Privacy Policy

Zetatech Services Inc. and our affiliates and subsidiaries respect your privacy and are committed to protecting it by complying with this policy. The purpose of this privacy policy is to inform users of the CoinPappa and any associated applications or websites, as to the information we collect, what we do with this information, and how we process your personal information.

CoinPappa (The “Platform” or “CoinPappa”) refers to an ecosystem comprising the website <https://coinpappa.com/> mobile or desktop applications, system of smart contracts, and other applications, products and platforms within the ecosystem, that are developed to offer the CoinPappa Services as defined in the Terms and Conditions.

Privacy Policy Consent

By using our Platform, you consent to the policy and our information administration practices. We may provide additional disclosures in relation to this policy, which will apply supplementary to this policy. These disclosures may expand on information administration practices or provide further clarification for specific practices.

If you disagree with or are not comfortable with any aspect of our policy, you should immediately cease accessing and the use of our Platform and our Services.

Changes to the Privacy Policy

We reserve the right to alter and/or modify this policy at any time. Please review this policy periodically in case of any changes. If any significant or substantive amendments are made, we will notify you by email. We include the date the privacy policy was last revised at the top of the page.

Who Does this Privacy Policy Apply To?

This policy applies to users (e.g., individuals, merchants, and legal entities) who use and access our Platform and Services.

What Personal Information Do We Collect?

We only collect information that is required  to the provision of our Services.

The information that we may collect includes, but is not limited to:

1.       Identification Information

Full name, date of birth, age, nationality, gender, signature, phone number, home address, email, utility bills, income statements, passport number, driver’s license details, national identity card details, photograph identification cards, a photographic image of you, occupation, criminal record and biometrics such as a video of your hand for authentication purposes.

2.       Financial Information

Transaction history, trading data, payment card numbers, bank account information, credit history information from credit bureaus, details about your source of funds, assets and liabilities.

3.       Technical Data Information

Internet protocol (IP) address used to connect your computer to the Internet, login, e-mail address, password and location of your device or computer.

4.       Automatically collected information

Device information (including but not limited to, IP address, device ID, device model, network type, OS version, time zone settings, battery status, screen resolution, etc; device event information, (such as crash reports and system activity details); your browsing behaviour while using our Platform and/or Services.

5.       User Data

User account details, username, passwords, phone number, purchase history, records of any interactions with our Platform’s specialists, customer service, or support teams (including emails, chat logs, or phone call transcripts), digital wallet and digital asset trading data, frequency and times of Platform usage, and other details necessary for account management.

6.       Other Information

Information about your activity and your behaviour, occupation, hobbies, trading experience, interests, preferences, for marketing and advertising purposes and any other information we require to comply with our legal obligations.

How We Collect Information about you

We use different methods to collect your information, including through:

1.       Direct interactions with you when you provide it to us, for example, by signing up for the Platform, using the Platform, and filling in forms or corresponding with us by phone, email, or otherwise.

2.       The financial institutions you use to transfer funds to us.

3.       Credit checking agencies may provide us with your personal information when we do a credit check.

4.       Through monitored, tracked and recorded of our Platform by transactional monitoring tools.

5.       Automated technologies or interactions, as you navigate through our Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

6.       We engage in affiliate marketing, which is done by embedding tracking links into third party websites. If you click on a link for an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commissions. An affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and links to <https://coinpappa.com/>.  As part of this program, we provide third parties with a customized links to track the referrals from third partywebsite. This program utilizes cookies to track visits for the purposes of assigning commission on these sales.

Why Do We Collect This Information?

1.       To Provide you with our Services

The information collected allows us to register you as a new customer, verify your identity, conduct criminal and credit check and provide you with our products and services.

2.       To Create a Better Experience for Our Users

The collection of data will allow us to update and create new services that will better meet our user’s needs. We endeavour to create a more personalised experience for our users.

3.       To Protect Our Users

The collection of transaction information will allow us to identify any suspicious activity that may lead to fraud or loss of funds. This may include enhancing security, combating spam and malware devices, and identifying and combating botting programs. As the crypto space is ever changing, we need to combat new risks affiliated with that. Devoid of your personal information, it will be difficult for us to ensure the security of our service. 

4.       To Comply with Regulatory Requirements

Our Services may be subject to regulations that require us to collect your personal information, which will be used to maintain compliance with Know Your Customer, Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its associated regulations, as well as any other regulations that are legislated in the future, whether national or international. Some of the information that is required to be collected pursuant to these regulations include personal identification information, personal usage information, financial information, and employment information.

5.       To Enforce our Terms in Our User Agreement

It is important for us to regulate our Services and users relating to the prevention and mitigation any potentially prohibited activities, enforcing our agreements with third parties, and violations of our user agreement or terms and conditions. For these purposes, it is essential for us to collect user data.

If we are unable to process user information for these reasons, the consequence is the termination of your access or use of our Platform and Services, as we cannot perform our Services in accordance with our terms.

6.       Maintain your Registration as a User

This will allow you to access your account safely and securely whenever and wherever you are.

7.       Ensure Quality Control

We store user information for quality control and staff training, to ensure we provide users with accurate information.

8.       Marketing Activities

We may send you marketing or promotional offers to inform you of CoinPappa or our affiliate’s events, to deliver targeted marketing, and to provide you with promotional offers based on your communication preferences. We use information relating to your usage of CoinPappa and contact information to provide a better marketing experience.

Who Will We Share Your Information With?

Information that we collect may  be used or disclosed to:

·         individuals, entities, organisations, as part of CoinPappa providing trading services to users and includes, but is not limited to, experts, tribunals, law firms, enforcement agencies, and other associated professionals;

·         persons the user has expressly authorised or consented;

·         our associated commercial and business partners, which include, but are not limited to, professional advisors, commercial organisations, and business agents;

·         comply with legal obligations or requirements;

·         develop business and commercial relationships;

·         respond to any enquiries where necessary; and

·         all other matters, services, engagements, business developments, and commercial enterprises to the maximum extent permitted by law;

·         Third-party program restriction providers, fraud prevention vendors and anti-cheating detection providers to block cheating tools and unauthorized programs, and provide a safe and fair trading environment;

·         real-time voice transmission platform providers to provide voice chat services;

·         Identity verification service providers in order to provide identity verification services;

·         online survey service providers in order to improve the CoinPappa’s Services;

·         marketing platforms and providers of analytics services relating to trading behaviour, in order to tailor the Services and conduct marketing activities.

We may share your information in situations where it is necessary to comply with a legal obligation or a legitimate request for data access. It may also be shared during a merger or acquisition, with our affiliated entities for the purposes outlined in this Policy, or when you have explicitly given your consent or provided instructions.

Do we use cookies?

Cookies are small files which a platform uses to identify you when you come back to the site and to store details about your use of the site.

Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our Platform.

CoinPappa and our authorised third parties, may use cookies, and/or other tools to store and sometimes track information, such as analysing website traffic to help us provide a better website visitor experience. We may also collect certain information such as browser type, operating system, IP address, etc. This information isused in an aggregated manner to analyse how people use our site, such that we can improve our service.

Our goal is to ensure a trading environment that is both secure and equitable for every player. By accessing our Platform and Services, you acknowledge that we or third parties may employ cookies and similar technologies, or gather information about your device or machine, to prevent fraud, enhance security, and authenticate your identity. Additionally, we may utilize alternative anti-cheat measures in conjunction with our services.

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Why We Share Personal Information with Other Parties

We will never sell or rent your personal information. We will only share your information in the following circumstances:

·         We share your information with third party identity verification services to prevent fraud. We share this information to confirm your identity with relevant public records to prevent fraud. These third-party services will store your information; however, they will only use this information for purposes of identity verification.

·         We may share your information with service providers. These services providers may include debt collection service agents, marketing firms, and technology services. All service providers are contracted to solely use this information for purposes that we have provided it for.

·         We will share your information with financial institutions which we have partnered with to process payments.

·         We may share your information with companies or entities that we purchase or merge with. The new company or entity will uphold this policy.

·         We may share your information with law enforcement officials or other entities when required to do so under applicable law.

·         We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our terms or any other applicable policies.

How We Protect and Store Personal Information

We may hold sensitive information in our facilities or service providers located worldwide. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

We cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please note that the user plays a critical role in ensuring their own personal information.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us.

If you have reason to believe that your data is no longer secure, please contact us at the email address, mailing address or telephone number listed at the end of this Privacy Policy.

Personal Information Rights

You have a right to access and correct personal information that we hold about you. You can also require any inaccurate personal information to be corrected or deleted.

You can withdraw consent to our use of your personal information at any time.  Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

If you wish to exercise any of these rights, please contact us as set out below.

How You Can Access or Change Personal Information

International Data Transfers

Data Retention

Our Policy Concerning Children

Links and Third-Party Services

Contact Information and Challenging Compliance

You are entitled to review, correct, or amend your personal information, that information where it is inaccurate. You may do this by contacting us.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Our operations span across the globe, and in order to deliver our Services, we may transfer your data to countries and regions beyond your current location. Should your personal information be transferred, stored, or processed by us, we will make reasonable efforts to protect the privacy of your personal information. We may store, process and/or transfer your information outside your jurisdiction of residence. While such information is outside of your jurisdiction of residence, it is subject to the laws of the jurisdiction in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other jurisdiction pursuant to local laws. Specific regions within certain countries where data processing takes place are outlined in further detail below.

By submitting your information or engaging with the Platform, you consent to this transfer, storage, or processing. If you have any questions about foreign transfers of information, you may contact us using the information below.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Without obtaining verifiable parental consent or as permitted by law, we do not intentionally gather, utilize, or disclose any information about children (the age threshold may vary depending on the country of residence). If you are a parent or guardian and you believe that your child has shared information with us, you can reach out to us at our contact information below and request the deletion of your child’s information from our system.

By clicking on a link to a third-party website, which includes advertisements, you will be directed away from our Site to the chosen website. As we lack control over the actions of third parties, we are not accountable for how they utilize your personal information, and we cannot guarantee that they will maintain the same privacy and security measures as we do. We recommend that you thoroughly review the privacy policies of any other service provider you engage with. Prior to sharing any personal information, it is advisable to consult the privacy policy of any linked third-party website associated with our Services.

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Privacy Officer CONTACT@ZETATECHSERVICES.COM

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

General Data Protection Regulations (GDPR)

The General Data Protection Regulations (GDPR) apply to organisations who process data in the EU as well as organisations that offer goods or services to or monitors the behaviour of the people inside the EU. The GDPR applies to all information that can directly or indirectly influence an individual.

We have prepared ourselves for the GDPR by providing information as to when our data is deleted, a transparent overview of our use of the personal information it has collected, and detailed how you can exercise your privacy rights.

European Union Residents have the following rights:

1.       Right to Withdraw

You will have the right to withdraw your consent to process your personal information.

2.       Right to Request

You have a right to request that we provide you with a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others.

3.       Right to Update

You have the right to request that we update any of your personal information that you believe incorrect or inaccurate.

4.       Right to Erasure

You have the right to request erasure of your personal information that:

(a)     is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

(b)    was collected in relation to processing that you previously consented, but later withdraw such consent; or

(c)     was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

5.       Right to Data Portability

If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

A “controller” Is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.

6.       Right to Restriction of or Processing

You have the right to restrict or object to us processing your personal information where one of the following applies:

(d)    You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.

(e)     The processing is unlawful, and you oppose the erasure of your personal information and request the restriction of its use instead.

(f)      We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defence of legal claims.

(g)    You have objected to processing, pending the verification.

7.       Restricted Personal Information

Restricted Personal Information shall only be processed with your consent or for the establishment, exercise, or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.

8.       Notification of Erasure, Rectification and Restriction

We will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information has been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information.

9.       Right to Object to Processing

Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable law.

10.   Automated individual decision-making and profiling

You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

11.   Right to Complaint

If you believe we have infringed your rights, we kindly request that you contact prior to lodging a complaint with the relevant authorities so that we may attempt to resolve the dispute.

However, if you have unresolved concerns, you have the right to complain to the data protection authority in the location in which you live, work, or believe a data protection breach has occurred.

Jurisdiction-Specific Supplemental Terms

In the event of a conflict between the terms of this Privacy Policy and the Jurisdiction-Specific Supplemental Terms which pertain to the jurisdiction from which you access CoinPappa, the relevant jurisdiction’s Supplemental Terms will prevail.

1.       EEA, Switzerland, and the UK

If you are an EEA (European Economic Area), Switzerland, or a UK residents, you may have additional rights:

International Data Transfer: If we move your data outside the European Economic Area (EEA) to a country that does not have a recognized level of data protection as determined by the European Commission, we make every effort to implement appropriate measures to protect your personal data in accordance with relevant data protection and privacy laws. These measures may include using data transfer agreements that incorporate the latest standard contractual clauses, which are pre-approved by the European Commission and offer sufficient safeguards for personal data. If you wish to obtain a copy of these measures, please contact us as specified in this Policy. In other cases, we transfer personal data with your consent, to fulfill a contractual obligation, or based on a legitimate interest that does not override your rights and freedoms.

Your Privacy Rights: You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

2.      California

If you reside in California you may have additional rights, as listed here:

Privacy Notice for California Residents: This Privacy Notice (“Notice”) for California residents provided pursuant to the California Consumer Privacy Act (“CCPA”) supplements the Privacy Policy of CoinPappa Trading Systems and its affiliates (“we”, or “us”) and provides additional information on how your personal information is collected, used, disclosed and processed online or offline. Unless otherwise specified, all terms used within this Notice shall carry the same meaning as they are defined in our Privacy Policy(“Policy”). This Notice and the Policy together constitutes our “California Privacy Policy”.

We will collect the following categories of information that may directly or indirectly identify or describe you or your device, or information that may be reasonably capable of being associated with or reasonably linked to you or your device (“personal information”). We have collected these same categories of personal information from consumers over the past 12 months. Please refer to our Policy concerning the categories of sources from which this personal information is collected.

Also, we may provide service providers or third parties with certain personal information to provide or improve our services. Within the past 12 months, we disclosed or shared each of the following categories of personal information with the following categories of third parties. We do not sell personal information to third parties as that term is defined by the CCPA.

You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at contact@zetatechservices.com

Please note that at least your email address will be required to submit a request. If you exercise your rights via email, you must specify the right(s) you wish to exercise.

We will verify your identity and respond to your request within 45 calendar days. If necessary, we can take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, provided that we notifies you to explain the reason for the delay.

1) Right to Access: You have the right to request the following information up to two times within a 12-month period. Categories of the personal information that was disclosed for a business purpose or sold during the past 12 months, and categories of third parties to whom the information was disclosed or sold.

2) Right to Request Deletion: You have the right to request that the personal information collected from you be deleted.

3) Right to Opt-Out of Personal Information Sales: You have the right to “opt out” by requesting that your personal information not be sold in any form. However, we do not sell personal information.

4) Right to Non-Discrimination: You have the right to not be discriminated against for exercising your privacy rights under the CCPA.

5) Rights for California Minors: Minors under the age of 18 have the right to request the deletion of and/or obtain information posted on websites such as forums or bulletin boards.

6) Shine the Light: You have the right to request the categories of the personal information that we disclosed to third parties in the last year for direct marketing purposes and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for direct marketing purposes.

Authorized Agent: You have the option to appoint another individual or entity (referred to as an “authorized agent”) to act on your behalf regarding your rights as guaranteed by the CCPA. An authorized agent can be either a natural person or a business entity registered with the Secretary of State to conduct business in California, and you must provide explicit authorization for them to make requests for information access or deletion on your behalf.

To utilize an authorized agent for your request, we require a signed permission document from you granting them the authority. Your authorized agent can initiate a request for information access or deletion by sending an email to < SUPPORT@COINPAPPA.COM >. If you reach out to us for the request, we will provide you with the necessary authorized forms for support.

Please note that the aforementioned requirement does not apply if your agent possesses power of attorney according to Probate Code sections 4000 to 4465. However, it’s important to understand that we may reject a request from an agent who fails to provide proof of their authorization to act on your behalf. According to the CCPA, your agent assumes responsibility for implementing and maintaining reasonable security measures to safeguard your information and utilizing your personal information solely for the purpose of fulfilling your request.