Privacy Policy and Statement


Updated and Effective as of July 12, 2018
I. INTRODUCTION

Welcome! Thank you for visiting ZukExchange.com ("ZukExchange"), a digital asset trading website. By visiting, accessing, or using ZukExchange.com and associated application program interface or mobile applications ("Site"), you consent to the policies and practices of our privacy policy (the "Privacy Policy"), so please read them carefully. This Privacy Policy explains how ZukExchange uses your Personal Data (defined below) as we provide you with access and utility through our digital asset trading platform via software, API (application program interface), technologies, products and/or functionalities ("Service").

In the course of providing you our Service, to abide by the laws in the jurisdictions that we operate, and to improve our services, we need to collect and maintain personal information about you. As a rule, we never disclose any personal information about our customers to any non-affiliated third parties, except as described below.

We may update this Privacy Policy at any time by posting the amended version on this site,including the effective date of the amended version. We will communicate any material changes to this Privacy Policy via email.

II. DEFINITIONS

Digital Asset

As used herein, "Digital Asset" means a digital asset, such as bitcoin or ether, which is based on the cryptographic protocol on a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.

Personal Data

As used herein, "Personal Data" means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.

III. WHAT PERSONAL DATA WE COLLECT

ZukExchange collects, processes, and stores Personal Data collected from you via your use of the Service or where you have given your consent. This Personal Data may include contact details, copies of identification documentation provided by you or derived from publicly accessible databases, your government identification number as well as information relating to your device or internet service (such as an IP address and a MAC number).

We collect information you provide during the ZukExchange onboarding process, which may be a completed, incomplete, or abandoned process. We collect, use, store, and transfer your Personal Data, which may include the following:

Operating within the European Economic Area ("EEA"), we collect, store, and process your personal information in accordance with the provisions of the General Data Protection Regulation (GDPR) and the Data Protection Act. To understand more about how we protect the data collected from individuals and entities located within the EEA, please see the details below.

Individual customers:

Email address

Mobile phone number

Full legal name (including former name, and names in local language)

Nationality

Passport number, or any government issued ID number

Date of birth ("DOB")

Proof of identity (e.g. passport, driver's license, or government-issued ID)

Residential address

Proof of residency

Date of birth ("DOB")

Corporate customers:

Corporate legal name (including the legal name in local language)

Incorporation/registration Information

Full legal name of all beneficial owners, directors, and legal representatives

Address (principal place of business and/or other physical locations)

Proof of legal existence

Description of the business

Percentage of ownership for Individual/corporate owners

Contact information of owners, principals, and executive management (as applicable)

Proof of identity (e.g., passport, driver's license, or government-issued ID) for significant individual beneficial owner of the institutional customer entity

Personal Data for each entity's significant beneficial owner of the institutional customer entity (see the "Individual Customer" section above for details on what Personal Data we collect from individuals)

Source of wealth

Amount of bitcoin or other digital assets projected to be injected

IV. COLLECTION AND TRANSFER OF DATA OUTSIDE OF THE EEA

As outlined above, we may collect Personal Data from customers located in the EEA. To facilitate the services we provide to customers located in the EEA, we request explicit consent for the transfer of Personal Data from the EEA to outside of the area. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use ZukExchange and our services. You will have the ability to withdraw your digital assets; however, all other functionalities will be disabled.

V. HOW WE USE YOUR PERSONAL DATA

ZukExchange uses Personal Data to communicate with you and to administer, deliver, improve, and personalize the Service. ZukExchange might also generate generic data out of any Personal Data we collect and use it for our own purposes. We may also use such data to communicate with you in relation to other products or services offered by ZukExchange and/or its partners. We do not share your Personal Data with third parties (other than partners, in connection with their services to ZukExchange) except where you have given your consent and further detailed below.

We may share your Personal Data with third parties:

(a) if we think that sharing it is necessary to enforce the Terms of Service?

(b) to comply with government agencies, including regulators, law enforcement and/or justice departments?

(c) to third parties who provide services to ZukExchange (such as administration or technical services)?

(d) in connection with the sale or transfer of our business or any part thereof.

Additionally, we have implemented international standards to prevent money laundering, terrorist financing and circumventing trade and economic sanctions and will implement final Virtual Financial Asset rules and regulations when effective, which will likely require us to undertake due diligence on our customers. This may include the use of third-party data and service providers which we will cross-reference with your personal information.

VI. HOW WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside of ZukExchange. It may also be processed by staff operating outside of ZukExchange who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing, except customers located in the EEA, as detailed above. All information you provide to us is stored on our and/or third party cloud servers.

VII. ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL DATA

You have the right to obtain a copy of your Personal Data upon request and ascertain whether the information we hold about you is accurate and up-to-date. If any of your Personal Data is inaccurate, you may request to update your information. You may also request to delete your Personal Data, with the exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For data access, correction, or deletion requests, please contact [email protected] with the subject "Media INQUIRY".

In response to data access, correction, or deletion request, we will verify the requesting party's identity to ensure that he or she is legally entitled to make such request. While we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee should your request be repetitive or onerous.

VIII. MARKETING

We may communicate company news, promotions, and information relating to our products and services provided by ZukExchange. We may share Personal Data with third parties to help us with our marketing and promotional projects, or sending marketing communications. By using ZukExchange, you accept this Privacy Policy and you agree to receive such marketing communications.

Customers can opt out of these marketing communications at any moment. If you do not want to receive these communications, please send an email to [email protected]

For product related communications, such as policy/terms updates and operational notifications, you will not be able to opt out of receiving such information.

IX. COOKIE USAGE

While you access ZukExchange, we may use the industry practice of placing a small amount of data that will be saved by your browser (Cookies). This information can be placed on your computer or other devices used to visit ZukExchange. This information helps us recognize you as a customer, collect information about your use of ZukExchange to better customize our services and better your experience. We may also use the information collected to ensure compliance with our compliance program, and to ensure your account security has not been compromised by detecting irregular or suspicious account activities.

Most browsers are set up to accept cookies automatically. Some Cookies expire when you finalize the session and other Cookies remain on your computer or other devices until deleted or expired. You have the option to decline the use of our Cookies, but this may affect the functionality of ZukExchange services or your user experience.

X. INFORMATION SECURITY

We endeavor to protect ZukExchange and you from unauthorized access, alteration, disclosure, or destruction of Personal Data we collect and store. We take various measures to ensure information security, including encryption of the ZukExchange communications with SSL; required two-factor authentication for all sessions; periodic review of our Personal Data collection, storage, and processing practices; and restricted access to your Personal Data on a need-to-know basis for our employees and vendors who are subject to strict contractual confidentiality obligations.

XI. CONTACTING ZukExchange ABOUT PRIVACY QUESTIONS OR CONCERNS

If you have any questions about this Privacy Policy or the use of your Personal Data, please contact us by sending an email to the following address [email protected] with the subject "PRIVACY REQUEST".

XII. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page and, when appropriate, we will notify you by email.