Privacy and Cookie Policy

This Privacy and Cookies Policy (the “Privacy Policy”) governs Your use of Zenit World’s content, features, products and services (“Services”) branded as Zenit (“Zenit”, “we”, “our”, “us”) and encompasses Your use of the website domain https://zenit.world/, any additional Zenit APIs, portal, or mobile application (hereinafter collectively referred to as the “Platform”), and all documents, data, materials or other information made available on the Platform. This Policy applies to all visitors, account holders and/or users (“User”, “you”, “your”) who act in their own personal capacity, or who are authorized to act on behalf of a corporate entity. Please read this Policy along with our Terms and Conditions carefully, and note that by using Zenit World, you are consenting to the collection, storage, processing, and transfer of your Personal Data in accordance with this Privacy Policy. Capitalized terms used in this Privacy Policy but not defined here, adopt the same meaning given to them in our Terms and Conditions.

1. Definitions

1.1. “Account” refers to the registered account opened by the User on the Platform.

1.2. “Third Party Service Provider” means the service providers and Third-Parties with which we have service agreements to expand the range of Services and products accessible across our Platform to its Users and community members. However, each one is governed by their own terms and policies. We do not exercise any control or management over these Third Party Service Provider websites. Users should display their own due diligence to read and understand each one of the legal documentation governing those products and Services.

1.3. “Personal Data” is defined as any information that relates directly or indirectly to a natural person whether living or deceased, who is identified or identifiable from that information, or from that and other information.

1.4. “User” refers to any natural or legal person accessing and creating an Account on the Zenit Platform according to applicable terms and conditions, using any kind of technological device that allows reading, listening, and/or watching information on the Platform and/or interacting with this information in an active or passively way.

1.5. “Platform” refers to the domain “https://zenit.world/”, its applications, and its subdomains. Any kind of redirection link to any kind of website and or platform control by Third Party Partner Websites is not covered by this Policy, therefore you agree to check the relevant privacy and cookies policy in place from the relevant Third Party Partner website.

1.6. “Cookies” refers to a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it or otherwise. For further details on cookies, please visit All About Cookies. This Policy may be made available in several languages; all versions are legally binding, but in the event of inconsistency between the English version and a translated version, the English version prevails.

1. Purpose of the Policy

2.1. We at Zenit know and understand how important it is for you to understand how we collect, store, process, share, and use your Personal Data. We respect and protect the privacy of our Users’ Personal Data in our Platform.

2.2. The purpose of this Policy is to describe how we collect, process, and manage Users’ Personal Data through the Platform, which is developed to offer our Services.

1. Acceptance

3.1. By accessing and using our Platform, you are consenting and accepting the terms of this Policy, the Terms and Conditions of the Service, and any other supplementing documentation provided related to the present document. If you do not agree or consent to receive our cookies, then this may in some cases preclude you from using the Zenit Platform, or Services, or negatively affect the display or function thereof.

3.2. In any case, Zenit will not hold any responsibility for any errors, bugs, or malfunctions on the Platform regarding the information displayed and/or its functions, caused by your lack of consent to receive our cookies.

1. User Login Credential Information

4.1. Users understand and acknowledge that when they access specific Services provided by Third-Party Service Providers through the Zenit Platform, they shall be subject to the individual privacy policy of each respective Third Party Service Provider. The privacy practices, data collection, processing, and usage of information by the Third Party Service Providers are governed solely by their own privacy policies. Zenit does not have any discretion or control over the privacy practices of the Third Party Service Providers.

4.2. Users grant Zenit permission to use their data and information as required to create and maintain an Account on the Platform. This information includes name, email address, contact details, and any other relevant information as specifically detailed in clause 5, required for Account registration and management. Zenit may share your Personal Data with third parties, as detailed described in clause 7.

4.3. Users acknowledge that Zenit will use the provided Personal Data to generate login credentials, such as username and password, for accessing the Platform. These login credentials will enable Users to access the various Services provided by Third Party Service Providers through the Platform.

1. Personal Information of the Users That We Collect and Process

5.1. Your Personal Data is collected, processed, and stored with us in order to provide, develop, and enhance our products and Services including technical infrastructure, security, compliance, fraud prevention, and customer support, as well as to comply with our legal obligations. We are committed to exercising due diligence when dealing with every User and in the course of conducting business, we ensure that it is able to comply with all the applicable laws and regulations that are required to prevent the facilitation of money laundering and terrorist financing.

5.2. Users’ Personal Data we collect and process is as follows:

Users’ Personal Information	Browser Information	Log Information
Full name	IP address	Device specific information
Date of birth	Login information	Location
Email address	Email address	System activity
Gender	Browser type and version	Uniform Resource Locator (URL)
Residence address	Time zone setting	Data collected via cookies
Nationality	Platform
Country code	Operating system
Contact number	Transaction history
Occupation and Employment Status	Pages accessed and links clicked
Referral activities on our Third Party Service Provider Websites

Financial Information
Source of wealth
Credit card details
Bank account details, including institution name, branch, account name, bank identifier
Bank account number or IBAN
Passport or National ID details
Wallet address

5.3 We obtain this information in a number of ways through Your use of our Platform, including through any of our websites, account opening applications, contact forms, telephone, internet chat systems, our practice account sign up forms, webinar sign up forms and information provided in the course of ongoing client service correspondence. We may also collect information about you from third parties either through customer due diligence providers, sanctions screening providers, credit reference agencies, publicly available sources or screened third party data lists.

5.4 We also keep records of your trading behaviour, including a record of suspicious transactions and orders, your preference for certain types of products and services, your financial transactions, the products you trade with us and their performance, historical data about the trades you have made including the amounts deposited. We will use your information to provide you with products and services, or information about our products and services, and continuously review your ongoing needs once you open an Account with us or subscribe to information resources on our sites or applications (e.g. blogs, newsletters etc.).

5.5 We also collect, use and share statistical or demographic data for many purposes (“Aggregated Data”). Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity and will be anonymised. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. Where we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with the law and this Policy.

1. How Users’ Personal Data is Used

6.1. To communicate with the User;

6.2. To comply with legal and regulatory requirements;

6.3. To detect and prevent fraud and credit risks;

6.4. To provide, troubleshoot, and improve Zenit Services;

6.5. To enforce our terms laid out in our Terms and Conditions;

6.6. To provide customer Services;

6.7. To ensure quality control;

6.8. To ensure network and information security;

6.9. To enhance and personalize User experience;

6.10. To facilitate corporate acquisitions, mergers, or transactions;

6.11. To engage in marketing activities;

6.12. For Transaction Services;

6.13. Purposes for which we seek Users’ consent;

1. Personal Data Storage and Transfer

7.1. Personal Data is collected from wherever the User is located. We primarily store on our servers, and we may share the Personal Data with specific third parties, which include Third Party Service Providers in accordance with our Terms and Conditions. Such sharing of data becomes essential for the effective delivery of our Services or in instances where a legal basis mandates such sharing. The aforementioned third parties are authorized to collect, utilize, and disclose your information as instructed by us. This ensures that the services provided are comprehensive and aligned with our standards.

7.2. Your Personal Data may be subject to transfers between integrated Third Party Service Provider Platforms based on the need to provide efficiency and better user experience to our community members. Your continued engagement with our Services signifies your acknowledgment and acceptance of this data transfer mechanism.

7.3. The data we may share with our Third Party Service Providers include:

7.3.1. KYC Country;

7.3.2. KYC Status;

7.3.3. Date of Zenit Account registration;

7.3.4. Wallet address details (chain, address, date of connecting).

7.4. We further ensure that we comply with the applicable data protection regulations and we shall share information in the following circumstances:

7.4.1. With competent legal or regulatory authorities. We are subject to various legal obligations and might be required to report or disclose your Personal Data when law or competent authorities require us to do so. The scope of the Personal Data disclosed depends on the authority’s request or the scope stipulated in the law. Such events include, but are not limited to, events of suspicious activities or transactions such as any fraud, tax, money laundering or terrorist financing activities. In certain cases, Zenit may be required to process your Personal Data for the purposes of pursuing, defending or assisting in any claim, litigation or other proceedings related to you and such data might be disclosed to lawyers, courts or other administrative bodies.

7.4.2. With third-party KYC/AML service providers of Zenit to perform verification Services in the User onboarding process and in the ongoing transaction monitoring process. Zenit acquires the User’s information via Third Party Partners who conduct KYC/AML on behalf of Zenit.

7.4.3. With service providers under contracts for operational purposes, for instance;

7.4.3.1. Cloud storage;

7.4.3.2. Payment processing;

7.4.3.3. Transaction monitoring;

7.4.3.4. Network infrastructure;

7.4.3.5. Security;

7.4.3.6. Customer support;

7.4.3.7. Marketing;

7.4.3.8. Data analytics.

7.4.4. With our affiliates or business partners as a general part of conducting business to offer, and improve, our Services.

7.4.5. With financial institutions which we partner with to process payments you have authorized.

7.4.6. We transfer only the minimum amount of data necessary to a particular outsourced service provider(s) and we only cooperate with the outsourced service providers who can provide and ensure adequate level of Personal Data protection.

7.5. Insofar as is reasonably practicable, Zenit shall ensure that the service providers and affiliates or business partners who process Personal Data on behalf of our Users, acknowledge the confidentiality of your Personal Data and protect your right to privacy by complying with all applicable privacy and data protection laws.

7.6. Each Third Party Service Provider website may have its own data transfer policies, terms of use, and privacy policies governing how your information is handled, processed, and shared. By continuing to use our Platform you acknowledge and agree to adhere to the data transfer policies of those Third Party Service Providers and consent to the processing and transfer of your information outside of your country of residence as described in this policy. Additionally, you understand that the local data protection regulation may not offer the same extent of coverage or protection as the laws prevailing in your country of residence.

7.7. Zenit is not liable for any disparities in eligibility criteria among Third Party Service Providers. Users are encouraged to directly contact the relevant Third Party Service Provider for clarifications on their access policies. User’s access to any Third Party Service Provider through our Platform is contingent upon the User’s compliance with the respective Third Party Service Provider’s applicable terms, conditions, laws and regulations.

1. Protection of Personal Data

8.1. Zenit maintains physical, technical, administrative, and procedural safeguards in connection with the collection, storage, and disclosure of User’s Personal Data. We use firewall barriers, encryption techniques, and authentication procedures to maintain the security of User’s online sessions.

8.2. In the event of a User signing in his/her account on different devices, Zenit shall notify a security alert to confirm and ensure the protection of the User’s account.

8.3. You are requested to protect your account password from unauthorized access to avoid unnecessary authentication issues. To circumvent loss, misuse, unauthorized acquisition, or alteration of your data, also you are further requested to choose the strongest password and to protect the account privacy data from any third parties. In the event of unauthorized access, we insist you notify our customer support immediately.

8.4. Furthermore, Zenit does not ensure the security or privacy of data transmitted via email, phone or SMS, till such data reaches the domain of our network, since we have no access to protect such data until it reaches our network domain.

1. Data Retention

9.1. We are responsible for retaining either the original or a precise copy of all data and information acquired from its Users. This retention will be in a format that is readily accessible for a five (5) year period following the conclusion of your involvement with our services, as well as those offered by our Third Party Service Provider Websites on which our services are engaged. Any Personal Data provided by you will be securely maintained by us throughout the retention period. Variation in this period of retention might change based on the type of interaction of each User with the platform, products and services, and compliance with requirements from governmental authorities.

9.2. We shall take reasonable measures to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required to provide our services for which it was processed and in certain circumstances, if required by law, we may not destroy any relevant records or Personal Data even though the prescribed period for retention shall have elapsed.

9.3. When an investigation into a suspicious User or a suspicious transaction has been initiated and in the event of proceeding with the investigation in respect of the User, Zenit shall not destroy any relevant records even though the prescribed period for retention shall have elapsed by the reporting authority, for the reason that we are subjected to certain anti-money laundering laws.

9.4. Furthermore, information or data collected via technical means such as cookies, web page counters, and other analytics tools is kept for a period of up to twelve months from the expiry of the Cookies Policy, as defined under Section.

1. Data Protection Law and the European Data Protection Rights

10.1. This Policy is governed by and shall be construed under the data protection laws of the Comoros Union. Additionally, the highest standard of data protection, as outlined in the General Data Protection Regulation ("GDPR"), shall also apply to the processing of Personal Data covered by this Policy.

10.2. If you are located in the European Economic Area (EEA), you will have the rights as described below under clause 11:

1. Your Rights Protected Under GDPR

11.1. Under certain circumstances, you have rights under data protection laws in relation to your Personal Data which are set out below:

11.1.1. Request access - This enables you to receive copies of the Personal Data we hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request". This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us".

11.1.2. Request erasure - This enables you to request us to delete or remove Personal Data where there is no good reason for us to continue to process it. Please note that there may be circumstances where we may be legally entitled to retain your Personal Data.

11.1.3. Request to Restrict Processing- This enables you to object to the processing of your Personal Data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.

11.1.4. Request to Object Processing - You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

11.1.5. Request to transfer - We will provide you, or a third party you have authorized, with a copy of your Personal Data in a structured, commonly used, machine-readable format in order to transfer the data at your request. Note that this right only applies to automated information, which you initially provided consent for us to use, or where we used the information to perform a contract with you.

11.1.6. Right to data rectification: This gives you the authority to request correction or amendment of your Personal Data. This right ensures that personal data is accurate, up-to-date, and complete. If you discover that your Personal Data is incorrect, incomplete, or outdated, you can exercise this right by submitting a formal request to us. We are then obligated to rectify the erroneous data without undue delay, considering the purposes of the processing. This right supports the accuracy and fairness of data processing and contributes to the overall integrity and reliability of the Personal Data collected and processed by us.

1. Use of Cookies

12.1. Whenever you visit our Platform, Zenit will send a Cookie to the device you are using to access our Platform, who may place tracking technologies on your device, browser, or the webpage you are viewing, in order to personalize your experience, understand usage patterns, provide, improve, and secure Zenit Platform. Your device automatically stores the Cookie in a file located within your browser allowing us to recognize your device upon future access. Cookies set by our operators are called “First party cookies”. Cookies set by parties other than our platforms are called “Third-party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through the website for instance such as advertising, interactive content, and analytics.

12.2. We use Cookies to:

12.2.1. Optimize your trading experience, including remembering your preferences, location, preferred language, browser and other details;

12.2.2. Authenticate your identity for security purposes;

12.2.3. Maintain our website and certain functions available on it;

12.2.4. Analyse and track the use of our Services;

12.2.5. Adjust our platform according to your trading habits and our regulatory requirements.

12.3. We use the following Cookies to operate our Platform:

12.3.1. Session Cookies are temporary and expire once you close your browser. It stores information for the time, or session when you are on our Platform;

12.3.2. Persistent Cookies encompass all Cookies that remain on your hard drive until you erase them or your browser does it. It depends on the Cookie’s expiration date. All persistent cookies have an expiration date written into their code, but their duration can vary;

12.3.3. First-Party Cookies are put on your device directly by the Platform you are visiting;

12.3.4. Third-Party Cookies are placed on your device, not by our Platform, but by a third party like an advertiser or an analytic system. Generally, Third-Party Cookies consist of tracking Cookies used to identify online behavior, understand interests, and then customize advertising for the User on other Platforms. Any information obtained from Third-Party Cookies is processed by the respective Collaborative Partners;

12.3.5. Google Analytics Cookies to measure our User’s interactions with the content on our Platform. These cookies collect information about your interactions with our Platform, such as unique visits, repeat visits, session duration, and Platform activity;

12.3.6. Facebook Pixel processes information about a User’s activity on our Platform, such as the Platform visited, Facebook identity, browser data, and more. The information processed from Facebook pixel is used to serve ads based on your interests through Facebook, as well as to measure cross-device conversions and User interactions on our Platform;

12.3.7. Essential Cookies are known as strictly necessary Cookies for you to browse our Platform and use its features, such as accessing secure areas of our Platform. These Cookies are generally First-Party Session Cookies. These cookies do not require consent from you. Essential Cookies helps to make our Platform easy to use by providing basic functions such as page navigation, language selections, authorization, and filling in forms. Our Platform will not function without these Cookies and they cannot be disabled. These Cookies do not reveal the User’s identity or collect information. They are stored on the User’s device until the browser is closed;

12.3.8. Functionality Cookies allow our Platform to remember choices you have made in the past like what language you prefer, what region you would like, or what username and password are so you can automatically log in. We use Cookies for navigation and to facilitate your access to and use of this site. These Cookies are necessary for the transmission of communications on the network or to supply Services whatever requested by you. Further, they help us to know which pages are the most and least popular and see how visitors move around the Platform;

12.3.9. Performance Cookies collect information about how you use our Platform, like which page you visited and which link you clicked on. None of this type of information can be used to identify you. The sole purpose of performance cookies is to improve our Platform functions. Analytics may collect information through log data, such as; (i) IP address, (ii) Type of browser and device, (iii) Operating system, (iv) Name of the Internet Service Provider, (v) Country information, (vi) Date and time of visit, (vii) Web page origin and exit.

12.3.10. Marketing Cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an advertisement. These Cookies can share information with other organizations or advertisers. These cookies may be set through the Platform by our advertising partners. If you do not allow these cookies, you will experience less targeted advertising. These cookies are set on your device for up to two (2) years or deleted if you erase your browser cookie data.

12.4. You reserve the right to decide whether to accept or reject Cookies from our Platform. You can exercise your Cookie rights by setting your preferences in the Cookie Consent Manager. However, you will not be able to reject the Essential Cookies and still access the Platform, as they are strictly necessary to provide you with our Services. Should you opt to decline Cookies, you retain the option to utilize our Platform; however, access to certain functionalities and areas may be limited. You can configure or modify your web browser settings to accept or reject Cookies. Exercise caution when rejecting or disabling Cookies, as it may impact the functionality of our Platform. Consequently, it is advisable not to disable Cookies.

1. Privacy Terms in Using Digital Assets and Blockchain Technology

13.1. The digital assets and/or digital tokens are recorded on a public blockchain. It is a ledger which means a chain of blocks where each block contains the recording of any data transmission. Blockchains are decentralized or third-party networks that are not controlled or operated by any Third Party Service Provider service provider affiliates or business partners of Zenit, and we have no access or authority to erase, modify, or alter any personal data that could be available in such networks.

13.2. We make no claims to ensure the protection of such data that utilizes blockchain technology, and we bear no liability for breaches of such data should they occur.

13.3. By using the Platform, you expressly acknowledge and accept that the data on the blockchain is irreversible and you consent to the permanent record of data being stored on such a blockchain.

1. Modifications

14.1. We reserve the right, at our sole discretion, to modify, amend, supplement, or replace this Policy at any time and such update details shall be indicated at the top of this page.

14.2. Our Platform Policies and Terms may be revised or updated periodically to meet the necessary requirements and standards. We encourage you to regularly visit our Platform to stay informed about any changes to these Policies and the Terms.

14.3. Your continued access to the Platform means that you agree to the updated content and to abide by the updated Policy.

1. Contact Information 15.1. In the event of any comments, questions, inquiries, or complaints regarding this Policy, the User has the right to submit questions and/or concerns, by raising a ticket via the Platform or by contacting [e-mail] [e-mail]