at any time. This will not affect the legality of processing conducted prior to your withdrawal. 

 

5. Right to Object or Restrict Processing: You may restrict or object to our use of your Data based on our legitimate interests, public interest, or for direct marketing. You can opt-out of marketing communications by registering with us or emailing infoHK@zfintechhk.com. 

 

6. Right to Non-Discrimination: We will not discriminate against you for exercising any of your rights provided by law. 

 

To protect your privacy and security, we may verify your identity before processing your request, and we may decline requests if we cannot verify your identity. 

 

Please note that these rights are not absolute and may be denied in certain circumstances, including when granting access or assisting with portability could adversely affect the rights and freedoms of others, to protect our rights and properties, if the request is frivolous, or as otherwise permitted by law. 

 

 

7.  WHAT ARE COOKIES? 

 

Cookies are small files of information that often include a unique identification number, stored on your computer’s hard drive when you use our website. Unless you adjust your browser settings to refuse cookies, our system will issue cookies as soon as you visit the site. Cookies are commonly used across many websites, and you can control their acceptance by changing your browser preferences. 

 

Some of our business partners, such as advertisers, may also use cookies on our website. We do not have access to or control over these cookies. They do not contain personally identifiable information and are not used to identify you.  

 

You can choose to disable cookies; however, this may limit your access to certain parts of our website, particularly secure areas. 

 

 

8. HOW DO WE EMPLOY COOKIES? 

 

Our company employs cookies in various ways to enhance your experience on our website, including: 

 

1. Keeping you signed in; and 

 

2. Understanding how you navigate our site. 

 

 

9. WHAT TYPES OF COOKIES DO WE USE? 

 

1. Session Cookies 

 

We utilize session cookies to enhance the user experience during a single visit. These temporary cookies retain information such as page navigation but do not collect or track personal information. Session cookies expire when the user closes their browser. 

 

2. Performance Cookies (Optional) 

 

In cases where analytics or tracking mechanisms are employed for page performance (e.g., Google Analytics), these cookies gather anonymous data regarding user interactions with the page. This includes, but is not limited to, metrics such as page views and time spent on the page. 

 

3. Third-Party Cookies: 

 

Third parties may place cookies through our site for various purposes, including: 

 

1. Serving and tracking advertisements on our site. 

 

2. Controlling the frequency of particular advertisements. 

 

3. Customizing content based on your preferences. 

 

4. Counting the number of anonymous users visiting our site. 

 

5. Analyzing website usage. 

 

 

10. HOW CAN YOU MANAGE YOUR COOKIE PREFERENCES? 

 

You have the option to accept or decline cookies. While most web browsers automatically accept them, you can typically adjust your browser settings to refuse cookies if that’s your preference. However, doing so may limit your ability to fully utilize the website. 

 

For more information on how to disable cookies, please visit www.allaboutcookies.org. 

 

 

11. LOCAL DATA STORAGE  

 

Cookie is not applicable for mobile applications. Therefore, our mobile application employs local data storage tools to collect data related to your usage. Our mobile application utilizes local databases and storage mechanisms to store data directly on your device. This approach is essential for managing app settings, caching request data, and enhancing overall app performance. 

 

1. Local Database (Hive) 

 

We use Hive to store non-sensitive information, such as cached API requests and user preferences. 

 

2. Flutter Secure Storage 

 

For sensitive data, such as authorization tokens, we employ Flutter Secure Storage. This solution leverages platform-specific secure storage mechanisms, including KeyChain for iOS and KeyStore and EncryptedSharedPreferences for Android. 

  

 

12. PRIVACY POLICIES OF OTHER WEBSITES 

 

Our website may contain links to other sites. Please note that our Privacy Policy applies exclusively to our website. If you click on a link to a different site, that site will be governed by its own separate privacy policy, which may differ from ours. We encourage you to review the privacy policies of any third-party websites you visit. 

 

 

13. UPDATES TO OUR PRIVACY POLICY 

 

We will review and update our Privacy Policy at least once a year or whenever there are changes to relevant data protection laws. Any discrepancies will be addressed promptly. 

 

 

14. HOW TO REACH US? 

 

For any requests, comments, or questions about this policy, please feel free to reach out to us at infoHK@zfintechhk.com. 

 

 

15. HOW TO CONTACT THE RELEVANT AUTHORITIES? 

 

If you wish to report a complaint or feel that your concerns have not been adequately addressed by our company, you may contact the Privacy Commissioner for Personal Data in Hong Kong. Your feedback is important to us, and we encourage you to reach out if you need further assistance.