Privacy policy

This Privacy Policy explains how Zota Technology (CA) Inc. ("Zota", "we", "us") collects, uses, discloses, stores, and protects personal information in the course of providing its services.

This Privacy Policy applies to:

• ·all users and clients of Zota;
• ·all personal information collected through the website, online portal, communications, or services; and
• ·all processing activities conducted by or on behalf of Zota.

The collection, use, and disclosure of personal information described in this Privacy Policy, including for identity verification and anti-money laundering purposes, is necessary for Zota to establish and maintain a business relationship with you. Zota will not require consent to the collection, use, or disclosure of personal information beyond what is required to fulfil the explicitly specified and legitimate purposes described in this Privacy Policy.

This Privacy Policy forms an integral and binding part of the contractual framework governing the relationship between you and Zota, together with:

• ·Disclaimer
• ·General Terms & Conditions
• ·Website Terms of Use
• ·Any pricing, fees, or commercial terms accepted online

By engaging with Zota’s services, you acknowledge that you have read and understood this Privacy Policy.

Zota processes personal information in accordance with:

• ·the Personal Information Protection and Electronic Documents Act (PIPEDA), and any successor legislation;
• ·applicable provincial privacy laws, where relevant, including but not limited to Quebec’s Act respecting the protection of personal information in the private sector and the Personal Information Protection Acts of Alberta and British Columbia;
• ·the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations, and other applicable Canadian laws; and
• ·where applicable, foreign data protection laws (including the EU and UK General Data Protection Regulation and the Swiss Federal Act on Data Protection).

Zota may collect and process the following categories of personal information:

• ·identification and contact details (e.g. name, address, email, phone);
• ·business and professional information;
• ·beneficial ownership and control information;
• ·government-issued identification (where required by law);
• ·transaction-related and usage data;
• ·communications and correspondence;
• ·technical data (IP address, device identifiers, logs).

Zota’s services are not intended for individuals under the age of majority in their province or territory of residence, and Zota does not knowingly collect personal information from such individuals.

Personal information is collected and used for the following purposes:

• ·client onboarding and account administration;
• ·compliance with AML / ATF, sanctions, and regulatory obligations;
• ·provision and operation of services;
• ·fraud prevention, security, and risk management;
• ·communication with clients and users and, with consent, marketing communications in accordance with Canada’s Anti-Spam Legislation;
• ·legal, regulatory, and audit purposes.

Zota does not use personal information for purposes incompatible with those described above.

Zota processes personal information on one or more of the following bases, as permitted under PIPEDA:

• ·contractual necessity;
• ·compliance with legal and regulatory obligations;
• ·legitimate business purposes;
• ·consent, where required by law.

Where consent is required, it is obtained through explicit actions (e.g. acceptance of policies, submission of information).

Zota may share personal information with regulated third-party service providers, including:

• ·banks, payment institutions, electronic money institutions, and payment card processors;
• ·virtual currency exchanges, liquidity providers, custodians, and other virtual asset service providers;
• ·identity verification, AML/KYC, sanctions screening, and blockchain analytics providers;
• ·technology, hosting, and security providers;
• ·professional advisers and auditors.

Such disclosures are made only where necessary and subject to contractual and organisational safeguards.
Zota does not sell personal information.

Personal information may be transferred to and processed in jurisdictions outside Canada, including the European Union, United Kingdom, or Switzerland, where Zota or its service providers operate.

Where cross-border transfers occur, Zota applies appropriate safeguards to ensure an adequate level of protection consistent with applicable laws.

Zota retains personal information only for as long as necessary to fulfil the purposes for which it was collected, including:

• ·AML / ATF records: at least five (5) years, as required under the PCMLTFA and its regulations, or longer where required by law;
• ·transaction and business records: as required under applicable legislation;
• ·general communications: as necessary for business and legal purposes.

Once retention periods expire, data is securely deleted or anonymised. Information recorded on a public blockchain in connection with a virtual currency transaction is permanent and cannot be modified or deleted by Zota.

Zota implements appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, or disclosure.

Despite these measures, no system can guarantee absolute security. In the event of a breach of security safeguards involving personal information that creates a real risk of significant harm, Zota will notify affected individuals, the Office of the Privacy Commissioner of Canada, and any other competent authority, as required by applicable law.

Subject to applicable law, individuals may request:

• ·access to their personal information;
• ·correction of inaccurate or incomplete information;
• ·information about how their data is used.

Requests may be submitted using the contact details below and will be handled in accordance with PIPEDA. Additional rights may apply depending on applicable provincial law, including rights relating to:

• ·withdrawal of consent where consent is the legal basis;
• ·complaints;
• ·information about collection/use/disclosure;
• ·correction;
• ·access; and
• ·deletion/withdrawal requests where legally available.

Zota may disclose personal information:

• ·to FINTRAC, including through suspicious transaction reports, large virtual currency transaction reports, and other reports required under the PCMLTFA, or to other competent authorities;
• ·where required by law or court order;
• ·to enforce legal rights or protect the integrity of services.

Such disclosures are made in accordance with applicable legal requirements.

Zota uses cookies and similar technologies in accordance with its Cookie Policy.
Where required by law, consent is obtained through the website’s cookie management tools.

This Privacy Policy may be updated from time to time to reflect changes in law, regulation, or business practices.
Updated versions will be published on the website. Continued use of services constitutes acceptance of the updated Privacy Policy.

Questions or requests relating to this Privacy Policy may be directed to:
Zota Technology (CA) Inc.
Email: info@zotatech.ca