This Privacy Policy as amended or otherwise changed from time to time (“Policy”) sets out how ZK Candy Ltd, a company incorporated in the British Virgin Islands and our affiliates (collectively referred to as “ZKCandy”, “we”, “us”, or “our”) collects, uses, processes, and protects your Personal Data collected through your use of our website as well as any marketing campaigns, product feedback forms, surveys, events and sales (collectively “Services”).
By accessing our website of any Services, you acknowledge and agree that you have read, understood, and agreed to the terms of this Policy. If you do not agree with any terms hereof, please cease to use or access to our website of the Services.
“Personal Data” or “Personal Information” means any personally identifiable information that can be issued to identify or contact you, which may include without limitation the following information:
ZK Candy and/or our service provider(s) may obtain or request Personal Data about you in the manner as described below:
When you access to the website or any Services, ZK Candy and/or our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the websites, our communications, and other online services, such as:
When you access to the website or any Services, you may be requested to provide the following information to us:
We may obtain Personal Information from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, a third-party login service, third party identity verification services, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.
The nature of a public blockchain means that certain information is publicly available, including but not limited to: your wallet address; the address of a sender initiating a transaction; the address of a recipient (whether an Ethereum address or a smart contract address); the maximum amount of gas fees that the sender is willing to allocate for executing the transaction; the price the sender is willing to pay per unit of gas; the nonce (a sequential number issued by the sender’s address); the cryptographic signature generated using the sender’s private key; the IP address from the requester (visible only to remote procedure call nodes); and any additional data needed for the transaction, such as invoking functions in a smart contract or providing arguments for those functions. When you authorize (i.e., use a crypto wallet to “sign”) a blockchain transaction through any of the websites, you are authorizing us to collect and use all information associated with that transaction which we will do in accordance with this Policy. Note that we are not able to control whether or how third parties use information that is stored on the blockchain, and we expressly disclaim responsibility for any such activities by third parties.
We may use various techniques and tools to automatically collect information through this website or any of our Services, including but not limited to:
Cookies are small text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
such as HTML5, which provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications,
A pixel tag or web beacon (also known as clear GIFs) may be used to collect information in relation to the engagement on the website or our Services and demonstrate where a webpage or email was accessed or opened, or that certain content was viewed or clicked.
We may use your Personal Information for the following purposes:
We use your Personal Information to provide, operate, maintain, secure and improve the Websites; provide information about the Websites; manage and develop our business and operations; communicate with you about the Websites, including by sending you announcements, updates, security alerts, and support and administrative messages; understand your needs and interests, and personalize your experience; and respond to your requests, questions and feedback and to provide support. We use such Personal Information to fulfil our obligations to you or when it is in our legitimate business interests to do so.
We may use your Personal Information to personalize your experience accessing this website of any Services, including recommending services, content, and offers based on your preferences and behaviors.
We may use your Personal Data to analyze, develop, enhance and improve the website and our Services or develop new services or products by studying the use of the website and our Services, and analyzing interest and engagement in our Services.
Except where consent is required, and unless you have opted out of receiving marketing communications, it is in our and our marketing partners’ legitimate interests to collect and use your Personal Information for marketing and advertising purposes. We or our advertising partners may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email, custom audiences advertising, and “interest-based” or “personalized advertising”.
We will use or disclose your Personal Information if we reasonably believe that it is required or necessary to comply with the applicable laws, regulations or rules, lawful requests, and legal process, such as to respond to subpoenas or requests from any court of a competent jurisdiction and government authorities. We may also use your Personal Information to (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the websites; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. In these circumstances, we will process your Personal Information to either comply with a legal obligation or when it is in our legitimate business interests. Furthermore, the IP addresses may be evaluated, together with other data, in case of attacks on the network infrastructure or other unauthorized use or misuse of the websites, for the purpose of intelligence and protection, and if appropriate, used in criminal proceedings for identification and civil and criminal proceedings against the relevant users. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. of the General Data Protection Regulation (GDPR).
It is in our legitimate business interests to create anonymous data from Personal Information collected by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Websites and promote our business.
We may use your Personal Information for such purposes as disclosed to you at the time you provide your Personal Information or with your consent.
We will not make available or disclose your Personal Data to any third parties, save for the provider of the website, unless you have expressly consented to it or if we are required to disclose under any applicable laws, regulations, or rules, or where it is necessary to enforce our rights concerning a contractual relationship. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR. Notwithstanding the aforementioned, we may disclose your Personal Data for the following purposes:
By using the websites, you understand and acknowledge that we may transfer your Personal Information to service providers or other third parties who are located in various countries globally. This includes service providers of the websites and e-commerce providers such as payment solution providers to assist us in the processing of your online payments. When we transfer your Personal Data to third parties abroad for the purposes of the data processing described in this Privacy Policy, unless we can rely on a derogation provided under data protection law, we will ensure that relevant safeguards are in place to afford adequate protection for your Personal Information and we will comply with applicable data protection laws, in particular if you reside in the Cayman Islands, UK or the EEA by relying on a UK government adequacy regulation or adequacy decision by the European Commission, or on contractual protections for the transfer of your Personal Information. We may also rely on specific contracts approved by the European Commission which offer Personal Data protection. For more information about how we transfer Personal Data internationally, please contact us as set out in the “Contact Us” section below.
Subject to the applicable data protection laws of the jurisdiction you are subject to, the rights available to you in relation to your Personal Data are as follows:
You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of any marketing email. You may continue to receive service-related and other non-marketing emails.
Have access to the Personal Information we hold about you (including, if applicable, to obtain such information in a structured and commonly-used machine readable format).
Request to have any incomplete or inaccurate Personal Information we hold about you corrected, subject to the fulfilment of any verification requirements.
Request to delete or remove Personal Information where such information is no longer required by us.
Object to the processing of your Personal Data unless it is necessary, or we have compelling legitimate interest to process such Personal Data.
To withdraw your consent to us to process your Personal Data, where we rely on your consent for the processing of such Personal Data. For the avoidance of doubt, this shall not affect the lawfulness of any Personal Data processing prior to your withdrawal.
We take the protection of your Personal Data seriously. We protect Personal Data against manipulation, partial or complete loss, misuse, and unauthorized access with appropriate physical, technological and organizational safeguards and security measures. However, data transmission over the internet (including via blockchain) cannot be guaranteed as completely secure. We do not warrant or guarantee the security of any Personal Data transmitted to us via the internet or through a blockchain. Please note that any data transmission on the internet (including through blockchains) is generally not secure or may be accessed by third parties, and we accept no liability for data transmitted to us via the internet or through a blockchain.
When you submit a job application to us or visit the “Join Us” or “Careers” portion of our website, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diverse information that you voluntarily provide. When required, we will only process sensitive personal information with your consent. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to provide improved administration of the website, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend the rights or property of us or others; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service. In these circumstances, we will process your Personal Information to either enter into a contract with you, to comply with a legal obligation or when it is in our legitimate business interests.
We store the Personal Information we collect as described in this Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
The website and Services are not intended for use by children under 13 years of age and we do not knowingly collect Personal Information from children. If we learn that we have collected Personal Information from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it. If you are a parent or guardian and believe that your child under 13 has provided any Personal Information to us without your consent, you may contact us as described in the “Contact Us” section below.
If you have a concern about our privacy practices, including the way we handle your Personal Information, please contact us at legal@zkcandy.io. We will endeavor to respond to your complaint as soon as possible. This is without prejudice to your right to report it to any data protection authority that is authorized to hear those concerns.
ZK Candy is the data controller in respect of your Personal Data processed in connection with the website and the Services under this Policy. If you have any queries about our privacy practices, this Policy or would like to exercise your rights with respect to your Personal Data as stated herein, please contact us at legal@zkcandy.io.