> For the complete documentation index, see [llms.txt](https://docs.zoth.io/zoth/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.zoth.io/zoth/legal-disclaimer/privacy-policy/zpayments.md). # zPayments ### I. INTRODUCTION Welcome to zPayments. This Privacy Policy ("Privacy Policy") explains how Zoth Payments Limited ( the "Company", "we", "our" or "us") the operator of zPayments collects, uses, stores, shares and protects your Personal Information when you access or use our website, APIs, dashboards, portals, applications and other services that facilitate stablecoin-funded fiat payouts through the payment infrastructure and settlement network operated by or integrated with Zoth Payments Limited (collectively, the "Services"). We recognise the importance of protecting your privacy and are committed to handling your Personal Information responsibly and in accordance with applicable laws. We maintain administrative, technical and organisational measures designed to safeguard your Personal Information from unauthorised access, disclosure, alteration, misuse or loss. This Privacy Policy should be read together with our Terms of Use and forms an integral part thereof. By accessing or using the Services, creating an account, or otherwise providing your Personal Information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use and disclosure of your Personal Information as described herein. ### II. INFORMATION WE COLLECT To provide our Services, comply with legal and regulatory obligations, prevent fraud and maintain the security of our Platform, we collect Personal Information directly from you, automatically through your use of the Services and, where permitted by applicable law, , from authorised third parties. The Personal Information we collect may include your name, residential or business address, email address, telephone number, date of birth, nationality, government-issued identification documents, tax identification details, photographs, company registration information, beneficial ownership details and information relating to authorised representatives where you are acting on behalf of a legal entity. Where necessary to facilitate transactions, we may also collect financial and payment-related information, including bank account details, beneficiary information, payment instructions, settlement records, transaction history, payout information and details relating to supported stablecoins. If you use blockchain-based features of the Services, we may collect publicly available information associated with your transactions, including wallet addresses, transaction hashes, blockchain network identifiers and other digital asset information required to process or verify transactions carried out through the Platform. To comply with applicable anti-money laundering, counter-terrorist financing and sanctions laws, we may also collect information required for identity verification and compliance purposes, including Know Your Customer (KYC) and Know Your Business (KYB) documentation, source of funds, source of wealth, sanctions screening results, politically exposed person (PEP) status and any enhanced due diligence information required under applicable law. In addition, we automatically collect certain technical information when you use the Platform, such as your IP address, browser type, operating system, device identifiers, access logs, cookies, usage data and other technical information that helps us operate, secure and improve the Services. We may also retain records of any communications you have with us, including customer support requests, enquiries, complaints, feedback and other correspondence. ### III. HOW WE COLLECT INFORMATION We collect Personal Information directly from you when you register for an account, complete onboarding procedures, submit KYC or KYB documentation, initiate transactions, contact our support team or otherwise interact with the Services. Certain information is collected automatically through cookies, server logs, analytics tools and similar technologies when you access or use the Platform. This information helps us understand how the Services are used, improve their functionality and maintain their security. Where permitted by law and where reasonably necessary for the purposes described in this Privacy Policy, we may also obtain Personal Information from trusted third parties, including banking partners, payment processors, liquidity providers, blockchain analytics providers, identity verification providers, sanctions screening providers, public registries and government authorities, as well as other service providers engaged to support the delivery of our Services. ### IV. PURPOSE OF PROCESSING We use Personal Information only for purposes that are connected with providing and improving our Services or where we are required or permitted to do so under applicable law. In particular, we may use your Personal Information to create and manage your account, verify your identity, complete KYC and KYB procedures, process stablecoin-funded fiat payouts, facilitate settlements through our banking and payment partners, communicate with you regarding your account or transactions, respond to enquiries, detect and prevent fraud, manage operational and security risks, improve the functionality of the Platform, conduct internal reviews and audits, comply with legal and regulatory obligations, enforce our contractual rights, resolve disputes and protect the legitimate interests of zPayments, its users and its business partners. Where permitted by applicable law, we may also use aggregated or de-identified information for business analytics, product development, service improvements and other internal business purpose/s. ### V. DISCLOSURE OF PERSONAL INFORMATION We do not sell your Personal Information. However, we may disclose or otherwise make Personal Information available to third parties where reasonably necessary to provide, operate, maintain, secure or improve the Services, facilitate transactions, comply with applicable legal or regulatory requirements, prevent fraud or misuse, or protect the rights, property, security or legitimate business interests of Zoth Payments Limited, its users and its business partners. Your Personal Information may be shared with banking partners, payment processors, settlement providers, liquidity providers, blockchain infrastructure providers, cloud service providers, identity verification and compliance vendors, fraud prevention providers, technology providers, professional advisers, auditors, insurers, affiliates and other service providers engaged to support the operation of the Platform. We may also disclose Personal Information where required by law, regulation, court order or other legal process, or where we believe such disclosure is necessary to protect our rights, comply with regulatory requirements, respond to law enforcement requests or establish, exercise or defend legal claims. Where Personal Information is shared with third parties, we take reasonable steps to ensure that such parties are subject to appropriate confidentiality obligations and implement security measures appropriate to the nature of the information disclosed. ### VI. CROSS-BORDER DATA TRANSFERS Your Personal Information may be transferred to, stored in and processed in jurisdictions outside the jurisdiction in which you are located in connection with the provision and operation of the Services. Such jurisdictions may include jurisdictions in which our payout partners, payment service provider counterparties, compliance and screening vendors, technology providers and other service providers operate. Where Personal Information is transferred to or processed in another jurisdiction, Zoth Payments Limited will implement appropriate contractual, technical and organisational safeguards where and to the extent required by applicable law. The Company is incorporated in Canada and processes Personal Information on servers located in Canada. Where you provide Personal Information from the European Economic Area (EEA) or the United Kingdom (UK), transfers may be made in reliance on applicable adequacy decisions, to the extent the relevant transfer falls within the scope of such adequacy decisions. Where an applicable adequacy decision applies, no additional transfer safeguard is required solely by reason of the transfer to Canada. Where Personal Information is transferred onward to recipients located outside Canada, the EEA, the UK or another jurisdiction recognised as providing an adequate level of protection under applicable law, Zoth Payments Limited will implement an appropriate transfer mechanism or safeguard where required by applicable law. Such safeguards may include the Standard Contractual Clauses approved by the European Commission and, where applicable, the UK International Data Transfer Addendum, together with any assessment or other measures required under applicable law. The categories of recipients your Personal Information may be transferred to includes: (i) payout partners who receive and disburse funds in connection with your payment instructions;; (ii)compliance and screening vendors who assist identity verification, sanctions screening and fraud prevention and related compliance activities; (iii) and payment service provider counterparties and other financial or technology service providers involved in processing or facilitating your transactions.. You may request information regarding the safeguards applicable to a particular transfer, subject to applicable law and confidentiality or security restrictions by contacting us at ### VII. BLOCKCHAIN TRANSACTIONS Certain features of the Services rely on public blockchain networks. These networks operate independently of zPayments and we do not own, control or manage them. Transactions recorded on a blockchain, including wallet addresses, transaction hashes and certain transaction details, may be publicly accessible and permanently recorded. Although this information may not directly identify an individual, it may be capable of identifying a person when combined with other available information. Because blockchain records are generally immutable, Because blockchain records may be immutable, zPayments may not be able to modify, delete or remove information once it has been permanently recorded on a public blockchain. Zoth Payments Limited may associate a verified user's identity with their blockchain wallet address and transaction history where reasonably necessary for compliance, fraud prevention, risk management, transaction monitoring or other purposes permitted by applicable law. ### VIII. COMPLIANCE AND REGULATORY MONITORING zPayments may collect, review, verify, monitor and retain personal information to comply with applicable anti-money laundering (AML), counter-terrorist financing (CTF), sanctions, fraud prevention, risk management and regulatory requirements, including obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) and requirements imposed by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Such information may be disclosed to competent regulatory authorities, law enforcement agencies, or other governmental bodies where required by law or as otherwise permitted by applicable regulation. zPayments reserves the right to suspend or terminate access to the Services and report activity to relevant authorities where required or permitted by law. ### IX. DATA RETENTION Personal information shall be retained for 5 years following account closure or the last transaction for AML/CTF. 1. Comply with applicable legal, tax, accounting, AML, CTF, sanctions, regulatory, audit and record-keeping obligations; 2. Resolve disputes and enforce agreements; and 3. Protect the legal rights and interests of zPayments. Certain information may be retained beyond termination of access to the Services where required by applicable law or regulatory authorities. Upon expiry of applicable retention periods, personal information will be securely deleted or anonymised in accordance with our internal data management procedures. ### X. DATA SECURITY We maintain appropriate administrative, technical and organisational measures designed to protect Personal Information against unauthorised access, disclosure, alteration, misuse, loss or destruction. These measures include access controls, encryption technologies, authentication procedures, secure network infrastructure, system monitoring and periodic security assessments. While we continually review and enhance our security practices, no method of transmitting or storing information electronically can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of Personal Information and users provide information to us at their own risk. ### XI. DATA BREACH NOTIFICATION Zoth Payments Limited will assess suspected or confirmed breaches of security safeguards in accordance with applicable law and will report such breaches to the Office of the Privacy Commissioner of Canada and notify affected individuals where and to the extent required by applicable law. ### XII. YOUR RIGHTS Subject to Personal Information Protection and Electronic Documents Act (PIPEDA) and regulatory constraints, users may have the right to: 1. Request access to personal information held about them; 2. Request correction of inaccurate or incomplete information; 3. Request deletion of information where legally permissible and not subject to mandatory retention obligations; 4. Object to or request restriction of certain processing activities; 5. Withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing; 6. Request information regarding how personal information is processed; and 7. Lodge a complaint with the PIPEDA data protection or regulatory authority. Please note that certain rights may be limited or overridden by applicable legal obligations, including AML, CTF, sanctions and regulatory record-keeping requirements. Requests to exercise rights may be submitted to the contact details set out in Section 13 below. ### XIII. COOKIES AND TRACKING TECHNOLOGIES zPayments may use cookies, web beacons, pixels and similar tracking technologies to operate and improve the Website and Platform, analyse usage patterns and support security and fraud prevention. Users may configure their browser settings to decline cookies, although this may affect the functionality and performance of the Services. zPayments does not use tracking technologies to serve targeted advertising to users. ### XIV. CONTACT INFORMATION If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal information, please contact: Zoth Payments Limited 1591 – 329 Howe Street, Vancouver, BC, V6C 3N2, Canada Email: Website: