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Privacy Policy

Last updated: July 1, 2024

General:

This Privacy Policy ("Policy") is operated by ZenBoost OÜ, with its registered address at: Harju county, Tallinn, Haaberst district, Paldiski street 199a, 13517 Estonia (hereinafter the "Company”), describes and governs the information collection, use, and sharing practices of Company and its corporate affiliates, subsidiaries, and divisions as may change from time to time (collectively, "we," "us," and "our") with respect to Sites, mobile applications, and other digital and interactive services that link to this Privacy Policy (together, the "Services").

Before You submit any information on or through the Services, please carefully review this Privacy Policy together with our Terms & Conditions and any other documents referred to therein to understand our views and practices regarding Your information and how we will treat it. By accessing or using any part of Service, including browsing the Site, You consent to the collection, use, and disclosure of Your Personal Data information as further outlined in this Privacy Policy.

IF YOU DO NOT AGREE WITH THE PRIVACY POLICY, YOU SHOULD NOT ACCESS OR USE THE SERVICE(s).

Definitions:

Personal Information (Personal Data): any information which identifies You personally or which may help us to identify You (e.g. your name, address, e-mail address, trades etc.).

GDPR: General Data Protection Regulation Act.

Data subject: is any living an identified or identifiable person (our User).

Data controller: means the natural or legal person who (either or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

Data processor: a company which processes Personal Data on behalf and upon instructions of the Data controller.

Service(s): Company Site, our Platform used for providing our Service(s) to You and including that Sites/landing pages which are used for the purposes of informing our Users/Site visitors on our promotional, marketing campaigns and special offers, mobile applications and other digital and interactive Service(s).

Personal data processing: any operation or set of operations performed on Personal Data (e.g., collection, storage, use, disclosure erasure).

Other capitalized terms, not defined above, have the meanings as defined in Terms & Conditions and the applicable data protection legislation (namely, the General Data Protection Regulation 2016/679 as of April 27, 2016).

What personal data we collect and process:

We may collect Your Personal Information if You use this Site and open an Account to use the Platform. This is defined as collection for the purpose of provision of Service(s) to You in accordance with our Terms & Conditions. Please note that if you refuse to share your Personal Information for this purpose, we will not be able to provide our Services to You.

How we keep Your Data secure:

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Personal Data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. We take reasonable administrative, physical, and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. This includes using Secure Sockets Layer (SSL) software, which encrypts the personal information you input, and storing your information in encrypted form behind a firewall designed to block access from outside our network. Although we use commercially reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. Moreover, we cannot assure you that your personal information that we collect will not be used or disclosed inconsistently with this Policy. We assume no responsibility or liability for disclosure of any of your information due to errors in transmission, unauthorized third party access, or other causes beyond our reasonable control.

Where we store your data:

The personal data that we collect from you may be transferred to and stored at a location in the European Economic Area (EEA) and outside EEA, where we host our servers. It may also be processed by law enforcement agencies and employees located outside the EEA who work for us or our suppliers (for example, staff who are involved in providing services that you order from us, processing your payment details or providing support services to us). By submitting your personal data to us, you agree to this transfer, storage and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

The types of the Personal Information which we collect may include:

  • Email address;
  • First and Last name;
  • Phone number;
  • Address, City, State, Country, Post code;
  • your payment card data (processed and collected by payment processor partner(s));

Information we collect through your use of our Service(s):

When You use our Service(s) we collect information that helps us to deliver the Service You have chosen and to improve Your experience. This is done through Cookies and other technologies.

Examples of the type of information we may collect are:

  • Browser and Operating System information;
  • Device;
  • IP address;
  • Location;
  • your IP address;
  • Internet service provider;
  • User name and password.

You can also disclose additional information which may not be essential for us to deliver the Service to you. By providing it You help us to ensure we communicate with You in a way that’s most relevant, useful and engaging for You. We may collect and ask for additional information when You order, purchase, register, subscribe or make use of our Services in any way.

How we may use your Personal Information and other type of collected information:

We will process your Personal Information and other type of information for the various purpose(s), including but not limited:

  • To provide you with the Service(s) that You ask us to provide You;
  • To notify You about changes to our Service(s);
  • To provide You support according to Service(s);
  • To gather analysis or valuable information so that we can improve our Service(s);
  • To Site administration, troubleshooting, processing of e-commerce transactions, administration of sweepstakes and contests, and other communications with You;
  • To satisfy the legal obligations stemming from regulatory obligations that arise from providing You the Service(s) and our legitimate interest.

Retention of Personal Information

Your information is held within our servers located within the European Union. Access to this information is provided to our support employees whose office may also be outside of the European Union but who adhere to the same principles of data security and processes as those within the European Union.

Your payment method information that You may use are passed on to a third-party payment processor(s) which is/are based in the EU and with which Company has a contractual agreement to safeguard Your rights. Unless You create an account with us and conduct transactions, we do not retain Your payment method information.

We will hold Your Personal Information only for as long as it is necessary for the purposes described in this Privacy Policy and our own legal and regulatory requirements.

In accordance with record-keeping activities for Anti-Money Laundering, Tax, and Company legal obligations and considering the period during which You may bring legal claims against us under the law of Estonia, we will retain Personal Information for a period of five years after our User closes his or her Account and terminates legal relationships with us for five years from the end of the tax period in which the User conducts his or her last transaction.

Data stored for regulatory purposes only will be protected from unnecessary processing and will be held only for the purpose of being able to provide information or access to relevant authorities.

Your Data Protection Rights:

If You are a resident of the European Economic Area (EEA), in certain circumstances, You have the following data protection rights:

You have the right to access Your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us at contact@zenboostlimited.com or where possible, You can do these actions in Your Account profile page yourself.

Upon Your written request, we will inform You of the Personal Information relating to You that we hold and the use and general disclosure of Your Personal Information. We will also give You a copy of the Personal Information we have retained.

You have the right to ask us to rectify information You think is inaccurate. You also have the right to ask us to complete information You think is incomplete. Moreover, You have the right to restrict and object to the processing of Your personal data in certain circumstances.

To ensure the confidentiality, integrity and availability of Your information to yourself, we may request You to confirm Your identity by providing identification documentation and/or other methods prior to assisting You in exercising any of your rights.

If You refuse to prove Your identity, we may decline to take actions in respect of Your data, save restricting processing, until we can ensure that such actions are the true wish of the data subject.

In the carrying out of our services we may use automated processing and profiling to reduce the risks of fraud, money laundering and abuse of our services. Through this automated processing, we carry out an analysis of Your identification, transactional and behavioral patterns.

We may not able to provide you with some or all our services if You do not wish this automated processing to be carried out. If You feel that this processing might be detrimental to You, please contact us on at contact@zenboostlimited.com, and our compliance officer will review Your application.

Please note, if You make a request, we have one month to respond to You.

COOKIE POLICY

We may collect information about your computer or mobile device by using Cookies. If You use our Site, You are consenting to the use of Cookies as explained here. Cookies are small text files that are placed on Your computer by Sites that You visit and provide statistical data to us, that do not identify You personally, but tell us a lot about Your browsing habits that help us to tailor Your user experience to suit Your needs. We use cookies to enhance our security, help us gather information during subscription and understand our web traffic trends and to share Your non-personal information with carefully selected third parties for marketing purposes. They help us to improve the Services and to deliver a better and more personalized Service.

Cookies enable us:

  • To estimate our audience size and usage pattern
  • To store information about Your preferences, and so allow us to customize the Services according to Your individual interests
  • To speed up Your searches
  • To recognize You when you return to any Site or application
  • To provide anonymous statistical information: non-personal data may be gathered on our behalf using cookies, log file data, and code that is embedded on our Sites by specific third-party partners to help these selected third parties deliver relevant advertisements to You.

We use this Cookie information to help improve the Services we provide to You. When You visit the publicly available sections of the Services, a session ID Cookie is placed on Your computer that only exists for the duration of Your current visit. We also place persistent Cookies (also known as local storage devices) on members’ computers to make Your login process faster and easier. Using persistent Cookies on Your computer or mobile device supports us in preventing phishing, scamming, and unauthorized login attempts, and also allows us to restore access to Your hacked account. We do not use and/or collect any information whilst You are logged off.

Controlling and deleting Cookies

You have the right to choose whether or not to accept Cookies. We explain how You can exercise this right below. However, please note that if You choose to refuse Cookies You may not be able to use the full functionality of our Sites and the Sites of other companies. You may block Cookies:

  • by using the opt-outs provided below;
  • by visiting http://www.youronlinechoices.com/;
  • through Your browser, as explained below.

You can block Cookies by changing Your browser settings so that Cookies from this Site cannot be placed on Your computer or mobile device. To do this, follow the instructions provided by Your browser (usually located within the “Help”, “Tools” or “Edit” facility). Disabling a Cookie or category of Cookie does not delete the Cookie from Your browser, You will need to do this Yourself from within Your browser.

For further information about Cookies, including how to find out what Cookies have been set on Your device and how to manage and delete them, visit www.aboutcookies.org and www.youronlinechoices.eu

Copyrights

The copyright of this Site is the property of Company.

All content including texts, graphics, photographs, animations, videos and clips visible on the Site are object of copyright and are intellectual property of Company and may not be reproduced, used, presented or represented without an explicit written permission. Any distribution of files, obtained by the users under the terms of this Site, or of parts of such files, constitutes a violation of the relevant intellectual property laws and is prosecuted by the law. Nothing contained on this Site may be interpreted as granting a license or right of use as a trademark without the prior explicit written permission of Company

Changes

We will continue to evaluate this Privacy Policy as we update and expand the Service(s) and our offerings, and we may make changes to the Privacy Policy accordingly. Any changes will be posted here and You should check this page periodically for updates. Your continued use of the Service(s) will signify acceptance of the terms of the updated Privacy Policy.

If we consider that Your rights may be affected by any such changes, we will request You to confirm Your consideration and acceptance prior to continue our relationship with You.

Termination

This Privacy Policy is effective until terminated by either party. If You no longer agree to be bound by this Privacy Policy, You must cease use of Company Site. If You are dissatisfied with Company Site, its’ content, or any of these terms, conditions, and policies, Your sole legal remedy is to discontinue using of its service(s). Company reserves the right to terminate or suspend Your access to and use of the Site/service(s), or parts of it, without notice, if we believe, in our sole discretion, that such use is in violation of any applicable law, or harmful to our interests or the interests, including intellectual property or other rights of another person or entity, or where Company has reason to believe that You are in violation of these Privacy Policy.

Governing Law

Our Site is operated and provided in Estonia. This Privacy Policy and the use of this Site are governed by the laws of Estonia. Collected information will be used according to the rules and laws that applied at the time the information was collected. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any party.

Contact Us

If you have any questions, comments, or concerns not specifically regarding our Privacy Policy and/or practices as it or they relate to the Platform, please contact us at the email address contact@zenboostlimited.com or call us 372 668 0326