ETZ Privacy Notice

Introduction and Scope

This Privacy Notice describes the practices of ETZ and its associated entities ("ETZ," "we," "us," or "our") regarding the collection, utilization, disclosure, and safeguarding of user data through the ETZ platform (accessible at https://www.etz.com), mobile applications, and all related offerings.

When we request specific personal details from users, such requests are either mandated by legal requirements or necessary for designated operational purposes. Information provided beyond what is required is furnished on a voluntary basis. Users retain discretion over providing non-mandatory information, though declining may limit access to certain Services.

Utilizing this platform, including related Application Programming Interfaces (APIs) and mobile applications, constitutes acceptance of the practices outlined in this Privacy Notice. We recommend thorough review of this document.

This Notice clarifies the types of data we gather, our methods of utilizing and retaining such data, and our data sharing practices. Users who object to the handling of their Personal Information (defined herein) as described may not utilize the platform or any services, software, APIs, technologies, products, or features we offer (collectively, the "Services").

Key Terminology

Digital Currency

The term "Digital Currency" encompasses what may also be termed "cryptocurrency," "virtual financial asset," or "digital commodity," including assets like bitcoin or ether. These are founded on cryptographic protocols within computer networks that may be: (i) centralized or decentralized in nature, (ii) proprietary or open-source, and (iii) utilized for transactional purposes and/or value storage.

Personal Information

"Personal Information" refers to any data relating to an identified or identifiable individual, including but not limited to: names, identification numbers, geographic data, digital identifiers, or factors pertaining to the physical, financial, cultural, or social characteristics of an individual.

PERSONAL INFORMATION WE GATHER

ETZ gathers, processes, and retains Personal Information obtained through your utilization of our Services or when consent has been provided. Such information may encompass contact particulars, identification document copies you supply or we obtain from publicly available sources, government-issued identification numbers, and device or internet service details (including IP and MAC addresses).

Operating across multiple regulated territories globally, ETZ handles personal data in compliance with applicable regulations, striving to meet the highest standards of data privacy requirements. This Privacy Notice consolidates various regulatory requirements applicable to our organization and serves as our unified policy governing data collection, retention, and processing activities. As regulations evolve, we continuously update our practices and this Notice accordingly.

We gather information provided during ETZ account registration, whether completed, partial, or abandoned. Personal data is also collected through customer support interactions, marketing subscription requests, or communications via telephone, email, or other channels. The Personal Information we collect, utilize, retain, and transfer may include:

For Individual Users:

Email contact
Mobile telephone number
Complete legal name (including previous names and names in native language)
Country of citizenship
Government-issued identification or passport number
Birth date
Identity verification documents (e.g., passport, driver's license, government ID)
Home address
Documentation of legal existence
Supplementary Personal Information or documentation as determined by our Compliance Department
Internet Protocol address
Device identification

For Business Entities:

Corporate legal designation (including designation in native language)
Registration/incorporation details
Complete legal names of all beneficial owners, board members, and authorized representatives
Physical locations (primary business address and/or additional locations)
Documentation of legal existence
Business operations description
Ownership percentages for individual/corporate stakeholders
Contact details for owners, principals, and senior management (where applicable)
Identity verification documents (e.g., passport, driver's license, government ID) for principal individual beneficial owners
Personal Information for each entity's principal beneficial owner (refer to "Individual Users" section for specifics)
Wealth source documentation
Projected fiat currency deposits
Projected cryptocurrency or digital asset deposits

INTERNATIONAL DATA TRANSFER

Given that we gather Personal Information from users across various jurisdictions, and many such jurisdictions mandate consent for cross-border Personal Information transfers, your explicit authorization is required and implied through your utilization and/or continued utilization of the Services. Declining such consent will result in inability to access ETZ's platform and/or Services. Digital asset withdrawal capabilities will remain available; however, all other platform functionalities will be disabled.

UTILIZATION OF YOUR PERSONAL INFORMATION

ETZ employs Personal Information for communication purposes and to manage, provide, enhance, and customize the Services. ETZ may generate anonymized data from collected Personal Information for internal purposes. Such data may also facilitate communications regarding additional products or services from ETZ and/or affiliated partners. Your Personal Information is not disclosed to external parties (except partners providing services to ETZ) without your authorization, as further detailed below.

Personal Information may be shared with external parties:

(a) when necessary to uphold our Terms of Service;

(b) to satisfy requirements of governmental entities, including regulatory bodies, law enforcement, and/or judicial departments;

(c) with service providers to ETZ (including administrative or technical service vendors);

(d) in relation to business sales or transfers, in whole or in part.

Furthermore, we maintain international protocols to combat money laundering, terrorism financing, and sanctions evasion, and will implement applicable Digital Currency regulations when effective, likely requiring customer due diligence. This may involve third-party data and service vendors for cross-referencing with your personal details.

PERSONAL INFORMATION RETENTION

We implement protective measures to shield users and ETZ from unauthorized access, modification, disclosure, or destruction of collected and stored personal data. Our information security approach includes multiple safeguards. Data is stored securely in fault-tolerant encrypted storage meeting industry standards, with numerous security protocols preventing data loss, misuse, or alteration, including:

5.1 Physical Safeguards. Physical documents containing personal information are secured in locked facilities. Physical storage of personal information occurs only under exceptional circumstances.

5.2 Digital Safeguards. Digital data containing personal information resides in computer systems and storage media with stringent access controls.

5.3 Administrative Safeguards. Only authorized personnel may access personal information, and such personnel must adhere to internal data confidentiality protocols. Strict physical access limitations to facilities and files are enforced. Additionally, staff undergo continuous training on applicable laws, regulations, privacy security protocols, and security awareness, with regular emergency response training and drills ensuring job competency and emergency protocol mastery.

5.5 Technical Safeguards. Our web servers are secured by multiple firewall systems.

Please understand that absolute information security cannot be guaranteed. Accordingly, we request your cooperation in independently implementing safety precautions to protect your personal information.

Essential security practices include:

5.6 Employ robust user identification, passwords, and PINs that are not easily guessable or known to others ("User Credentials"). User Credentials must satisfy our specified requirements upon creation. Maintain confidentiality and do not disclose User Credentials to anyone.

5.7 Install anti-virus, anti-spyware, and firewall software on personal computers and mobile devices.

5.8 Regularly update operating systems, anti-virus, and firewall products with current security patches and versions.

5.9 Disable file and printer sharing on computers, particularly when connected to the Internet.

5.10 Maintain regular backups of critical data.

5.11 Consider encryption technologies for highly sensitive or confidential information protection.

5.12 After completing platform sessions, log out completely and clear browser cache.

5.13 Avoid installing software or executing programs from unverified sources.

5.14 Delete unsolicited emails or chain correspondence.

5.15 Refrain from opening email attachments from unknown senders.

5.16 Do not disclose personal, financial, or payment card information to unfamiliar or questionable websites.

5.17 Avoid using untrusted computers or equipment.

5.18 Do not access online services or conduct financial transactions using public or internet café computers.

Should you suspect your personal information, particularly account and/or password details, has been compromised, immediately secure your account and contact our customer support team. Unless legally required or specified in the Terms of Use, you acknowledge our right (but not obligation) to retain all collected personal information throughout your Account duration and for 5 additional years following account closure. You acknowledge that, to the maximum extent legally permissible, we bear no liability for information breaches or losses not resulting from our intentional acts or gross negligence, including hacker attacks, power failures, or unavoidable technical malfunctions.

ACCESSING, MODIFYING, AND REMOVING YOUR PERSONAL INFORMATION

You possess the right to request copies of your Personal Information and verify whether our held information is accurate and current. Should any Personal Information be inaccurate, you may request updates. You may also request Personal Information deletion, though we may decline such requests in specific situations, such as legal compliance obligations. For data access, modification, or deletion requests, contact hello@etz.com with subject line "DATA INQUIRY".

Regarding data access, modification, or deletion requests, please note that for mutual protection, we can only process properly verified requests from authorized data owners. Therefore, before taking action, we will implement verification procedures as deemed necessary in our discretion to confirm requester identity (including telephone callbacks, email confirmations from registered email addresses, or other procedures we may require) to ensure request legitimacy. Due to potential complexities and international time differences, we cannot guarantee specific fulfillment timelines for such requests, and ETZ disclaims liability for any losses or damages resulting from delays in processing data access, modification, or deletion requests. While we endeavor to respond to data requests without charge, we reserve the right to impose reasonable fees for burdensome, repetitive, or resource-intensive requests.

PROMOTIONAL COMMUNICATIONS

We may communicate corporate updates, promotions, and information regarding products and services provided by ETZ. Personal Information may be shared with third parties supporting our marketing and promotional initiatives or to deliver marketing communications. By utilizing ETZ, you accept this Privacy Notice and consent to receiving such promotional communications.

Users may opt out of promotional communications at any time. To decline these communications, please email hello@etz.com.

For operational communications, including policy/terms updates and system notifications, opt-out options are not available.

COOKIE IMPLEMENTATION

When accessing ETZ, we may employ the standard practice of storing small data amounts via your browser (Cookies). This information may be stored on your computer or devices used to access ETZ. Such information assists in recognizing you as a user and collecting usage information to enhance our services and optimize your experience. We may also utilize collected information to support our compliance programs (BSA and AML) and detect irregular or suspicious account activities to maintain account security.

Most browsers default to automatic cookie acceptance. Some Cookies terminate upon session completion while others persist until deleted or expired. You may decline cookie usage, though this may impact ETZ service functionality or user experience.

PRIVACY INQUIRIES TO ETZ

For questions regarding this Privacy Notice or Personal Information usage, contact us via email at support@ETZ.com with subject line "PRIVACY REQUEST".

For European Economic Area users, you have the right to request that unresolved issues concerning personal information collection, use, or disclosure comply with applicable regulatory authority requirements in your jurisdiction.

PRIVACY NOTICE MODIFICATIONS

Future modifications to our Privacy Notice will be published on this page and, when appropriate, communicated through notifications and official website announcements. Regular review for changes and updates is recommended. As stated in this Privacy Notice, your utilization and/or continued utilization of Services constitutes implicit agreement to these terms and ongoing amendments, changes, or updates. You bear responsibility for monitoring this Privacy Notice for such amendments, and ETZ assumes no legal or financial liability for consequences of your failure to do so.

LANGUAGE SPECIFICATION

This Privacy Notice may be published in multiple languages. In case of discrepancies, the English version shall prevail.

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