Privacy Policy

1. Introduction

Zavin Technologies, Inc. ("Zavin," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our financial infrastructure platform and related services (collectively, the "Services").

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our policies and practices, do not use our Services.

2. Information We Collect

2.1 Information You Provide to Us

We collect information that you provide directly to us, including:

• Account Information: Name, email address, phone number, company name, and business details
• Identity Verification: Government-issued ID, proof of address, date of birth, and other KYC documentation
• Financial Information: Bank account details, transaction history, wallet addresses, and payment information
• Business Information: Company registration documents, beneficial ownership information, and business purpose
• Communications: Information you provide when you contact us, respond to surveys, or participate in promotions

2.2 Information Collected Automatically

When you use our Services, we automatically collect certain information:

• Usage Data: Information about how you use our Services, including transaction data, API calls, and feature usage
• Device Information: IP address, browser type, operating system, device identifiers, and mobile network information
• Location Data: General location information based on IP address
• Log Data: Server logs, error reports, and diagnostic information
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Identity verification service providers
• Fraud prevention and security service providers
• Banking and payment partners
• Blockchain data providers
• Credit bureaus and screening databases

3. How We Use Your Information

We use the information we collect to:

3.1 Provide and Maintain Our Services

• Process transactions and manage your account
• Provide customer support and respond to your requests
• Maintain and improve our platform infrastructure
• Develop new features and services

3.2 Compliance and Security

• Verify your identity and comply with KYC/AML regulations
• Detect, prevent, and address fraud, security incidents, and prohibited activities
• Comply with legal obligations and regulatory requirements
• Enforce our Terms of Service and other agreements
• Protect the rights, property, and safety of Zavin, our users, and the public

3.3 Communications

• Send you service-related notifications and updates
• Respond to your comments, questions, and requests
• Send you technical notices, security alerts, and administrative messages
• Provide you with news and information about our Services (with your consent)

3.4 Analytics and Improvement

• Analyze usage patterns and trends
• Monitor and analyze the effectiveness of our Services
• Develop and test new products, features, and services
• Conduct research and analytics

4. How We Share Your Information

We may share your information in the following circumstances:

4.1 With Your Consent

We may share your information when you explicitly authorize us to do so.

4.2 Service Providers

We share information with third-party vendors, consultants, and service providers who perform services on our behalf:

• Identity verification and KYC service providers
• Payment processing and banking partners
• Cloud hosting and infrastructure providers
• Fraud detection and security services
• Customer support platforms
• Analytics and data processing services

4.3 Legal Requirements and Protection

We may disclose your information if required to do so by law or in response to:

• Legal processes (subpoenas, court orders, government requests)
• Regulatory requirements and investigations
• Enforcement of our Terms of Service or other agreements
• Protection of our rights, property, or safety
• Prevention or investigation of fraud or security issues

4.4 Business Transfers

In connection with any merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.

4.5 Aggregated and De-Identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you for research, analytics, or other purposes.

5. Data Security

We implement appropriate technical and organizational security measures to protect your information:

• Encryption of data in transit (TLS 1.3) and at rest (AES-256)
• Multi-factor authentication and access controls
• Regular security audits and penetration testing
• Secure data centers with physical access controls
• Employee security training and background checks
• Incident response and disaster recovery procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your information for as long as necessary to:

• Provide our Services and maintain your account
• Comply with legal, regulatory, and tax obligations
• Resolve disputes and enforce our agreements
• Prevent fraud and abuse

We typically retain transaction data for at least 7 years to comply with financial regulations. When information is no longer needed, we securely delete or anonymize it.

7. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

7.1 Access and Portability

You have the right to access and obtain a copy of your personal information.

7.2 Correction

You have the right to correct inaccurate or incomplete personal information.

7.3 Deletion

You have the right to request deletion of your personal information, subject to certain exceptions (legal obligations, fraud prevention, dispute resolution).

7.4 Objection and Restriction

You have the right to object to certain processing of your information and request restriction of processing.

7.5 Withdraw Consent

Where we process your information based on consent, you have the right to withdraw consent at any time.

To exercise these rights, please contact us at privacy@zavin.io. We will respond to your request within 30 days.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have data protection laws different from those in your country.

We ensure appropriate safeguards are in place for international transfers, including:

• Standard contractual clauses approved by relevant authorities
• Data processing agreements with service providers
• Compliance with applicable cross-border transfer regulations

9. Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at privacy@zavin.io.

10. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last updated" date
• Sending you an email notification (for significant changes)

Your continued use of our Services after the effective date of the revised Privacy Policy constitutes acceptance of the changes.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us: