Welcome to ZebPay!
ZebPay is a legal organisation which endeavours to ensure all of its policies and procedures are fully compliant with the Privacy and Data Protection Act 2014 (Victoria) and the GDPR (General Data Protection Regulation 2016/679) requirements. We also endeavor to treat your privacy concerns very seriously.
ZebPay shall mean and include below –
Awlencan Innovations Australia Pty Ltd [ACN 629 939 948], 1198 Toorak Road, Camberwell, VIC, 3124 where a customer accesses the ZebPay Platform in or from supported countries
Persons using the ZebPay Platform, directly or indirectly, are referred to herein as “Users”.
This Privacy Policy describes our information handling practices when you access content we own or operate on the websites or apps of ZebPay or any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”).
In order to prevent misuse of the ZebPay Platform, Users are required to strictly comply with the terms contained herein, which forms part and parcel of the User Terms of Service . Terms not defined herein shall carry the same interpretation, as in the User Agreement and in the absence thereof to general usage and parlance.
THESE TERMS AND CONDITIONS OF PRIVACY SUPERSEDES AND REPLACES ANY AND ALL PRIOR ORAL OR WRITTEN UNDERSTANDINGS OR AGREEMENTS BETWEEN ZebPay AND THE USER WITH RESPECT TO THE PRIVACY POLICY.
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1.1 “Applicable Law” means the law in force for the time being within the territory of Australia, but also includes GDPR for those customers resident in the European Union .
1.2 ‘AML’ means ‘Anti-Money Laundering’, and in this connection, the applicable legislation shall be the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) and other regulatuions made under the aforementioned Act from time to time
1.3 “ZebPay Platform” shall mean and include ZebPay Android App, ZebPay iOS App (collectively, “ZebPay App”) or ZebPay Web app (“Web version”) and ZebPay website “www.zebpay.com” (“ZebPay Website”). Collectively along with the ZebPay Developer Portal, Public APIs and secure authentication for ZebPay Users is referred to as the “ZebPay Platform”.
1.4 “GDPR ” means REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (‘General Data Protection Regulation’).
2.1 ZebPay is committed to ensuring the safety and protection of all data and information shared with ZebPay by its Users in accordance with Applicable Laws and the terms and conditions set out hereunder and processes established by ZebPay in compliance with the applicable reasonable security practices and procedures, prescribed by Government or Regulatory authorities, as the case may be.
2.2 ZebPay shall not be liable for any breach or violation of its systems or policies due to malicious attacks, errors, commissions or omissions not willfully initiated by ZebPay, leading to breach of data or information of User.
3.1 Personal information is data that can be used to identify you directly or indirectly, or to contact you. Our Privacy Policy covers all personal information that you submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymized data, as it cannot be used to identify you.
3.2 We can ask you to provide personal information anytime you are in contact or consuming ZebPay Platform. ZebPay group of companies may share your personal information with each other and use it consistently with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, and content. Except as described in this Privacy Policy, ZebPay will not sell, rent or loan any personal Information to any third party.
How to contact ZebPay for data protection inquiries:
4.1 We have endeavored to nominate an independent Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set-out below.
4.2 ZebPay may collect required personal data and information of the User to provide its services. Use of the ZebPay Platform is contingent upon acceptance of the terms and conditions contained herein. User shall be deemed to have volunteered the data and information collected, retained, used and disseminated by ZebPay, upon accepting the terms herein and those contained in the Terms of Service and User agreement of ZebPay.
4.3 ZebPay processes your personal data and information of the User in accordance with the guidelines laid by Applicable Laws. Personal data’ means any information or opinion relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, which can include (but is not limited to) data concerning that person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record that is also personal information, health information about an individual, genetic information about an individual that is not otherwise health information, biometric information that is to be used for the purpose of automated biometric identification or verification, and biometric templates.
4.4 ZebPay collects your personal information to provide our Services. ZebPay ensures that your personal data is processed lawfully, fairly and in a transparent manner and is collected for specified, explicit and legitimate purposes shared with you. Any information you provide to us that is not required, is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all our Services when you do choose not to share certain information with us. We may collect the following types of information provided / shared by the User as applicable for
1) Personal Identification Information : Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, national ID proof, home address, and/or email.
Why we collect this information
2) Recognized Identification Information : Tax ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information.
Why we collect this information
3) Monetary Information : Bank account information,Credit or Debit Card Number, transaction history, trading data, and/or tax identification.
Why we collect this information
4) Transaction Information : Information about the transactions by using ZebPay Platform, such as the name of the recipient, digital currency address, your name, the amount, and/or timestamped.
Why we collect this information
5) Employment or Business Information : Office location, job title, and/or description of Business, role, etc.
Why we collect this information
6) Online Identifiers : User’s device information including but not limited to IMEI or equipment identification number, IMSI or subscriber identification, UUID, MAC address, OS version, device details, network operator, contact list information, Wi-fi / Data Network connectivity. Cookies Information generated by the User’s use of the app and the website, including cookies and IP addresses. Geolocation of a User’s device or such or other automatically collated data or information of User, please visit our Cookie Policy
Why we collect this information
7) Access to User’s Photo Gallery / Media / Files / Camera for using ZebPay Platform more efficiently.
Why we collect this information
8) Access to User’s apps and services including messaging through SMS; Storage data, device details;
Why we collect this information
9) Leave a message – We may collect your name, email id, mobile number, country, etc when you leave a message on our website.
Why we collect this information
Depending on the purpose of our processing activity, the processing of your personal data will be based on one of the following:
6.1 ZebPay uses cookies on its App and website to collect data about user. For a detailed policy on use and collection of Cookies, please visit our Cookie Policy
7.1 ZebPay may collect, use and share aggregated data to create anonymised statistical data. ZebPay may provide this statistical data to its business partners or third parties.
7.2 Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website / app feature.
However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
You are entitled to inform ZebPay at any time that your personal details have changed or otherwise request erasure of your personal data by emailing customer support at help@zebpay .com
7.3 We will only retain your personal data for as long as necessary to fulfil the purpose for which we have collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.
7.4 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.
7.5 By law we have to keep basic information about our customers (including contract, identity, financial and transaction data) for seven (7) years after they cease being customers for online trading purposes.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. When you use this website or other services we provide to you, you may be able to link to other third-party websites, plug-ins and applications.
7.6 This Privacy Policy does not apply to those sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policies on such sites.
7.7 ZebPay uses cookies to gather information about your access to this website and other services we provide to you. Cookies are small pieces of information which use a unique identification tag and are stored on your device as a result of you using this website or other service we provide to you.
When cookies are used by us, they collect statistical and factual information about how you use our services. Most internet browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to have your computer notify you each time a cookie is sent to it, and thereby give yourself the choice whether to accept it or not. If you disable or refuse cookies, please note that some parts of this website may become inadmissible or not function properly and impair the quality of the services that we provide to you in relation to your account.
For more information about the types of cookies ZebPay uses, please refer to our specific Cookie Policy .
7.8 ZebPay protects your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
7.9 The retention period may be extended to comply with legal obligations, resolve disputes, and enforce agreements for a period of seven(7) years after termination of the account or such period, under applicable laws. ZebPay may retain data for further periods but is not obligated to do so in all instances. ZebPay shall not be liable or responsible for non – availability or non – retention of data or information beyond the termination of the User account.
7.10 The retention period may extend beyond the end of User account, but it will be only as long as it is necessary for ZebPay to have sufficient information to respond to any issues that may arise later, including but not limited to retention for the purpose of investigations or ongoing prosecutions or in case of Suspicious transactions or if ZebPay requires the information for its records or to support legal proceedings, or if ZebPay believes in good faith that a law, regulation, rule or guideline requires it.
7.11 Please note that ZebPay cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur and you play a vital role in protecting your own personal information as users while registering with ZebPay Platform, it is important to choose a password or PIN of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorised access to or use of your account
7.12 Likewise, ZebPay cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at dpo@zebpay.com. ZebPay however takes all reasonable steps to secure data and information pertaining to its Users, including those prescribed under applicable laws and Rules framed thereunder.
7.13 We will keep information about visitors to our websites (not being customers) for a reasonable length of time, that lets us understand how people use our website and any technical issues they have.
7.14 We try to respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or you have a number of requests. In this case, we will notify you and keep you updated.
7.15 You have a right to make a complaint at any time to the Office of the Australia Information Commissioner (“OAIC”), the Australian supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the OAIC so please contact us or our DPO in the first instance at the email specified above.
8.1 The User shall ensure that all data and information shared with ZebPay is accurate, correct and complete. User shall ensure that change of the User’s address or any change in circumstances impacting use of the ZebPay Platform, is promptly communicated to ZebPay.
8.2 ZebPay will not be held liable or responsible for any incorrect information provided by the User to ZebPay.
8.3 User may, upon termination of the use of the ZebPay Platform, as provided in the Terms of Service, withdraw consent granted herein to ZebPay. The same shall however not affect actions undertaken or data and information collated, or technological processes initiated prior to such withdrawal of consent. Such withdrawal of consent shall also not affect retention of data and information collected prior to such withdrawal.
9.1 Where we use certain service providers which are not located in Australia, we may use specific contracts compatible with Applicable Laws which give your personal data the same protection it has in Australia (or the EU, in the case of our EU customers).
9.2 In all other instances, the User generally agrees and consents to ZebPay sharing the following anonymized data or to otherwise gives ZebPay permission to share its Data with third-parties for the following:
You have the following rights, which can be exercised by contacting us dpo@zebpay.com so that we may consider your request under applicable law.
Right to withdraw consent – You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of ZebPay’s data processing based on consent before your withdrawal.
Right of access to and rectification of your personal information – You have a right to request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated (if applicable) with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. You may also request us to rectify or update any of your personal information held by ZebPay that is inaccurate.
Right to erasure [right to be forgotten] – You have the right to request erasure of your personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented, but later withdraw such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. The above is subject to limitations by relevant data protection laws.
Right to data portability – If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible and once our platform interface allows for the ‘exportation’ of such data. In this connection, ZebPay is committed towards creating a robust function ensuring data portability in due course.
Without prejudice to the aforesaid, data portability will be prohibited if the requested migration of said data adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which alone or jointly with others, determines the purposes and means of the processing of your personal information.
Right to restriction or objections for processing – You have the right to restrict or object to us processing your personal information where one of the following applies:
You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.
The processing is unlawful, and you oppose the erasure of your personal information and request the restriction of its use instead.
We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.
You have objected to processing, pending the verification whether the legitimate grounds of ZebPay’s processing override your rights.
Restricted personal information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.
Notification of erasure, rectification and restriction – We will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information has been disclosed, unless this proves impossible or involves a disproportionate effort. We will inform you about those recipients if you request this information.
Right to object to processing – Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Automated individual decision-making, including profiling – You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.
Right to lodge a complaint – If you believe that we have infringed your rights, we encourage you to contact us first at dpo@zebpay.com , so that we can try to resolve the issue or dispute informally.
Your rights to personal information are not absolute. Access may be denied when:
To Invoke or exercise any of your rights, please contact our Data Protection Officer (DPO) at: dpo@zebpay.com
11.1 Protection of the User’s personal information is of utmost importance to ZebPay and it takes all reasonable steps to secure data and information pertaining to its Users, including those prescribed under applicable laws and Rules framed thereunder
11.2 ZebPay takes appropriate legal, administrative, physical, and reasonable electronic measures designed to protect the information that Users share with ZebPay
11.3 ZebPay however does not extend any warranties with respect to the security or safety of data and information transmitted through digital platforms or online, both of which are susceptible to malicious attacks.
These terms may be periodically reviewed and revised when required by law, or due to business reasons . we will notify you of changes to this Privacy Policy. The revised Policy will be uploaded on the ZebPay website and will reflect the modified date of the terms. Continued use of the ZebPay Platform constitutes agreement of User to the terms contained herein and any amendments thereto. ZebPay may for any important changes in the policy would send an email to the user's registered email id.
We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Services prior to the change becoming effective. ZebPay also encourages users to periodically visit our policies from time to time
All other provisions of the ZebPay Terms of Service and user agreement shall be read along with this policy and shall form part hereof, including Governing Laws and jurisdiction, notices, severability, assignment and such or other provisions.
If you have questions, please contact our Data Protection Officer (DPO) at: dpo@zebpay .com
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Address : © 2020 Awlencan Innovations Australia Pty Ltd | 1198, Toorak Road, Camberwell, VIC, 3124
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