This privacy policy (“Policy”) describes how ConsenSys Software Inc. (“Company”, “we”, “our”, or “us”) collects, uses, shares, and stores personal information of users of its websites https://exzocoin.com and exzoswap app (the “Sites”). This Policy applies to the Sites, applications, products and services (collectively, “Services”) on or in which it is posted, linked, or referenced. 

By using the Services, you accept the terms of this Policy and our Terms of Use, and consent to our collection, use, disclosure, and retention of your information as described in this Policy.  If you have not done so already, please also review our terms of use. The terms of use contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.

Please note that this Policy does not apply to information collected through third-party websites or services that you may access through the Services or that you submit to us through email, text message or other electronic message or offline.

If you are visiting the Sites from the European Union (EU), see our Notice to EU Data Subjects below for our legal bases for processing and transfer of your data. 

 

WHAT WE COLLECT

We get information about you in a range of ways. 

Information You Give Us. Information we collect from you may include:

  • Identity information, such as your first name, last name, username or similar identifier, title, date of birth and gender;
  • Contact information, such as your postal address, email address and telephone number;
  • Profile information, such as your username and password, interests, preferences, feedback and survey responses;
  • Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support or otherwise correspond with us;
  • Financial information, such as your credit card or other payment card details;
  • Transaction information, such details about purchases you make through the Service and billing details;
  • Usage information, such as information about how you use the Service and interact with us;
  • Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;
  • Financial information, such as bank account number and bank routing number; financial assets holdings; and
  • Technical information, such as your Ethereum wallet address, application programming interface (API)-key and network information regarding transactions. Please note that your Ethereum wallet address is not collected by https://metamask.io/ or associated plugins and mobile applications (“Metamask”). 

Further Information You Give Us In Relation to the Codefi Site and Codefi Services. Further information we collect from you in relation to https://codefi.consensys.net/ (the “Codefi Site”) and Codefi Services may include:

  • Further identity information, such as your country of birth, nationality, social security number, place of birth, employer and occupation;
  • Passport and/or photo ID for identity verification purposes; 
  • Information required to comply with anti-money laundering (AML) laws and know-your-customer (KYC) requirements (such as nationality and place of birth); 
  • Source of funds for participating in token launches; and
  • Information that you give us in relation to your purchased token holdings, such as earnings received from staking, and the number of tokens in your wallet. 

Information We Get From Others. We may get information about you from other third party sources and we may add this to information we get from your use of the Services. Such information may include:

  • Registration using Single Sign-On Account: When registering some user accounts (e.g. with the Codefi Site), you also have the option of using a single sign-on account (“SSO”). With an SSO, you can sign up for various different services and platforms with a single account. Some of our Sites currently offer you the opportunity to use the SSO services offered by  Google, LLC, Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google’s Privacy Policy and Terms of Use apply to the registration and use of the Google SSO service, see https://policies.google.com/privacy/. Please note that the registration for and the use of SSO services are subject to the Google privacy policy and terms of use, which are beyond our control.

Information Automatically Collected. We may automatically record certain information about how you use our Sites (we refer to this information as “Log Data“). Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Sites to which a user browsed and the time spent on those pages or features, the frequency with which the Sites are used by a user, search terms, the links on our Sites that a user clicked on or used, and other statistics. We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.

We may use cookies, local storage or similar technologies to analyze trends, administer the Sites, track users’ movements around the Sites, and to gather demographic information about our user base as a whole. Users can control the use of cookies and local storage at the individual browser level. For more information, please see our Cookies Policy.

We also may use Google Analytics to help us offer you an optimized user experience.  You can find more information about Google Analytics’ use of your personal data here: https://www.google.com/analytics/terms/us.html. Please note that Metamask does not use Google Analytics in its wallet. 

We use Segment, an event tracking tool, in some of our Services in order to better understand how you are using the Sites. You can find more information about Segment’s use of your personal data here: https://segment.com/docs/legal/privacy/

We also use Mixpanel in some of our Services in order to better understand how you are using the Sites. You can find more information about Mixpanel’s use of your personal data here: https://mixpanel.com/legal/privacy-policy/

We use Hotjar in some of our Services in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Sites). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link. Please note that Metamask does not use Hotjar. 

Information we will never collect. We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed. 

 

USE OF PERSONAL INFORMATION

To provide our service

We will use your personal information in the following ways:

  • To enable you to access and use the Services
  • To provide and deliver products and services that you may request.
  • To process and complete transactions, and send you related information, including purchase confirmations and invoices
  • To send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws (including anti-money laundering (AML) laws and know-your-customer (KYC) requirements), lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.  

To communicate with you

We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.

To optimize our platform

In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our Services. We may also use your information to respond to your comments and questions regarding the Services, and to provide you and other users with general customer service. 

With your consent

We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Sites, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.

For compliance, fraud prevention, and safety

We may use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

 

SHARING OF PERSONAL INFORMATION

We do not share the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We disclose personal information to third parties under the following circumstances: 

  • Affiliates. We may disclose your personal information to our subsidiaries and corporate affiliates (i.e. our family of companies that are related by common ownership or control) for purposes consistent with this Privacy Policy.
  • Business Transfers. We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • Compliance with Laws and Law Enforcement; Protection and Safety. We may share personal information for legal, protection, and safety purposes.
    • We may share information to comply with laws, including KYC and AML requirements.
    • We may share information to respond to lawful requests and legal processes.
    • We may share information to protect the rights and property of the Company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
    • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
  • Professional Advisors and Service Providers. We may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the Service on our behalf (such as bill and credit card payment processing, customer support, hosting, email delivery and database management services), as well as lawyers, bankers, auditors, and insurers.
  • Other. You may permit us to share your personal information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities. 

We may also share aggregated and/or anonymized data with others for their own uses.

 

INTERNATIONAL TRANSFER

The Company has offices outside of the EU and has affiliates and service providers in the United States and in other countries. Your personal information may be transferred to or from the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

EU users should read the important information provided  below about transfer of personal information outside of the European Economic Area (EEA).

 

HOW INFORMATION IS SECURED 

We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this privacy policy. In addition, we retain personal information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use, and other actions permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.

 

INFORMATION CHOICES AND CHANGES

Accessing, Updating, Correcting, and Deleting your Information

You may access information that you have voluntarily provided through your account on the Services, and to review, correct, or delete it by sending a request to [email protected] You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences.

Tracking Technologies Generally

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. For more information, please see our Cookies Policy

Google Analytics

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

 

CONTACT INFORMATION. We welcome your comments or questions about this Policy, and you may contact us at: [email protected]

 

CHANGES TO THIS PRIVACY POLICY. We may change this privacy policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Sites (or as otherwise indicated at the time of posting). In all cases, your continued use of the Sites or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

 

ELIGIBILITY

If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Sites and subsequently we will delete that information.

 

NOTICE TO CALIFORNIA RESIDENTS

Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we collect from you, please see the “What We Collect” section above. We collect this information for the business and commercial purposes described in the “Use of Personal Information” section above. We share this information with the categories of third parties described in the “Sharing of Personal Information” section above. Company does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please refer to our Cookies Policy for more information regarding the types of third-party cookies, if any, that we use.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected] Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

 

NOTICE TO EU DATA SUBJECTS

Personal Information

With respect to EU data subjects, “personal information,” as used in this Privacy Policy, is equivalent to
“personal data” as defined in the European Union General Data Protection Regulation (GDPR). 

Sensitive Data

Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.

Legal Bases for Processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal bases under which we process your personal information, contact us at [email protected]

At Exzo, we’re committed to protecting and respecting your privacy. This Privacy and Cookie Policy (“Privacy Policy”) govern your access to and use of this Website, Exzo.com (the “Website”), and associated content, software, and mobile applications (collectively, the “Service”). This Privacy Policy also includes our Terms of Use which is located at https://Exzo.com/terms. This Privacy Policy explains when and why we collect personal information about people who visit our Website or use our Services and how we use the personal information, the conditions under which we may disclose your personal information to others, and how we keep personal information secure. This Privacy Policy also explains how we use cookies and similar technology on our Website and in connection with our Services. We may change this Privacy Policy from time to time so please check this page occasionally to ensure that you are happy with any changes. By using our Website or our Services, you are agreeing to be bound by this Privacy Policy. What Information Do We Collect? Exzo (“Exzo”, “we” or “us”) collects (a) the e-mail addresses of those who communicate with us via e-mail; (b) aggregate information concerning what pages users access or visit; (c) information volunteered by the user (such as survey information and/or site registrations); (d) financial information provided by the user for user syncing and information purposes only; and (e) information related to your use of the Website and/or the mobile application, including IP address, geographic location, and date and time of your request. How Do We Use the Information? Exzo uses collected information for the following purposes: To fulfill a contract or take steps linked to a contract such as processing your registration on our Website or sending you information about changes to our terms or policies; Where it is necessary for purposes which are in Exzo’s or third parties’ legitimate interests such as (a) to provide the information or content you have requested; (b) to contact you about our programs, products, features or services; (c) for internal business purposes such as identification and authentication or customer service, portfolio tracking and user preference syncing between devices; (d) to ensure the security of our Website, by trying to prevent unauthorized or malicious activities; (e) to enforce compliance with our Terms of Use and other policies; (f) to help other organizations (such as copyright owners) to enforce their rights; and (g) to tailor content, advertisements, and offers for you or for other purposes disclosed at the time of collection. If you do not wish to receive marketing information about our programs, products, features or services, you may send an email to us at [email protected] Where you give us consent, such as (a) where you ask us to send marketing information to you via a medium where we need your consent, including alerts via mobile push notifications; (b) where you give us consent to place cookies and to use similar technologies; and (c) on other occasions where we ask you for consent, for a purpose which we explain at that time. Where we are legally required to do so. We may also provide access to your personally identifiable information when legally required to do so, to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorized use of our Website, to limit our legal liability and protect our rights, or to protect the rights, property or safety of visitors of the Website or the public. In those instances, the information is provided only for that purpose. How Do We Share Your Information? We do not share or sell your personal data to other organizations for commercial purposes, except to provide products or services you’ve requested, when we have your permission, or under the following circumstances: It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law. We transfer information about you if Exzo is acquired by or merged with another company. In this event, Exzo will notify you before information about you is transferred and becomes subject to a different privacy policy. We provide such information to trusted businesses or persons for the sole purpose of processing personally identifying information on our behalf. When this is done, it is subject to agreements that oblige those parties to process such information only on our instructions and in compliance with this Privacy Policy and appropriate confidentiality and security measures. We provide such information to third parties who have entered into non-disclosure agreements with us. We provide such information to a company controlled by, or under common control with, Exzo for any purpose permitted by this Privacy Policy. We may aggregate, anonymize, and publish data for statistical and research purposes only. For example, we may compile and share information related to the popularity of certain products tracked by users. In any such instance, the information will not be able to be traced back to any individual. Cookies and Web Beacons A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a Website’s computers and stored on your computer’s hard drive. Cookies are required to use some Exzo services. Exzo and its ad management partners (“Ad Partners”) use cookies to record current session information. Our Ad Partners may also from time to time use web beacons (also known as Internet tags, pixel tags, and clear GIFs). These web beacons are provided by our Ad Partners and allow Ad Partners to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the Ad Partners. Web beacons enable our Ad Partners to recognize a unique cookie on your web browser, which in turn enables us to learn which advertisements bring users to our Website. With both cookies and web beacon technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, geographic location, telephone number, or e-mail address. You can opt-out of Google Analytics data collection with the Google Analytics Opt-out Browser Add-on. You may also wish to refer to this website for additional information about disabling cookies from your browser: http://www.allaboutcookies.org/manage-cookies/. Data Storage Exzo uses third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run Exzo and the related Website and mobile application. Exzo owns the code, databases, and all rights to the Exzo Website and mobile application and Services. Security We take precautions to ensure the security of your personal information. However, we cannot guarantee that hackers or unauthorized personnel may gain access to your personal information despite our efforts. You should note that in using the Exzo service, your information will travel over the Internet and through third-party infrastructures and mobile networks, which are not under our control. We cannot protect, nor does this Privacy Policy apply to, any information that you transmit to other users. You should never transmit personal or identifying information to other users. Retention of Your Personal Information We retain information as long as it is necessary to provide the Services requested by you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until you ask us to delete it or your account is deleted, whichever comes first. Additionally, we may retain information from deleted accounts to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Use, and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy. Information about you that is no longer necessary and relevant to provide our Services may be de-identified and aggregated with other non-personal data to provide insights which are commercially valuable to Exzo, such as statistics related to the use of Exzo’s Website and application. Children The Exzo service is not intended for children under the age of 16, and we do not knowingly collect information from children under the age of 16. Children aged 16 or younger should not submit any personal information without the permission of their parents or guardians. By using the Exzo service, you are representing that you are at least 18 years old, or that you are at least 16 years old and have your parents’ or guardians’ permission to use the Service. Consent to Worldwide Transfer and Processing of Personal Information Exzo is located in the United States. and the terms of this Privacy Policy and the related Terms of Use shall be governed by and construed in accordance with U.S. federal law and the laws of Delaware, without regard to any principles of conflicts of law. If you are not located in the United States, by accessing the Website and Services and providing personal information through it, you agree and acknowledge and consent to the collection, maintenance, processing, and transfer of such information in and to the United States and other countries and territories. These other jurisdictions may have different privacy laws from your home jurisdiction and provide different levels of protection of personal information. Exzo does have processes and procedures in place to provide adequate levels of protection to protect the transfer of data from the European Union. You agree that the terms of this Privacy Policy and the Terms of Use will apply, and you consent to the transmission and processing of your personal information in any jurisdiction. EU and EEA Users’ Rights If you are habitually located in the European Union or European Economic Area, you generally have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We briefly describe these rights below: You have the right to access your personal data and, if necessary, have it amended, deleted or restricted. In certain instances, you may have the right to the portability of your data. You can also ask us to not send marketing communications and not to use your personal data when we carry out profiling for direct marketing purposes. You can opt out of receiving e-mail newsletters and other marketing communications by following the opt-out instructions provided to you in those e-mails. Transactional account messages will be unaffected even if you opt out from marketing communications. Complaints Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority, although we hope that we can assist with any queries or concerns you may have about our use of your personal data. Your California Privacy Rights California Consumer Privacy Act (CCPA) In the last twelve months, Exzo may have collected, used, and shared, for business purposes, personal information about you as described in this Privacy Policy. Each category of data may be used by Exzo or shared with third parties also as described in this Privacy Policy. Residents of California have the right to request access to and deletion of the information Exzo holds about them. Such requests may be submitted by email to [email protected] or by mail to Exzo LLC. Exzo will not sell your personal information without your consent. Exzo will not discriminate against you for exercising your rights under CCPA. Specifically, we will not: Deny access to our Services; Charge a different rate for the use of our Services; or Provide a different quality of service. Changes Exzo may periodically update this policy. We may notify you about significant changes in the way we treat personal information by placing a prominent notice on our Website so please check back occasionally to ensure that you agree with the changes. If you do not, do not use the Website, the application or our Services. Questions Any questions about this Privacy Policy should be addressed to this e-mail address: [email protected] Effective Date: January 1st, 2020.

I accept & understand that ExzoCoin 2.0 (EXZO) is strictly a utility token not security or any form of investment of any sort. ExzoCoin 2.0 is utilized as a voucher and a loyalty reward system that enables individuals to gain access to our platforms and services. There is no tie or correlation between Exzo's leadership or contractors efforts to the price of the ExzoCoin 2.0 (EXZO) utility token. I understand ExzoCoin 2.0 (EXZO) is NOT an investment of money, not in a common enterprise, purchasers should hold no expectation of profits from the investment, where those profits are derived primarily from the efforts of others. By clicking accept you agree that you acknowledge, accept, and understand the disclaimers. Continuing on to this website without clicking the "I acknowledge & accept" button will act as confirmation of your acceptance of this disclaimer.