Marketing Consent Policy

Last updated: 2023/05/29

Introduction

We value your privacy and are committed to ensuring that your personal data is protected. This Marketing Consent Policy outlines how we collect and use your consent to send you marketing communications.

What are you agreeing to?

You may be about to create or have created a zkMe account, most likely for the purposes of onboarding with one of the “Integrators” of zkMe (companies that use our software solution to onboard their customers). zkMe gives you a digital identity wallet that you can use to onboard with the services of our Integrators.

Additionally, we partner with our Integrators and other companies - our “Partners” - to offer you a variety of benefits (e.g., bonuses for registering with our Partners, discounts in trading fees when using our Partners' services, etc.). Our Integrators and Partners are financial services providers, in particular FinTechs. For example, cryptocurrency exchanges and trading platforms, providers of crypto wallet infrastructure, crypto-backed lending platforms, crypto savings accounts providers, digital banks, etc. Our Integrators and Partners can also be providers of services that support the operation of the FinTech industry, for example, crypto tax software providers, etc.

  • Your Personal Data is collected from you when:
  • You visit our Website;
  • You request assistance from our customer support team by filling out the 'Contact Us' form;
  • You complete surveys, subscribe to newsletters, or request other information from us;
  • You participate in contests, apply for a job, or participate in activities where we may require information about you.
  • By agreeing to this Marketing Consent Policy, you agree to receive, through e-mail, SMS (depending on the registration method you select), as well as social media accounts/handles and any other means of communication you provide us, advertising and marketing information from us about:

  • Sending promotional emails about our products and services.
  • Providing information about special offers and promotions.
  • Inviting you to participate in surveys and feedback sessions.
  • Informing you about updates and new features.
  • Our identification product and service, including new features or new Integrators and Partners;
  • The products and services of our Integrators and Partners;
  • The products and services offered by zkMe Labs, with registered address at zkMe Labs, PO Box 2775, 71 Fort Street, 3rd Floor, Grand Cayman, KY1-1111, Cayman Islands, commercial registration number CR-408273.
  • Our third-party partners may use technologies such as cookies to gather information regarding your activities on our web pages and other websites in order to provide you with advertising based on your interests, and to measure the effectiveness of the advertisements.
  • For these purposes, we will process your e-mail address or your mobile phone number (depending on the registration method you select), as well as social media accounts/handles and any other means of communication you provide us. You confirmed your ownership over the e-mail or phone number that will be used for advertising and marketing communication by clicking on a confirmation link we sent you via e-mail or SMS. You also confirm your ownership of the social media accounts/handles and any other means of communication you provide us.

    How We Use Your Information

    We will use the information provided by you solely for the purposes mentioned above. We ensure that your data is stored securely and used responsibly.

    Integrators and Partners communications

    By agreeing with this Marketing Consent Policy, you also instruct us to share your email address or mobile phone number (depending on the registration method you select), as well as social media handles and any other means of communication you provide us with partners in order to be directly contacted by them about products and services.

    You may opt out of such a feature at any time by sending an e-mail to [[email protected]].

    For these purposes, we will process your e-mail address or your mobile phone number, (depending on the registration method you select), as well as social media accounts/handles and any other means of communication you provide us. You confirmed your ownership over the e-mail or phone number that will be used for advertising and marketing communication by clicking on a confirmation link we sent you via e-mail or SMS. You also confirm your ownership of the social media accounts/handles and any other means of communication you provide us.

    zkMe Labs does not offer nor employs individuals to offer such Partner’s products or services. You acknowledge that zkMe Labs does not supervise, direct, control or monitor Partners in the offering of these products or performance of these services and agree that we are not responsible for the offering, performance or procurement of these products or services, that we do not endorse any particular Partner’s offered product or services, and that nothing shall create an employment, agency, or joint venture relationship between zkMe Labs and any Partner. You agree that we are not responsible for Partner’s or others’ content or information and that we are not responsible for any misuse of our Services.

    Opting Out

    You have the right to withdraw your consent at any time. If you choose to opt out, you can do so by:

  • Clicking the "Unsubscribe" link in any of our marketing emails.
  • Contacting our customer support team at [[email protected]].
  • Upon receiving your request to opt out, we will promptly remove you from our marketing list.

    Your Data Subject rights

    We adhere to strict security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. Your information is stored securely and is only accessible to authorized personnel.

    You may contact our Data Protection Officer (DPO) for any reason through the "Contact Us" form or via the following e-mail address: [email protected].

    If you make a request to delete your personal data, that request will be honored only to the extent where the data is no longer needed for the Services, or when it is no longer required for our business, legal or contractual record-keeping requirements. Any request to delete all or any personal data related to a visitor is fulfilled within 30 days. This period is justified by the complexity of the systems and technologies we operate to process the data.

    Where a Personal Data Breach occurs or is suspected, it is reported immediately to the DPO or the CEO and, where applicable, to the data protection authority and the individual affected by the breach. The report includes full and accurate details of the incident (including its reasons and magnitude) and sets out the planned measures intended to eliminate the breach.

    As the Data Controller, we respect and guarantee the following rights of each Data Subject:

  • Right to obtain confirmation as to whether or not his or her personal data is being processed (§15 of the EU GDPR);
  • Right to rectification (§16 of the EU GDPR);
  • Right to erase Personal Data (§17 of the EU GDPR) if one of the following applies: (i) the Personal data is no longer necessary in relation to the purposes for which was collected or otherwise processed; (ii) Data Subject objects to the Processing and there are no overriding legitimate grounds for the Processing; (iii) the Personal Data has been unlawfully processed;
  • Right to restrict personal data processing (§18 of the EU GDPR) if one of the following applies: (i) the accuracy of the personal data is contested; (ii) the processing is unlawful and the Data Subject objects to the erasure of the Personal Data and requests to restrict their use instead; (iii) zkMe Labs no longer needs the Personal Data for the purposes of the processing, but they are required by the Data Subject to establish, exercise or defend legal claims; (iv) the Data Subject has objected to processing pending the verification whether zkMe Labs legitimate grounds override those of Data Subject;
  • Right to be informed (§19 of the EU GDPR);
  • Right to data portability (§20 of the EU GDPR);
  • Right to object (§21 of the EU GDPR) if the processing is justified by the "public interest" or "legitimate interest" legal ground as set out in point (e) and (f) of §6(1) of the GDPR;
  • Right not to be subject solely on automated processing (§22 of the EU GDPR) unless one of the following applies: (i) such decision is necessary for entering into, or performance of a contract; (ii) such decision is authorised by the law to which zkMe is subject and which also lays down suitable measures to safeguard the Data Subject's rights and freedoms and legitimate interests, or (iii) such decision is based on the Data Subject's explicit consent;
  • Right to lodge a complaint (§77 of the EU GDPR).
  • We guarantee that making a request for receiving personal data is free unless a reasonable cost is to be charged where requests are unfounded or excessive or repetitive in character.

    General Provisions

    We may modify this Marketing Consent Policy and any other documents linked or referred to in these policy (together, “Documents”), or any portion of the Documents. You should look at these documents regularly. We may notify you of modifications to the Documents by posting a notice or by sending you an email (using the address you provided when registering), as we may determine, at our sole discretion, on a case-by-case basis. Your login and/or continued use of our services constitutes your acceptance of the modification to the Documents and/or to the functionalities of the services. You instruct us to, whenever the Documents are modified, to post them online or to send you via e-mail, as we may determine in our sole discretion, and confirm that you will be responsible for reviewing the Documents link or the e-mail and in case of non-agreement, you will send an e-mail informing us of the same.

    Contact Us

    If you have any questions or concerns about this Marketing Consent Policy or our data practices, please contact us at:

  • Email: [[email protected]]
  • Address: [zkMe Labs, PO Box 2775, 71 Fort Street, 3rd Floor, Grand Cayman, KY1-1111, Cayman Islands]
  • Thank you for trusting us with your personal data. Your privacy and satisfaction are important to us.