Scope

This Privacy Policy describes what personal information Ope Hub, dig. tec., d.o.o. (“we,” “us,” “our,” the “Company,” or “ETZ”) collects, why we collect it, and how we process your information. This Privacy Policy, together with the ETZ Terms of Use, applies to you whether you access the ETZ website and/or any services provided by ETZ directly or via a third-party digital asset service provider (a “Third-Party Platform”).

By accessing or using ETZ, you represent that you are at least eighteen (18) years of age, have the legal capacity to consent to this Privacy Policy, and agree to fully comply with the policies and practices set forth herein. If you are under eighteen (18) years of age, you may not create an account or otherwise access ETZ products and services.

Digital Assets

As used herein, “Digital Assets” refer to digital assets based on cryptographic protocols in electronic systems (also referred to as “cryptocurrency,” “virtual currency”), including but not limited to Bitcoin or Ether, where such electronic system may be (i) centralized or decentralized, (ii) proprietary or open source, and (iii) used as a medium of exchange and/or store of value.

Information We Collect and Why We Collect It

For various purposes—including creating your account, performing our contractual obligations to you, communicating with you, improving our products and services, detecting and monitoring fraud on the Platform, and complying with contractual and legal obligations—we must collect certain personal information. By accepting this Privacy Policy, you expressly consent to ETZ collecting the following categories of personal information:

Identity Information

Information used to identify you, such as your full legal name, date of birth, nationality, identification number or social security number, email address, telephone number, and residential address, as well as supporting documentation such as your passport, national ID card, and driver’s license.

For institutional users, this includes your institution’s legal name, employer identification number (“EIN”) or similar identifier, identity information relating to your account representatives and beneficial owners, business address, entity formation documentation, contact information, and any other information we may reasonably require to open your account and fulfill obligations related to the operation of such account.

Biometric Information

Information you provide during account registration, such as facial images or videos, which we use with specific identity verification and image recognition software to verify your identity.

Account Information

Additional information that may be required to open and operate your account, such as information regarding the source of your funds, bank account information, loan accounts, investment accounts, and credit and/or debit card information.

Device Information: Information automatically collected regarding your device (including but not limited to hardware, operating system, browser, etc.) and usage data (see “Cookies” below).

Location Information

Information automatically collected by analytics system providers to determine your location, including your IP address and/or domain name and any external webpage that referred you to us.

Log Information

Information generated when you use ETZ, which is automatically collected and stored in our server logs. This may include, without limitation, device-specific information, location information, system activity, and any internal and external information related to the ETZ pages you visit.

Transaction Information

Information generated by your transactional activity, including, without limitation, transaction activity, Digital Asset wallet addresses, and ownership details associated with wallet addresses.

Communications Information

Information you provide to us in communications, including onboarding applications and ongoing customer support interactions.

Blockchain and Analytics Information

Information obtained through public blockchains and blockchain analytics tools, such as wallet balances and transaction history.

Employment Data

Information about your employer, including where you provide payroll or tax documentation.

How We Collect Personal Information

We collect the personal information described above through various means, including:

Directly from you, when you create an ETZ account;
From you and/or Third-Party Platforms, when you use ETZ Pay products via a Third-Party Platform (as applicable);
From certain other third-party service providers and public registries that we use to verify your identity and process your transactions.

These third-party providers include, without limitation:

Plaid

ETZ uses Plaid Inc. (“Plaid”) to collect end-user data from financial institutions. By using our services, you expressly consent to the collection and processing of such personal information and grant ETZ and Plaid the rights, power, and authority to access and transmit your personal and financial information obtained from the relevant financial institutions on your behalf. You agree that your personal and financial information is transmitted, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

Sumsub

ETZ uses Sumsub to verify users’ identity documents and to screen users in accordance with our anti-money laundering (“AML”) and counter-terrorist financing (“CTF”) obligations. By using our services, you expressly consent to the collection of such personal information (including biometric information) and agree to the storage, retention, use, and disclosure of such information in accordance with the Sumsub Privacy Policy.

Please note that if you withdraw consent relating to the methods used to collect your personal information described above, you will be unable to continue using ETZ. In such case, please contact us to close your account.

Cookies

When you access ETZ, ETZ may use standard practices that place small data files on your computer or other device used to access ETZ, including cookies, flash cookies, pixel tags, or other tracking technologies (collectively, “Cookies”). Cookies are small pieces of information automatically stored in your device’s web browser that we can retrieve.

The types of information we collect include, without limitation, unique visitor identification information and information relating to your usage preferences. ETZ uses these technologies to help identify you as a user, collect information about how you use ETZ in order to better tailor our services and content to you, and collect information about your computer or other access device to (i) help ensure compliance with our BSA/AML program, and (ii) help ensure that your account remains secure by detecting abnormal or suspicious account activity.

By using ETZ, you acknowledge and agree that we may collect and/or transmit any collected data to our third-party service providers, such as analytics providers, who may also use the technologies described above. Please note that if you block or delete Cookies, you may be unable to use some or all functions of the ETZ website and/or services. If you do not consent to the placement of Cookies on your device, do not access or use ETZ.

How We Share Personal Information

ETZ will use your personal information only for the purposes described in this Privacy Policy. In some cases, this requires that we share your personal information with certain third parties, including:

Third-party identity verification services, which confirm your identity by comparing information you provide to public records and other third-party databases;
Third-party fraud monitoring/detection and other services used to monitor fraud and other prohibited conduct;
Service providers and affiliated entities under contract that assist us in operating portions of our business, such as payment processing, marketing, technology services, compliance services, and other necessary operations supporting our services;
Financial institutions that help process your transactions and otherwise support our services;
Third-party digital asset service providers, where applicable, when executing transactions between you and another third-party digital asset service provider on your behalf;
Companies or other entities involved in any joint venture, merger, acquisition, or sale of ETZ business for any reason;
Law enforcement agencies, regulators, or other authorized officials, including when:
(i) we are required to report customer information pursuant to regulatory obligations;
(ii) we are compelled to do so by subpoena, court order, or similar legal process;
(iii) we in good faith believe disclosure of personal information is necessary to prevent physical harm or financial loss, report suspected illegal activity, or investigate violations of our user agreements; or
(iv) disclosure is otherwise required by law; and
Other third parties with your consent or at your direction.

The third parties and affiliated service providers described above are subject to confidentiality and security obligations. You should be aware that such third parties and affiliated service providers may be located outside the jurisdiction in which you reside. By accepting this Privacy Policy, you expressly consent to any such cross-border transfer, storage, and processing of your personal information for the purposes described in this Privacy Policy.

Direct Marketing

Subject to applicable laws and regulations, we may from time to time use information collected from you to send you direct marketing materials promoting services, products, facilities, or activities. You may opt out of such direct marketing communications using the unsubscribe mechanism included in any direct marketing communication we send you. ETZ will never sell your personal information to any third party for marketing purposes.

Retention

ETZ will retain your personal information during the term of our relationship with you and for a period thereafter, in order to comply with applicable legal retention obligations.

Security and Breach

ETZ implements strict security measures designed to ensure the security, integrity, and confidentiality of your personal information. In the unlikely event of a system breach affecting your personal information, ETZ will act in accordance with its legal obligations to notify you and any relevant authorities.

Your Rights

Depending on applicable laws in your country or state, you may have certain rights regarding the use of your personal information, such as: requesting a copy of your personal information; where applicable, requesting the transfer of your personal information; objecting to the use of, or sharing of, your personal information for certain purposes (such as direct marketing); or requesting that we correct or delete your personal information.

If you wish to exercise any of these rights, please contact us at the email address provided below, specifying your request and the basis on which you are making such request. You have the right to exercise any applicable rights without discrimination, meaning that if you choose to exercise one of these rights, we will not discriminate against you or your use of ETZ services. However, please note that these rights are not absolute or guaranteed in all circumstances, and we will need to carefully consider your request in light of the terms explained in this Privacy Policy.

Contact Us

For any matters relating to this Privacy Policy, you may contact us at: customerservice@etz.com

Amendments

ETZ reserves the right to amend this Privacy Policy from time to time.

Third-Party Privacy Policies