Privacy P0licy

WELCOME TO the zerozero Foundation PRIVACY POLICY (“PRIVACY POLICY”).

PRIVACY POLICY

Last Revised on October 21, 2022

This Privacy Policy for the zerozero foundation (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Company’s website (https://www.zeroze.ro/), the zerozero ecosystem (“$00 Ecosystem”), and any related content, tools, features and functionality (collectively, the “Services”).  For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.  

PLEASE READ THIS PRIVACY POLICY CAREFULLY. If you do not want information about you used as described in this Privacy Policy, please do not access or use the Services.  

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law.  If you do not agree to any updates to this Privacy Policy please do not access or continue to use the services.

2. COMPANY’S COLLECTION AND USE OF INFORMATION

When you access or use the Services, we may collect certain categories of information about you from a variety of sources. 

Some features of the Services may require you to directly enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services may include:

  • Contact information. Name, email address, address. We collect basic contact details to communicate with you, provide you with the Services, administer your relationship with us, and respond to your queries (including to provide grants). 
  • Proposal information. Contact information, a statement about your proposal, why the zerozero community should accept it, steps to implement the proposal, and any other information you submit.
  • Account information. Username, password, security questions. We collect this information to create, maintain and secure your account. We collect account information to maintain and secure your account with us, provide you with the Services (including providing assistance, consulting services, and support), connect your wallet, and administer your relationship with us. 
  • Information about your use of the Services. Information related to your activity on and your other uses of the Services. We collect this information to facilitate your engagement with the Services, personalize your experience, monitor and analyze trends in connection with the Services and conduct internal research and development.
  • Any other information you choose to provide. This includes any information that you choose to include in communications with us, for example, when sending us an email, or post on the discussion forum. We use this information to facilitate your engagement with the Services, including to enable you to post on the discussion forum, post on social media, communicate with you about our Services, approve your proposal, monitor and analyze trends in connection with the Services and conduct internal research and development.

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs, and other tracking technologies (“Tracking Technologies”). Usage Data may include:

  • Device type, such as your phone, computer, or tablet;
  • IP address;
  • Screen resolution;
  • Browser type;
  • Date and time stamps, such as the date and time you first accessed the Services;
  • Operating system;
  • Log data;
  • Number of visits;
  • Language of device; 
  • Geolocation; and
  • Other information regarding your interaction with the Services, such as clickstream data.

We use the Usage Data we collect automatically to:

  • Improve and provide the Services;
  • Offer promotions;
  • Run analytics; and
  • Better understand user interaction with the Services.

In addition to the foregoing, we may use all of the above information to:

  • Create anonymized and aggregated data sets that we may use for a variety of functions, including research, internal analysis, analytics, and other functions;
  • Comply with any applicable legal obligations; 
  • Detect, investigate, and prevent activities that may violate our policies or be illegal; 
  • Enforce any applicable terms of use; and
  • Protect or defend the Services, our rights, the rights of our users or others.

We may obtain any of the above information about you from outside sources, such as Chainanalytics.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. See Section 6 below for more information.

In addition to the foregoing, we may use any of the above information to comply with any applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

3. HOW THE COMPANY SHARES YOUR INFORMATION

In certain circumstances, the Company may share your information with third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include: 

  • With vendors or other service providers, such as:
  • Compliance providers, such as know-your customer services;
  • Providers of website services such as moderation services;
  • Data analytics vendors;
  • Data storage providers;
  • Email vendors; 
  • Google analytics; and
  • Survey and marketing vendors.
  • With our affiliates or otherwise within our corporate group
  • When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations
  • To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries
  • In connection with an asset sale, merger, bankruptcy, or other business transaction
  • To enforce any applicable terms of service
  • To ensure the safety and security of the Company and/or its users
  • When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations
  •  With professional advisors, such as auditors, law firms, or accounting firms

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly. 

To opt out of tracking by Google Analytics, click here.

If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

5. USER GENERATED CONTENT

The Services also host a discussion forum, which users may elect to join and/or participate in. The purpose of these features is to have general discussions regarding the $00 Ecosystem, find and use helpful resources, and review and vote on proposals related to the $00 Ecosystem. Through your participation, you may submit content (“User-Generated Content” or “UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the ability to share it with third parties. If you choose to submit UGC to any public area of the Services, your UGC will be considered “public” and will be accessible by anyone, including the Company.

Please note that we do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the features permitting creation of UGC or what others do with information you share with them on such platforms.  We are not responsible for the accuracy, use or misuse of any UGC that you disclose or receive from third parties through the forums or email lists.

6. THIRD PARTY WEBSITES AND LINKS

We may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions.  We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services. 

7. YOUR RIGHTS

Depending on where you are located you may have certain rights in relation to your personal information:

  • Access: You have the right to access personal information we hold about you, how we use it, and who we share it with.
  • Portability: You have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
  • Correction: You have the right to correct any of your personal information we hold that is inaccurate.
  • Erasure: In certain circumstance, you have the right to delete the personal information we hold about you.
  • Restriction of processing to storage only: You have the right to require us to stop processing the personal information we hold about you, other than for storage purposes, in certain circumstances.
  • Objection: You have the right to object to our processing of your personal information.
  • Objection to marketing: You can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you.
  • Withdrawal of consent: Where we rely on consent to process your personal information, you have the right to withdraw this consent at any time by emailing us at support@p00l.io.

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. 

8. CHILDREN’S PRIVACY

We do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

9. DATA SECURITY

Please be aware that, despite our reasonable efforts to protect your information, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. 

10. CALIFORNIA PRIVACY RIGHTS

Sharing for Direct Marketing Purposes

California law permits users in California to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is shared with third parties for direct marketing purposes. We may from time to time elect to share certain “personal information” about you with third parties for those third parties’ direct marketing purposes. California users may, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year. 

To make such a request, please contact us using the information listed below. Please note that we are only required to respond to one request per California resident each year.

Users Under 18

Any California residents under the age of eighteen (18) who have registered to use the Services and who have posted content or information on the Services can request that such information be removed from the Services by contacting us at the e-mail or address set forth in the “How to Contact Us” section below. Such request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished the post and archived copies of it may be stored by search engines and others that we do not control.

11. HOW LONG DO WE STORE YOUR PERSONAL INFORMATION

We will retain your personal information as follows:

  • your account data for as long as you keep your account open or as needed to provide you with our Services;
  • if you contact us, we will keep your data for 26 months after you contact us; 
  • your technical usage information for 26 months; and
  • data on your use of our Website and our Services is retained for 26 months.

We will also retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies. If you stop using our Services, we may store your information in an aggregated and anonymized format; we may use this information indefinitely without further notice to you.

12. WHERE WE STORE YOUR INFORMATION

Personal information may be exported outside of the jurisdiction in which you reside. Under those circumstances, the governments, courts, law enforcement or regulatory agencies of that country or those countries may be able to obtain access to your personal information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside. You are not obliged to give your personal information to us, but if you choose not to do so, we may not be able to provide our services, or your access to our Services may be limited.

For any transfers of data outside the EEA or the UK, we will take appropriate measures in accordance with the GDPR to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy. These measures may include: entry into European Commission and UK Government approved standard contractual arrangements (“Model Clauses”). Please contact should you wish to examine a copy of the Model Clauses.

13. COMPLAINTS

If you are an EEA or UK resident and think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in the EEA country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner’s Office, as applicable to you. 

14. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at support@zeroze.ro or contact us at Silverside Management Ltd. of Whitehall Chambers, 2nd Floor Whitehall House, 238 North Church Street, PO Box 31489, KY1-1206, George Town, Grand Cayman, Cayman Islands.