Table of Contents
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
10. Contact Us
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
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.
• "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.
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
• “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
• 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
• 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
• 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
• 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,
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
• 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
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
• 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
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
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
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 email@example.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
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
• 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
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
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.
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)
You may close your Z-Wallet Account and request a return of outstanding balances. If You do
10. CONTACT US
practices, You may contact us at:
Zooyza LLC, 1645 S. River Road, Des Plaines, Illinois 60018, firstname.lastname@example.org, Customer Service (1-847-430-4856).