Scope and consent

This Privacy Notice (“Notice”) describes the ways Zinari Finance Inc. (“Zinari”, “we”, “us”, “our”) collects, stores, uses and protects information. Zinari’s services include merchant processing services, websites, mobile applications, products, and any other features, technologies or functionalities, including customer support (“Services”) offered by us. This Notice applies to www.Zinari.org and all other Zinari sites on which it appears (the “Sites”).

Our privacy practices may vary among the countries or territories in which we operate to reflect local practices and legal requirements. For Wyoming residents, please review our Wyoming Consumer Privacy Act Addendum. For EU residents, please review our EU Privacy Notice.

We may process information from the following types of users:

1. Visitors of our Sites;
2. Merchants who sign up for our Services (“Merchants” means any business that uses our Services to process payments, including non-profits that use our Services to accept donations and “Aggregators” that use our Services as a payment services platform for their own Merchants);
3. Shoppers of Merchants (“Shoppers” means individuals who indirectly interface with Zinari when paying a Merchant’s invoice that is forwarded by Zinari to a Merchant during checkout, when requesting a refund from a Merchant, when creating a Zinari account, or when making a donation to a non-profit); Zinari card holders who have signed up for a Zinari debit card;
4. Zinari wallet holders who have downloaded and installed the Zinari app on their mobile device; and
5. Payees (e.g., employees, contractors, vendors or exchange customers) who request a payment (“Payout”) via cryptocurrency from a Merchant and create a Zinari account.

What kind of information do we collect?

We collect different kinds of information when users interact with us. The information we collect depends on the type of user. We collect information you choose to provide to us when interacting with our Services. We may also collect information automatically from your devices. The following sections provide you with some more information.

1. Visitors of Our Sites
2. Merchants (including businesses such as nonprofits and Aggregators)
3. Shoppers of Merchants
4. Cardholders
5. Zinari Wallet Holders
6. Payees of Merchant
7. Additional Collection

How we use cookies

We may collect information about your activities on our sites via first and third-party cookies, clear GIFs or web beacons, or through other identifiers or technologies, including similar technologies as they may evolve over time. We refer to these technologies collectively as cookies.

We may allow third parties to use cookies on our sites. The information collected by cookies may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies. Information collected by cookies may be used on this site or on other websites or services, including those that may not be operated by us. Other parties may collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses our websites or online services. For more information about our use of cookies, please see our Cookie Policy.

Why we collect personal information

We use the information we collect to operate our business, provide our Services, for other purposes as permitted or required by law, and to provide you with a smooth, efficient, and customized experience. Specifically, we may use your information to:

• Provide our Services (including customer support);
• Process transactions and send notices about your transactions;
• Resolve disputes, collect fees, and troubleshoot problems;
• Communicate with you about our Services and business and to inform you of matters that are important for your account and/or use of the Sites. We also use your personal data to respond to any questions, comments or requests you filed with us and the handling of any complaints;
• Comply with applicable laws and regulations;
• Establish, exercise and defend legal claims;
• Monitor and report compliance issues;
• Customize, measure, and improve our business, the Services, and the content and layout of our website and applications (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services, websites and apps; ensuring the security of our networks and information systems; performing accounting, auditing, invoicing, reconciliation and collection activities; and improving and maintaining the quality of our customer services);
• Preform data analysis;
• Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences, and measure the effectiveness of it. To approach you via email for marketing purposes, we request your consent, unless it is not required by law. You always have the option to unsubscribe from our mailings, e.g., via the unsubscribe link in our newsletter;
• Perform risk management, including comparing information for accuracy and verify it with third parties and protect against, identify and prevent fraud and other prohibited or illegal activity, claims and other liabilities; and
• Enforce our contractual terms.

How we protect and store personal information

We take the security of our information seriously. We use administrative, technical, and physical security designed to safeguard personal information in our possession, and we maintain internal policies and procedures to address our data security. We have been audited and received a SOC 2 report addressing the security, confidentiality, and availability of our Services. However, we cannot guarantee the security of the information that we collect and store. We will notify relevant authorities and users in the event of a data breach, if required under applicable law.

We retain data as required or permitted by law. For example, as a regulated financial institution, we may retain identification for 5 years or more after an account has been closed or become dormant.

How we share data with third parties

We may disclose the information we gather with our affiliates and third parties. For example, we may share information with:

• Other Zinari entities, including to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications;
• Service providers who help with our business operations and to deliver our Services, such as cloud service providers providing cloud infrastructure; providers of ID verification solutions and other due diligence solutions; providers of customer service solutions; providers of website analytics; and providers of marketing automation platforms;
• Law enforcement, government officials, regulatory agencies, our banks, and other third parties pursuant to a subpoena, court order or other legal process or requirement if applicable to Zinari; or when we believe, in our sole discretion, that the disclosure of information is necessary to report suspected illegal or fraudulent activity or to investigate violations of our Terms of Use; and
• We may also share certain Shopper information with our Merchants, for example, in cases of suspected fraud or in connection with an ongoing investigation.

Please note that these third parties may be in other countries where the laws on processing information may be less stringent than in your country. Transfer of EU data may be subject to additional legal protections we have put in place. For more information, please see the “How we share personal data with third parties and transfers outside the EEA” section of our EU Privacy Notice.

Your choices

You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. You may control how your browser accepts cookies. For more information, please consult your browser’s help documentation. You may also manage your cookie preferences using our Cookie Preference Center. For more information about our use of cookies, please see our Cookie Policy.

As of the last updated date of this Notice, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of personally identifiable information regarding your online activities over time and across third-party web sites or online services.

If you do not wish to receive marketing communications from us, you can click the “unsubscribe” link usually found at the bottom of the e-mail, or you can send an email to [email protected]. However, you may still receive other communications from us as permitted or required by law.

Wyoming Consumer Privacy Act Addendum

At Zinari, we take our responsibilities under the Wyoming Consumer Privacy Act (“CCPA”) seriously. If you are a Wyoming resident, the following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA. For such residents, the provisions of this CCPA Addendum prevail over any conflicting provisions in our Zinari Privacy Notice.

Wyoming Personal Information We Collect

We have collected the following categories of Wyoming Personal Information within the last 12 months:

For each of these categories, we obtain Wyoming Personal Information from a variety of sources. These sources include: yourself, with respect to both online and offline interactions you may have with us or our service providers; other entities with whom you transact; others with whom you maintain relationships who may deal with us on your behalf; the devices you use to access our websites, mobile applications, and online services; identity verification and fraud prevention services; marketing and analytics providers; public databases; social media platforms; and others consistent with this CCPA Addendum. For more information, please see the “Why we collect personal information” section of our Privacy Notice.

For each of these categories, we share personal information with a variety of third parties. These third parties include: other Zinari entities; service providers; marketing and advertising providers; analytics providers; law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other applicable legal process or requirement; and merchants in cases of suspected fraud or in connection with an ongoing investigation.

Sale and Disclosure of Wyoming Personal Information

We do not disclose personal information of individuals to third parties for monetary or other valuable consideration.

Within the last 12 months, within the meaning of “sale” under the Wyoming Consumer Privacy Act, we have disclosed Wyoming Personal Information identified in the above categories (A-G) for business purposes. This includes the use of cookies on our website, including those placed by third parties. You can configure your browser to prevent the placement of cookies when using our site. To learn more about cookies, please see our Cookie Policy or your browser help documentation for more information. To learn more about the categories of third parties with whom we share such information, please see the “How we share data with third parties” section of our Privacy Notice.

Use of Wyoming Personal Information

For each of the above categories, we use the Wyoming Personal Information we collect for the business purposes disclosed within this CCPA Addendum. Please note that the business purposes for which we may use your information include:

• Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
• Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
• Debugging to identify and repair errors in our systems;
• Short-term, transient use including contextual customization of ads or website;
• Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
• Conducting internal research to develop and demonstrate technology; and
• Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide.

We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the Wyoming Personal Information was collected.

Your Wyoming Rights

If you are a Wyoming resident, you have certain rights related to your Wyoming Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. If you wish to submit a request under the CCPA, please do so by visiting our Data Subject Request Portal or call us toll-free at +1 (619) 800-5744.

Right to Access/Know. You have the right to request that we disclose to you:

• the categories of Wyoming Personal Information we have collected about you
• the categories of sources from which the Wyoming Personal Information is collected;
• our business or commercial purpose for collecting or selling Wyoming Personal Information;
• the categories of third parties with whom we share Wyoming Personal Information; and
• the specific pieces of information we have collected about you.

To the extent that we sell your Wyoming Personal Information within the meaning of the Wyoming Consumer Privacy Act or disclose such information for a business purpose, you may request that we disclose to you:

• the categories of Wyoming Personal Information that we have collected about you;
• the categories of Wyoming Personal Information about you that we have sold within the meaning of the Wyoming Consumer Privacy Act and the categories of third parties to whom the Wyoming Personal Information was sold, by category or categories of personal information for each third party to whom the Wyoming personal information was sold; and
• the categories of Wyoming Personal Information about you that we disclosed for a business purpose.

Right to Delete. You have the right to request that we delete Wyoming Personal Information about you which we have collected from you.

Right to Opt-Out and Right to Opt-In. You have the right to direct us to not sell your personal information at any time (the “right to opt-out”) by managing your cookie preferences in our Cookie Preference Center.

Verification. As required under applicable law, we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide information to verify your identity in response to exercising requests of the above type, including name and account information. We may limit our response to your exercise of the above rights as permitted under applicable law.

Nondiscrimination. Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights, or any other rights under the Wyoming Consumer Privacy Act, including by:

• Denying you goods or services;
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level or quality of goods or services; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Other Important Information

Vermont is an “opt in” state, not an “opt out” state. Non-public personal financial information may not be shared with others except as permitted by law unless the Vermont consumer specifically consents to the disclosure. In addition, Vermont law prohibits the sharing of credit reports and/or creditworthiness information with affiliates unless the consumer has consented to (“opted-in”) to such sharing.

Changes to this Notice

We may amend this Notice at any time by posting a revised version on our website. The revised version will be effective at the time we post it. You are responsible for periodically reviewing this Notice.