Privacy Policy

24 July 2018

1. General

Zilpa Pte Ltd (Company Registration No. 201809903D) and having its registered address at 16 Raffles Quay #10-00 Hong Leong Building Singapore 048581(hereinafter referred to as “Zilpa,” “we,” or “us”) recognizes the privacy of its users (“you”) and have drafted this Privacy Policy (including Personal Data Protection Act 2012) (No. 26 of 2012) (the “Act”) to reflect its commitment to protecting your privacy and personal data, Zilpa Pte Ltd is acting as data controller for the Zilpa.IO collectors registry management platform (https://zilpa.io/ico) including its related apps for iPhone and Android devices (hereinafter referred to as the “Platform), and is committed to protecting and respecting your privacy.

The Privacy Policy outlines the information and data that we collect, how that information may be used, how it is stored and retained, with whom it may be transmitted to and your consent in relation to such uses and disclosures.

The Act recognizes the rights of individuals to protect their personal data (including rights of access and correction) and the requirement for organizations to collect, use or disclose personal data for legitimate and reasonable purposes.

We urge you to read and review this Privacy Policy carefully before using the Platform.  By using our Platform, you are deemed to have accepted our practices described in this Privacy Policy.

2. Collect of information

2.1. We may collect and process the following information or data (including personal information and information that can be uniquely identified with you) about you:

2.1.1. your name (first name and/or last name), email address, IP, phone number and browsing data;

2.1.2. and other non-personally identifiable information including browser type, language preference, referring site, date and time of visits, which we may collect, or you may provide us while visiting our website.

2.1.3. details of your initial sign-up date and visits to the Platform and the resources that you access;

2.1.4. information we may require from you when you report a problem with the Platform;

2.1.5 we also collect aggregated information regarding your activity on our Platform.

2.2. We only collect such information when you choose to supply it to us.  We collect personal information for logged-in users, transacting users and commenting users.  All personal information collected will be used for the purposes of delivering quality online services on the Platform to you.

2.3. If you intend to purchase Zilpa (ZLP) tokens (“ZLP Tokens”), Zilpa will collect and store the following types of Personal Data about You:

  1. Your name, Date of birth;
  2. Your address, country of residence;
  3. Your email and contact phone.

2.4. In certain cases (when additional verification by bank or compliance authority is needed according to governmental rules, anti-money laundering (AML) or “know-your-customer” (KYC) policies) Zilpa may require you to provide additional information, and namely:

  1. Passport or driver license details;
  2. Numbers that you may use or have registered with your local tax authority;
  3. Utility bills;
  4. Photographs of You;
  5. Confirmation of proceeds sources;
  6. Sworn statements.

The abovementioned information and details shall be provided only upon special personal request to you and specified in respective email. Zilpa also reserves the right to request for remote identification procedures from you.

2.5. Zilpa reserves the right to request basic personal data to be presented to us prior to the purchase of ZLP Tokens and/or use of any services, available through the website or Platform. Zilpa may refuse your access to the website or Platform in case if Zilpa has grounded doubts as to validity, authenticity, and genuineness of the personal data, provided by you.

2.6. If you do not provide Zilpa with the personal data as specified hereof, you shall not be able to use the full functionality of the website or Platform and purchase ZLP Tokens and/or use the Platform. At that, Zilpa shall not bear any liability for such possible incomplete use.

2.7. When you access the website or Platform, Zilpa (or Google Analytics or similar service provider on our behalf) may place small data files called cookies on your computer or other devices. Zilpa uses these technologies to recognize you as our ZLP Token sale participant, customize the Platform (if required), advertising, measure promotional effectiveness and collect information about your computer or other access devices to mitigate risk, help prevent fraud and promote trust and safety. You may control the use of cookies within your internet browsers’ settings. If you reject or delete certain cookies, be aware that the performance of the related features and functions of our Website and services may be impaired.

2.8. Zilpa only collects from participants personal data that Zilpa needs for your proper use of the website or Platform or for the purchase of ZLP Tokens. In particular, Zilpa uses the participant’s personal data to:

  1. Administer the Platform and provide services;
  2. Develop new products and services;
  3. Personalize the Platform for you;
  4. Send you technical notices and support and administrative messages;
  5. Communicate with you about products, services, promotions, events and other news and information Zilpa think will be of interest to you;
  6. Monitor and analyze trends, usage and activities in connection with the Platform;
  7. Provide third parties with statistical information about Zilpa.IO participants (but those third parties will not be able to identify any individual participant from that information);
  8. Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Zilpa.IO and others;
  9. Link or combine personal data Zilpa collects from or about you; and
  10. Verify compliance with the terms and conditions governing the use of Zilpa.IO website.

3. Use of information

By using the Platform, you expressly authorize and consent to us gathering, reviewing, retaining and where reasonably required, transmitting the data to our intermediary companies and entities for the proper and reasonable purpose of them storing and using the data responsibly and in accordance with the Act. When you provide personal information through our Platform, the information may be sent to servers located outside of Singapore (including the United States).

We may use this information to:

3.1.1. carry out and administer any obligations arising from any agreements entered into between you and us;

3.1.2. allow you to participate in features of the Platform and other services; communicate with you by email to send relevant notifications about your activity on Zilpa IO and/or mobile devices about products or services that may be of interest to you; enable third parties to display inside the Platform products or services that may be of interest;

3.1.3. contact you and notify you about changes to the Platform or the services we offer (except where you have asked us not to do this);

3.1.4. analyze how users are making use of the Platform and for internal marketing and research purposes.

3.1.5. ensure that you comply with the conditions and applicable law.

3.1.6. Send you important notifications that you will require to use the Platform (eg: Forgot your password)

4. With whom we share your information

4.1 We do not share your personal information with others except as indicated in this Privacy Policy or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with:

4.1.1 Service providers: We may share information, including personal information, with third parties that perform certain services on our behalf. These services may include server hosting, marketing and supporting our notification service functionality, banking and brokerage partners, third-party identification service providers for fraud prevention purposes, Zilpa processing counterparties or agents hired by or cooperating with us.  These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.

4.1.2 We may allow other third-party service providers, advertising companies, advertisement networks, merchandising companies and other third parties to display advertisements and brands on our Platform. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements.

We do not provide any non-anonymized personal information to third parties.  We will adhere strictly to the provisions in the Act in relation to any disclosure and dissemination of information to any third parties.

4.2 Other Situations. We may disclose your information, including personal information:

In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.

5. Third Party Sites

There are a number of places on our Platform where you may click on a link to access other websites (such as token exchanges) that do not operate under this Privacy Policy. For example, if you click on an advertisement (news and promotions) on our Platform, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit.

6. How we protect your personal information

We take security measures to help safeguard your personal information from unauthorized access and disclosure. However, no system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee that your personal information, chats, or other communications will always remain secure.

If you wish to deactivate your account and delete all data related to your account, please email us at [email protected] Your account and all related data will be deleted within seven (7) business days.

7. No Third Party Rights

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the Platform.

8. Notification of changes to our Privacy Policy

We will post details of any changes to our Privacy Policy on our website (https://token.zilpa.io) or Platform to help ensure you are always aware of the information we collect, how we use it, and under what circumstances, if any, we share it with other parties.

9. Specific provisions related to the European Union General Data Protection Regulation (EU GDPR)

9.1    We acknowledge that the EU GDPR will apply if we process any personal data of individuals for data controllers in the EU or if we offer goods or services to individuals in the EU.  We understand that personal data must be processed lawfully, fairly and transparently, be collected and applied only for specified, explicit and legitimate purposes, must be limited to only what is required, must be accurate, not be kept in personally identifiable form for longer than is necessary and must be secured and protected pursuant to the EU GDPR.

9.2    We acknowledge and agree that the EU GDPR affords individuals with rights such as the right to be notified, right of access, right to fix incorrect information, right to be forgotten, right to restrict data use, right to data portability and right to object.  We agree that our data controller will act on a request from an individual without undue delay (within one month).  We will maintain records of how we process personal data, acknowledge the need to conduct data protection impact assessments and the need to apply careful consideration in the adoption and engagement of our data processors.
Contact & Data Protection Officer

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your Personal Data, please use one of the following means:

  • via email to:
    Our Data Protection Officer: [email protected];OR
  • by letter to:
    Zilpa Pte Ltd
    16 Raffles Quay #10-00 Hong Leong Building
    Singapore 048581