Privacy Policy

Table of Contents


1. Overview
2. Information We Collect
3. How We Use the Information We Collect
4. Sharing and Disclosure
5. Other Important Information
6. Your Rights
7. Operationg Globally and International Transfers
8. Security
9. Changes to This Privacy Policy
10. Contact Us


1. OVERVIEW

This Privacy Policy applies to Your use of Zooyza LLC’s services, including Your Z-Wallet Account, and Your use of mobile applications, websites, software, and other products and services available through zooyza.com (collectively, the “Services”). Your trust is important to us and we’re committed to protecting the privacy and security of Your personal information and transaction information. This Privacy Policy describes how we collect, use, process, and in limited circumstances, disclose Your personal information, in conjunction with Your access to and use of the Services. Please read this Policy carefully and contact us using the information in the “Contact Us” Section below if You have any questions.

1.1 Definitions

"Customer/Holder" means a member of the public who uses our Services.
"Linked payment method" means a debit, credit or prepaid card (physical or virtual) or a U.S. bank account that is linked to Your Z-Wallet Account to be used as a payment method.
"Participating Merchant" refers to merchant partners that accept payments from a Z-Wallet Account, or from any linked payment method, as payment in exchange for goods or services.
"Policy" means this Privacy Policy, as it is amended, modified, and updated from time to time by Zooyza.
"Services" has the meaning set forth in the first paragraph of the Overview.
"You", "Your", or "Users" refers to the user of the Services, including all holders of Z-Wallet Accounts.
"Z-Wallet Account" refers to the digital account represented by a 13-20 digit account number associated with the Services that a User creates by registering in our web or mobile applications.
“Zooyza” “we,” “our,” or “us,” means Zooyza LLC, an Illinois limited liability company, the issuer of Z-Wallet Accounts.

1.2 Data Controller

When this Policy refers to the “Data Controller”, it refers to the company that is responsible for Your information under this Privacy Policy as the Data Controller.


• If Your country of residence is the United States, the Data Controller is Zooyza LLC.
• This Policy is not directed to residents of other countries


Please see the Contact Us Section below for contact details of the Data Controller.

1.3 Core Principles

We follow a set of core privacy principles. These principles apply to all persons and organizations whose personal data we hold. We focus, in particular, of the following core principles:


To be transparent and to educate: You should understand what personal data is collected, for what purposes and to understand how we apply our privacy principles.
To empower the individual: Zooyza wants You to be in control of Your personal information and to make Your own choices about Your personal data.
To protect and keep Your data secure As a payment and financial service business, ensuring Your personal data and transaction information is kept safe and secure is one of our main business values – Zooyza works to maintain Your trust and we take responsibility to ensure that appropriate security standards are implemented and Your personal and transaction data is protected.
To collect and retain what personal data that we need: Zooyza collects personal data to perform its Services for You. We work to have controls in place to avoid collecting identifiable data beyond what we need.
To respect local law Zooyza and its affiliates keep privacy protection and commitment to data privacy top of mind in their development of products and services.

2. INFORMATION WE COLLECT

There are three general categories of information we collect.

2.1 Information You Give to Us

2.1.1 Information that is necessary for the use of the Services.

We ask for and collect the following personal information about You when you use the Services. This information is necessary for the adequate performance of the contract between You and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide You with all the requested Services.


Account Information. When You sign up for a Z-Wallet Account, we require certain information such as Your first name, last name, and date of birth.
Contact Data. This is data that can be used to contact You, such as Your address, phone number, email, and billing details.
Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of Your government issued ID, passport, national ID card, or driver’s license, as permitted by applicable laws) or other authentication information.
Payment and Financial Information. To use certain features of the Services related to payments (such as linking Your bank account or other payment method to Your Z-Wallet Account), we may require You to provide certain financial information (like Your bank account information or credit card information) and identity verification information (such as government issued ID, passport, driver’s license, date of birth and other authentication information) in order to facilitate the processing of payments and comply with laws, such as anti-money laundering regulations.
Communications with Zooyza. When You communicate with Zooyza, we collect information about Your communication and any information You choose to provide.

2.1.2 Information You choose to give us.

You may choose to provide us with additional personal information. This additional information will be processed based on our legitimate interest or when applicable, Your consent.


Request for Information or Services. You provide personal information directly to us or to our Participating Merchants so that we or they can contact You directly about Services or products or send requested information to You.
Additional Profile Information. You may choose to provide additional information as part of Your Z-Wallet Account profile.
Other Information. You may otherwise choose to provide us information when You fill in a form, update information on your Z-Wallet Account, respond to surveys, enter a competition or promotion, communicate with our Customer Service, or use other features of the Services.

2.1.3 Information We Automatically Collect from Your Use of the Services.

When You use the Services, we automatically collect personal information about the Services You use and how You use them. This information is necessary for the adequate performance of the contract between You and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Services.


Geo-location Information. When You use certain features of the Services, we may collect information about Your precise or approximate location as determined through data such as Your IP address or mobile device’s GPS to offer You an improved user experience. Most mobile devices allow You to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when You are not using the app if this connection is enabled through Your settings or device permissions.
Usage Information. We collect information about Your interactions with the Services such as the pages or content You view, purchase and return transactions, Your decisions to subscribe or withdraw from receiving marketing materials from us or third parties, and other actions related to Your use of the Services.
Log Data and Device Information. We automatically collect log data and device information when You access and use the Services, even if You have not created a Z-Wallet Account or logged in. That information includes, among other things: details about how You have used the Services (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, search engine keywords, JavaScript enablement, and the pages You have viewed or engaged with before or after using the Services.
Cookies and Similar Technologies.We may use cookies and other similar technologies when You use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases, the information we collect using cookies and other tools is only used in a non-identifiable manner without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases, we associate the information we collect using cookies and other technology with Your personal information. Our business partners may also use these tracking technologies on the Services or engage others to track Your behavior on our behalf.
Do Not Track Signals.While You may disable the usage of cookies through Your browser settings, the Services may not respond to a “Do Not Track” signal in the HTTP header from Your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
Payment Transaction Information. Zooyza collects information related to Your payment transactions through the Services, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, and other related transaction details. This information is necessary for the adequate performance of the contract between You and us for payment services.

2.1.4 Information We Collect from Third Parties.

Zooyza may collect information, including personal information that others (such as Participating Merchants) provide about You in connection with the Services, or obtain information from other sources and combine that with information we collect through the Services. We do not control, supervise or respond to how the third parties providing Your information may process your personal information, and any information request regarding the disclosure of Your personal information to us should be directed to such third parties.


Participating Merchants. Provide us with Your personal data for purposes of providing Services that You have chosen on websites operated by those Participating Merchants.
Profile Data from Social Platforms and Networks. In the event that we allow You to link, connect, or login to Your Z-Wallet Account with a third party social platform or network (such as Google or Facebook) and You elect to do so, the third party service may send us information such as Your registration and profile information from that service. This information varies and is controlled by that service or as authorized by You via Your privacy settings at that service.
Other Sources. To the extent permitted by applicable law, we may receive additional information about You, such as credit bureau reports (with Your consent where required) or other information to verify identity and creditworthiness and help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about You.

2.2 Children's Data

Our websites and applications are not directed to children under the age of 16 and we do not knowingly collect any personal information directly from children under 16. If You believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge You to contact us using the information provided under the “Contact Us” Section below.

3. HOW WE USE INFORMATION WE COLLECT

We may use, store, and process personal information to (1) provide, understand, improve, and develop the Services, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations, ensure compliance with Zooyza Policies, and mitigate fraud) and (3) provide, personalize, measure, and improve our advertising and marketing. How Zooyza uses Your personal data will vary depending on whether You are a Participating Merchant or a Customer and which Services you choose.

3.1 Provide, Improve, and Develop the Services.

We may use the personal information to provide, improve, and develop the Services such as to:


• enable You to access and use the Services,
• enable You to communicate with Participating Merchants and other third-party service providers, if needed in relation to the Services,
• operate, protect, improve, and optimize the Services and experience, such as by performing analytics and conducting research to improve the Services or develop new products and services, conduct internal audits, perform internal reporting and similar internal purposes,
• to conclude and perform the contract for Z-Wallet Account Services and transactions using linked payment methods, such as processing Your payment transactions and notifying You about the status of payments,
• enable us to effectively communicate with You (such as to send You emails to inform You about Services, update You on applicable security and fraud monitoring alerts, account notices, and notices of interruption of services or other important notices about the improvement of our Services and updates to our policies, including this Policy),
• provide Customer Service and resolve problems related to Services You request,
• if You provide us with Your contacts’ information, we may process this information: (i) to facilitate Your referral invitations, (ii) send Your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose You authorize at the time of collection, and
• to operate, protect, improve, and optimize the Services and experience, and personalize and customize Your experience.


We process this personal information for these purposes given our legitimate interest in improving the Services and our Customers’ experience with it, and where it is necessary for the adequate performance of the contract with You.

3.2 Create and Maintain a Trusted and Safer Environment.

We may use the personal information to create and maintain a trusted and safer environment such as to:


• detect, mitigate, and prevent fraud, spam, abuse, security incidents, and other harmful activity,
• conduct security investigations and risk assessments,
• conduct required “Know Your Customer” verification of identity and risk assessment procedures to verify or authenticate information or identifications provided by You and authorize Your use of our Services depending on if You are a Participating Merchant or Customer and Your choice of service or product,
• conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
• protect our business and comply with our legal obligations (such as compliance with anti-bribery and anti-money laundering requirements and other laws, network rules, and regulations that apply to payment service providers),
• resolve any disputes with Participating Merchants (including assistance with disputes and charge-backs related to purchases You make and pay for using Your Z-Wallet Account or a linked payment method), which may include sharing Your information with Participating Merchants and other third parties to resolve the disputes,
• Zooyza is required by law to authenticate and validate payments to mitigate and protect against identity theft and fraud; to do this, some personal and non-personal data collected by Zooyza directly, or provided to Zooyza by Participating Merchants or Customers, will be entered into our enterprise fraud systems for this validation purpose and remain there for future reference and cross-reference of information required to validate the payments,
• enforce our agreements and policies, and
• in connection with the activities above, we may conduct profiling based on Your interactions with the Services, Your profile information and other content You submit to the Services, and information obtained from third parties; in limited cases, automated processes may restrict or suspend access to the Services if such processes detect activity that we think poses a safety or other risk to the Services, our community, or third parties. If You challenge the decisioning based on the automated process, please contact us as provided in the Contact Us Section below.


We process this personal information for these purposes given our legitimate interest in protecting the Services, to measure the adequate performance of our contract with You, and to comply with applicable laws.

3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.

We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:


• send You promotional messages, marketing, advertising, and other information that may be of interest to You based on your preferences (including information about Zooyza or partner campaigns and services),
• personalize, measure, and improve our advertising,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Zooyza or its third party partners, and
• conduct profiling on Your characteristics and preferences (based on the information You provide to us, Your interactions with the Services, information obtained from third parties, and Your search and booking history) to send You promotional messages, marketing, advertising and other information that we think may be of interest to You.


We will process Your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer You products or services that may be of interest to You.

3.4 Your Choices for Marketing Communications

You will receive marketing communications from Zooyza if You have requested marketing communications from us or You have subscribed for Services or entered into a promotional competition, or taken a promotional offer or survey where You are requested to provide us with contact information in order to participate. You have choices on the promotional messages that You choose to receive.


• You can limit the information You provide to Zooyza. Participation in promotions and marketing programs is voluntary.
• You can limit the communications that Zooyza sends to You.


o To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email that we send to You or access the notification settings in Your Z-Wallet Account.
o To revoke permissions that You may have given to send promotional text messages, text STOP in response to any message.

4. SHARING & DISCLOSURE

4.1 Corporate Affiliates.

To enable or support us in providing the Services, we may share Your information, including personal information, within our corporate family of companies (affiliated with B.E.S.T., Inc.) that are related by common ownership or control. In this case, the processing of Your personal data may be carried out on an affiliated company’s servers or by third parties hired by one of our affiliates. This transfer is necessary to perform the contract between You and us and to comply with the provision of our Services or to meet other operational needs of the business or some of the other purposes set forth in this Policy.
Additionally, we share Your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve the Services and our affiliates’ services.
Your Rights. All sharing is subject to the rights that You exercise with respect to Your personal data. See “Your Rights” for more information.

4.2 Advertising and Social Media: Sharing With Your Consent.

Where You have provided consent, we share Your information, including personal information, as described at the time of consent, such as when You authorize a third-party application or website to access Your Z-Wallet Account or when You participate in promotional activities conducted by Zooyza partners or third parties.
Please note that You may, at any time ask Zooyza to cease processing Your data for these direct marketing purposes by following the procedures described in “Your Choices for Marketing Communications” above.

4.3 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

Zooyza may disclose Your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Zooyza, (iii) to respond to valid requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, You, or any other of our users to legal liability, (iv) to enforce and administer our contract with You and related policies, or (v) to protect the rights, property or personal safety of Zooyza, its employees, its Customers, or members of the public.
These disclosures may be necessary to comply with our legal obligations, for the protection of Your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Services secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.
Where appropriate, we may notify You about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon our property, our Customers and/or the Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify You about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

4.4 Participating Merchants, Service Providers, and Other Third Parties.

We share transactional data with Participating Merchants in accordance with our service agreements with Participating Merchants.
Zooyza also uses a variety of third-party service providers to help us provide services related to the Services. For example, service providers may help us: (i) verify Your identity or authenticate Your identification documents, (ii) check information against public databases, (iii) conduct background checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) provide risk analysis software and technical infrastructure support. These providers have limited access to Your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.
Authorized third-party financial institutions and banking partners that we contract with to jointly offer products and services may also receive personal data from Customers who accept Services in which these partners are involved. For example, depending on the type of payment Services that You have chosen, Zooyza may share Your personal data with financial institutions and acquirers, that validate, process, settle the payment transactions.
Zooyza will need to share Your information, including personal information, in order to ensure the adequate performance of our contract with You.

4.5 Aggregated Data.

We also may share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

5. OTHER IMPORTANT INFORMATION

5.1 Analyzing your Communications.

We may review, scan, or analyze Your communications on the Services for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze Your messaging communications to send third party marketing messages to You, and we will not sell reviews or analyses of these communications.
These activities are carried out based on Zooyza's legitimate interest in ensuring compliance with applicable laws and our contract with You and related policies, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

5.2 Third Party Partners & Integrations

The Services may contain links to third party websites or services, such as third-party integrations, co-branded services, or third party-branded services (“Third-Party Partners”). Zooyza doesn’t own or control these Third-Party Partners and when You interact with them, You may be providing information directly to the Third-Party Partner, Zooyza, or both. These Third-Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage You to review the privacy policies of the other websites You visit.

6. YOUR RIGHTS

You may exercise any of the rights described in this Section by contacting us and the applicable Data Controller by sending an email to support@zooyza.com. Please note that we may ask You to verify Your identity and request before taking further action on your request.

6.1 Managing Your Information.

You may access and update some of Your information through Your Z-Wallet Account settings. You are responsible for keeping Your personal information up-to-date.

6.2 Correct Inaccurate or Incomplete Information

You have the right to ask us to correct inaccurate or incomplete personal information about You (and which You cannot update Yourself within Your Z-Wallet Account). See "Contact Us" below for our contact information.

6.3 Data Access and Portability.

In some jurisdictions, applicable law may entitle You to request copies of Your personal information held by us. You may also be entitled to request copies of personal information that You have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

6.4 Data Retention and Erasure.

We generally retain Your personal information for as long as is necessary for the performance of the contract between You and us and to comply with our legal obligations. In certain jurisdictions, You can request to have all Your personal information deleted entirely. Please note that if You request the erasure of Your personal information:


• We may retain some of Your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Z-Wallet Account for fraud or safety reasons, we may retain certain information from that Z-Wallet Account to prevent that Customer from opening a new Z-Wallet Account in the future.
• We may retain and use Your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of Your information for tax, legal reporting and auditing obligations.
• Information You have shared with others (e.g., reviews, forum postings) may continue to be publicly visible on the Services, even after your Z-Wallet Account is closed. However, attribution of such information to You will be removed. Additionally, some copies of Your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain the Services to protect from accidental or malicious loss and destruction, residual copies of Your personal information may not be removed from our backup systems for a limited period of time.

6.5 Withdrawing Consent and Restriction of Processing.

If we are processing Your personal information based on Your consent, You can require certain personal data to be marked as restricted for processing certain circumstances or by sending an e-mail to us at the address listed in “Contact Us” below specifying which consent You are withdrawing. Please note that the withdrawal of Your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give You the right to limit the ways in which we use Your personal information, in particular where (i) You contest the accuracy of Your personal information; (ii) the processing is unlawful and You oppose the erasure of your personal information; (iii) we no longer need Your personal information for the purposes of the processing, but You require the information for the establishment, exercise or defense of legal claims; or (iv) You have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Zooyza override Your own.

6.6 Objection to Processing.

In some jurisdictions, applicable law may entitle You to require Zooyza not to process Your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If You object to such processing, Zooyza will no longer process Your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.
Where Your personal information is processed for direct marketing purposes, You may, at any time ask Zooyza to cease processing Your data for these direct marketing purposes by sending an e-mail to us at the address listed in the Contact Us Section.

6.7 Lodging Complaints.

You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by using the contact information in “Contact Us” below or with a supervisory authority in Your jurisdiction.

7. CERTAIN STATE-SPECIFIC PROVISIONS

7.1 California Residents.

Zooyza will not share information it collects about You with its affiliates or third parties (both financial and non-financial), except as required or permitted by California law.
California law permits Customers who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” Section for where to send such requests. Zooyza does not share personal information with third parties for their own direct marketing purposes without Your prior consent. Accordingly, You can prevent disclosure of Your personal information to third parties for their direct marketing purposes by withholding consent.

8. SECURITY

We regularly implement and update administrative, technical, and physical security measures to help protect Your information against unauthorized access, loss, destruction, or alteration. We follow the payments industry’s standards regarding the protection of personal data, including, among other measures, implementing firewalls and data encryption, Virtual Private Network and Transport Layer Security. Additionally, our processor is certified under the Payment Card Industry Data Security Standard.
We regularly review our policies regarding the collection, storage and processing of Your personal data, including physical security measures, to prevent adulteration, loss, query, use or fraudulent or unauthorized access to Your personal information. We have put in place procedures to address suspected personal data breach and will notify You and the applicable regulatory authorities where we are legally required to do so. If You know or have reason to believe that Your Z-Wallet Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Z-Wallet Account, please contact us immediately following the instructions in the Contact Us Section below.

9. CHANGES TO THIS PRIVACY POLICY

Zooyza reserves the right to modify this Privacy Policy at any time in accordance with this Section. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on our website at www.zooyza.com and update the “Last Updated” date at the top of this Privacy Policy. We will also provide You with notice of the modifications by email at least thirty (30) days before the date they become effective. If You disagree with the revised Privacy Policy, You may close your Z-Wallet Account and request a return of outstanding balances. If You do not close Your Z-Wallet Account before the date that the revised Privacy Policy becomes effective, Your continued access to or use of the Services will be subject to the revised Privacy Policy.

10. CONTACT US

If You have any questions or complaints about this Privacy Policy or Zooyza’s information handling practices, You may contact us at:
Zooyza LLC, 1645 S. River Road, Des Plaines, Illinois 60018, support@zooyza.com, Customer Service (1-847-430-4856).