PLEASE READ THIS POLICY IN ITS ENTIRETY AS THE TERMS MAY HAVE CHANGED
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Effective as of 25.05.2019

ABOUT

ZOTTO PAY LTD (ZOTTO or ZOTTO or ZOTTO PAY) is committed to protecting your company and personal information. This Privacy Policy has been written so that we can be transparent about how we collect, use and share any Personal Information. “Personal Information” is any information that can be used to personally identify you. This Privacy Policy does not cover data that has been anonymized that cannot be used to personally identify you.

We may update this Privacy Policy at any time. When a change is made to the Privacy Policy this page will be updated. You can see the date the page was last updated above. Changes to this Privacy Policy become effective immediately when posted to this page.

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of ZOTTO Service.

If you see an undefined term in this Privacy Policy (such as “ZOTTO Account” or “ZOTTO Card”), it has the same definition as in our Legal Agreement for ZOTTO Account, Merchant Agreement and User Agreement for ZOTTO Service or other legal documents regulating ZOTTO Service to all of which this Privacy Policy is inseparable part.

When this policy mentions “we,” “us,” or “our,” it refers to the respective company, proving ZOTTO Services to the Client, under the above mentioned Legal Agreements, that is responsible for your information under this Privacy Policy (the “Data Controller”).

For the purposes of this documents ZOTTO Services consist of products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by us or mobile apps, online platform, official social media platforms, or other online properties through which we provide restaurant management platform and payment services.

We give utmost importance to the protection of personal data of our customers. In the following Privacy Policy, we inform the Client about the collection, use and processing of your personal data when you apply, register or use our ZOTTO Service and all functionalities, included in the Service, including our website https://www.zottoapp.eu (hereinafter: “Website”), our Mobile App’s and our POS system.

For the purposes of providing ZOTTO Account under the Legal Agreement for ZOTTO Account with ZOTTO Ltd. the responsible Data Controller is ZOTTO Ltd, Company number 09548832, Registered office address Unit 6 Queens Yard, White Post Lane, London, England, E9 5EN. (referred to as ZOTTO):
For the purposes of providing ZOTTO Account under the Legal Agreement for ZOTTO Account the responsible Data Controller is ZOTTO Ltd;
For the purposes of providing acquiring services under the Merchant Agreement the responsible Data Controller is Zotto’s acquiring partner;
For the purposes of providing online access to payment instruments on ZOTTO Platform under the User Agreement for ZOTTO Service the responsible Data Controller is ZOTTO Ltd;

This Privacy Policy also applies to the information that is collected and used in relation to ZOTTO Online Store pursuant to Conditions of Use ZOTTO Online Store.

When you use ZOTTO Online Store for the purposes of online ordering and purchasing ZOTTO Terminals, you will be also providing your personal information, to ZOTTO Ltd;

Where one of the abovementioned entities is specified as responsible Data Controller we inform you that the other entities specified above are acting as Data Processors of the Date Controller and vice-versa. The ultimate liability lies with the respective Data Controller and you should address all your questions to the respective Data Controller via the contact details specified below.

ZOTTO Service is designed for business purposes and may be used by individuals or entities. In case you are registering for and/or using ZOTTO Services on behalf of an entity we will treat you as authorized person and you may be obliged to disclose to us personal data of the legal representatives, the employees, your customers (consumers), the agents, the beneficial owners or any other third-party related to the entity pursuant to the rules described below. You certify that where you have provided information regarding any third person besides yourself you have received prior consent from that other person to provide their personal information to us.

Not a Framework Contract: For the avoidance of doubt, this Privacy Policy does not constitute a “framework contract” for the purpose of the EU Payment Services Directive 2 (EU) 2015/2366 or any implementation of that directive in the European Union or EEA (including, without limitation any national laws implementing the EU PSD).

1. WHAT INFORMATION WE COLLECT

You are informed that there are three general categories of information that is collected from you differentiated on grounds as defined by the Regulation 2016/679 and other applicable data protection national laws.

1.1 Information That We Collect In Order To Perform Our Legal Obligations and In Order To Provide ZOTTO Service As Part Of Our Contract With You

We ask for and collect from you the following personal information when you use the ZOTTO Service.

This information is necessary for us to comply with our regulatory obligations and for the adequate performance of the contract between you and us. Without it, we may not be able to provide you effectively with ZOTTO Service for which you register.

Registration and Use of Account Information. When you sign up for ZOTTO Service, we require certain personal information such as:

First name and surname
Date of birth
Place of birth
Email address
Nationality
Registered address
Mobile telephone number
Identification document and all data from the identification document
Type of identification document
Issue date
ID number
Issuing authority

And other data which we may choose to collect in our enroll forms, which is necessary for your identification and verification.

Identity Verification Information. In accordance with our legal obligations under the relevant Anti-money laundering and anti-terrorism financing regulations, we are obliged to verify your identity or the identity of the authorized user who is opening the Account (in case of the company or other entity, referred to as “user opening the Account”).

We comply with this legal obligation by our third party partner and other procedures for verification in compliance with applicable AML laws. During the approval process, in order to fully comply with the relevant Anti-money laundering and anti-terrorism financing regulations, customers provide copy:

– photographs of the user registering for ZOTTO Service; and photographs of the principal page of your or the user opening the account’s passport or of the front and rear sides of any other official ID document.

For the same purposes you or user opening the Account you might have to provide us the digital copy of the Passport.

Tax information. In order to comply with CRS/FATCA regulations, we are required to collect your Tax Identification Number (“TIN”), Country of Tax Residence and status (active or passive business). We might be required to disclose this information to its supervising tax authorities.
Risk and Fraud related information. In order to comply with relevant Anti-money laundering and anti-terrorism financing regulations, we collect personal data regarding you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you.

For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off ZOTTO Service through partnerships, or about your experiences and interactions from our partner and networks.

Source of income, annual estimate over the account, business activity details. In order to comply with relevant Anti-money laundering and anti-terrorism financing regulations, we collect personal data regarding you related to your sources of income and any other similar financial information about you which would help us prevent money laundering and/or terrorist financing.
Log data and device information. We automatically collect log data and device information when you access and use the ZOTTO Service, even if you have not created a ZOTTO Account or logged in. That information includes, among other things: details about how you’ve used the ZOTTO Platform (including if you clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the ZOTTO Platform. We collect this information in relation to our legal obligation to provide you with secure methods of controlling your financial assets and your personal data.
Payment Transaction Information. We collect information related to your business’s payment transactions under ZOTTO Service for example when you accept card payments, we process payments executed by your business.
Sales data. Whenever a sale is performed through the Services, the date and time of the sale are recorded, along with the contents of the sale, amount paid, and any other information necessary to complete the sale.

The payment transaction information may include the payment instrument’s details used, date and time of transactions performed, amount of payment transaction and payment instrument.

This information is necessary for the adequate performance of the contract between you and us and to allow us to provide you effectively the restaurant management and payment services.

Participant information – When you use our ZOTTO Service, we collect Personal Data you provide us about the other participants associated with the transaction. Particular payment transaction information may include:

Accept Card Payments: When you accept card payments on your ZOTTO Terminal we collect payment details of the person performing the payment such as card number (PAN), issue date, expiry date, IBAN or other payment account identifier to which card is linked to, currency, amount of card transaction and other card transaction data.

1.2 Information That We Collect With Your Consent

You may choose to provide us with additional personal information in order to obtain a better user experience when using ZOTTO. This additional information will be processed based on your consent.

Address Book Contact Information. You may choose to give us access to your address book contacts or enter your contacts’ information manually to access certain features of the ZOTTO, like payment links with ZOTTO Service.
Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your ZOTTO Account, respond to surveys, participate in promotions, or use other features of the ZOTTO Service.

1.3 Information We Collect from Your Use of the ZOTTO Service.

When you use the ZOTTO Service, we may collect information, including personal information, about the services you use and how you use them. This information is necessary given our legitimate interest in being able to provide and improve the functionalities of the ZOTTO Service.

Geo-location Information. When you use certain features of the ZOTTO Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions. The legitimate interests that we pursue with this processing are the identification of location-specific problems (i.e. coverage problems for SMS-sending purposes) and other statistical information, which helps us improve our services.
Usage Information. We collect information about your interactions with ZOTTO Service such as your usage of any Apps or Functionalities and other interactions with ZOTTO Service. The legitimate interests that we pursue with this processing are the collection of crash reports and other statistical information, which helps us improve our services.
Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on ZOTTO Service, or engage others to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, ZOTTO Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted. For more information on our use of these technologies, see our Cookies Policy.

Please be advised that when you use ZOTTO Service, we automatically collect some of the personal information described in the sections above such as Geo-location Information, Log Data and Device Information, Cookies and Similar Technologies, Payment Transaction Information.

2. HOW WE USE INFORMATION WE COLLECT

We use, store, and process information, including personal information, about you to provide, understand, improve, and develop ZOTTO Service, create and maintain a secure environment, pursue our legitimate interests and comply with our legal obligations.

2.1 Providing restaurant management and payment services.

Employee data, customers profile information, acceptance of card payment, your ZOTTO account;
authenticate your access to your ZOTTO Account or your payment instrument;
communicate with you about your ZOTTO Account and payment instruments;
communicate your personal information with the third financial institution of Participants in your payment transaction;
create an account connection between your Account and a third-party account or platform, if applicable;
perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes
Detect and prevent fraud, abuse, security incidents, and other harmful activity by blocking ZOTTO Service or by applying other fraud prevention measures.
Conduct security investigations and risk assessments.
Conduct checks against databases and other information sources.
Comply with legal obligations (such as anti-money laundering regulations).
Enforce our rights, interests, and claims arising from the Legal Agreements.

We process this information given our legitimate interest in improving the ZOTTO Service and our clients’ experience with it, and where it is necessary for the adequate performance of the contract with you as well as to comply with applicable laws.

2.2. Provide, Improve, and Develop the ZOTTO Service and ZOTTO Online Store.

Enable you to access and use the ZOTTO Service.
Enable you to communicate with other clients.
Accept, process and administer online orders for ZOTTO online ordering web page;
Process purchase payments, issue invoices and or other kinds of payment documents for the processed order;
To organize the shipment of ordered ZOTTO Terminal;
To manage return procedure and refunds for defected devices.
Operate, protect, improve, and optimize the ZOTTO Service and your experience, such as by performing analytics and conducting research.
Provide customer service.
Send you service or support messages, updates, security alerts, and account notifications.
If you provide us with your contacts’ information, we may process this information: (i) to facilitate your payment transactions, (ii) process your requests, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection.
To operate, protect, improve, and optimize ZOTTO Service and experience, and personalize, customize your experience, introduce you to our other Services, we conduct profiling based on your interactions with ZOTTO Service.

We process this information given our legitimate interest in improving the ZOTTO Service, and where it is necessary for the adequate performance of the contract with you.

2.3 Create and Maintain a Secure Environment.

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
Conduct security investigations and risk assessments.
Generate one-time permission (OTP) codes for access to ZOTTO Account and for execution of payment transaction.
Verify or authenticate information or identifications provided by you.
Conduct checks against databases and other information third-party sources, including background or police checks, data providers, credit bureaus to the extent permitted by applicable laws and with your consent where required.
Monitor your payment transactions
Resolve any disputes between you and any of our clients and other users and enforce our agreements with third parties.
Enforce our legal rights.

We process this information given our legitimate interest in protecting ZOTTO Service, to measure the adequate performance of our contract with you, and to comply with applicable laws.

2.4. Provide, Personalize, Measure, and Improve our Advertising and Marketing.

Send you promotional messages, marketing, advertising, and other information related to ZOTTO Service and the products and services of unaffiliated businesses that may be of interest to you based on your preferences and social media advertising through social media platforms such as Facebook, LinkedIn or Google.
To provide personalized ZOTTO Services offered by us on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature or offer to you on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as advertising or analytics companies to provide these online services.
To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the ZOTTO Service and provide you with location-based Services, such as advertising, search results, and other personalized content.
To make it easier for you to find and connect with others, we may use your information you have shared with the Service to suggest connections between you and people you may know. For example, we may associate information that we learn about you through your and your contacts’ use of the Services, and information you and others provide to suggest people you may know or may want to transact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service.
Personalize, measure, and improve our advertising.
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or its third-party partners.
For participation in games, quizzes and completion of questionnaire or a contest entry form for promotional campaigns.
Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with ZOTTO Service, information obtained from third parties) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

We will process your personal information for the purposes listed in this section given your consent in undertaking marketing activities to offer you products or services that may be of your interest. You have the right to opt-out from processing your personal information for the purposes described above by withdrawing your consent at any time and free of charge.

3. WITH WHOM DO WE SHARE PERSONAL DATA

3.1. With other members of the ZOTTO corporate family: We may share your Personal Data with members of the ZOTTO Group of companies or within our extended family of companies that are related by common ownership or control, so that we may provide the Services you have requested or authorised or to manage the risk, or to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of ZOTTO Services and communications.

3.2. With third-party service providers: We may share personal information with third-party service providers that support us in providing ZOTTO Service, products and/or Platform with functions at our decision and our behalf.

These third-party service providers may for example:

verify your identity or authenticate your identification documents,
facilitating technically the Video Call and/or store the Video Call recording;
check information against public databases,
conduct background or police checks, fraud prevention, and risk assessment,
perform risk monitoring;
perform product development, maintenance and debugging,
allow the provision of ZOTTO Service through third-party platforms and software tools (e.g. through the integration with our APIs), or
provide customer support,
IT support and development services;
resell and distribute ZOTTO products;
provide technical support for ZOTTO products;
promote ZOTTO Service as business introducers, distributors, promoters, sales agents or similar;
perform courier services on our behalf;
provide cloud, storage or collocations services;
provide audit and accountancy services;
provide legal, compliance or other consultancy services;
Marketing and Public Relations services

These providers have limited access only to your information necessary to perform the tasks for which they were contracted for on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

3.3. With other financial and restaurant services institutions that we have contracted to enable us to provide effectively ZOTTO Service to our customers: These financial institutions may only use this information in order for us to provide you with the wider scope of payment features. Such may be:

Correspondent banks for the purposes of settling money transfers and currency exchange operations;
Domestic payment schemes for the purposes of processing domestic payments;
International payment schemes for the purposes of processing euro payments;
Restaurant management software providers
Restaurant raw material providers
Financial Institutions

3.4. With the other parties to transactions when you use ZOTTO Services, such as other Clients, merchants, and their service providers: We may share information with the other participants to your transactions, including other clients or payers/payees you are receiving funds from, and merchants or their service providers when you use the Services to pay for goods or services. The information includes:

Personal Data necessary to facilitate the transaction;
Personal Data to help other participant(s) resolve disputes and detect and prevent fraud; and

3.5. With other third parties for our legitimate interest or as permitted or required by law: We may share information about you with other parties for our legitimate interest or as permitted or required by law, including:

if we need to do so to comply with a law, legal process or regulations;
to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to us or our corporate family;
if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
to protect the vital interests of a person;
with credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes;
to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
to protect our property, Services and legal rights;
to facilitate a purchase or sale of all or part of our business;
in connection with shipping and related services for purchases made using a Service;
in relation to promoting ZOTTO Service to end users by third-party business introducers;
in relation to the distribution of ZOTTO Terminals to end-users by third-party retailers and distributors.
to help assess and manage risk and prevent fraud against us, our clients and fraud involving our websites, mobile apps or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants;
to banking partners as required by card association rules for inclusion on their list of terminated merchants;
to companies that we plan to merge with or be acquired by; and
to support our audit, compliance, and corporate governance functions.

With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connected with a third-party account or platform.

In addition, we may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why users visit your website, restaurant, and services. This data will not personally identify you or provide information about your use of ZOTTO Service. We do not share your Personal Data with third parties for their marketing purposes without your consent.

Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

3.6 Monitoring

We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer services or training purposes. When visiting our offices, CCTV, access control systems and/or other monitoring systems may be in operation.

3.7 Social Media

We may review and use public comments and opinions made on social networking sites (e.g. Facebook and Twitter) to better understand our customers and our provision and development of ZOTTO Service.

3.8 Business Transfers.

If any of the companies that provides ZOTTO Services is involved in any merger, acquisition, reorganization, sale of assets, transfer of portfolio, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred to a different legal person and/or becomes subject to a different privacy policy.

4. YOUR RIGHTS

You may exercise any of the rights described in this section before the respective Data Controller pursuant to the Legal Agreements by sending an email from your e-mail registered for ZOTTO Service to the respective Company providing the Service to you under the respective Legal Agreement stated below. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.

4.1 Managing Your Information.

You have the right to obtain the following:

confirmation of whether, and where, the we are processing your personal data;
information about the purposes of the processing;
information about the categories of data being processed;
information about the categories of recipients with whom the data may be shared;
information about the period for which the data will be stored (or the criteria used to determine that period);
information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing;
information about the existence of the right to complain to any Regulator;
where the data was not collected from you, information as to the source of the data; and information about the existence of, and an explanation of the logic involved in, any automated processing.
Additionally, you may request a copy of the personal data being processed.

4.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself via your online access to ZOTTO Account).

4.3 Data Access and Portability.

You have the right to:

receive a copy of your personal & business data in a structured, commonly used, machine-readable format that supports re-use;
transfer your personal data from one controller to another;
store your personal data for further personal use on a private device; and
have your personal data transmitted directly between controllers without hindrance.

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.

4.4 Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations. If you no longer want us to use your information to provide ZOTTO Service to you, you can request that we erase your personal information and close your ZOTTO Account, providing your account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevent us by law to close your account or terminate the Service. In case the Data Controller is a regulated financial institution, such as a credit institution, E-money institution, or similar, such Data Controller is obliged under PSD and AML laws to keep your personal information and all transaction history for a period of 5 years after the termination of the relation with you. Please note that if you request the erasure of your personal information:

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing security. For example, if we suspend an ZOTTO Account for fraud or safety reasons, we may retain certain information from that ZOTTO Account to prevent that client from opening a new ZOTTO Account in the future. We are also obliged to retain personal data which we have collected for the purposes of complying with the relevant anti-money laundering and anti-terrorism financing for a period as defined under the applicable law.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, ZOTTO may keep some of your information for tax, legal reporting and auditing obligations.
Because we maintain the ZOTTO to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

4.5 Withdrawing Consent and Restriction of Processing.

Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and pending the verification whether our legitimate grounds override your own.

4.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling for marketing purposes) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims. Please note that Data Controllers which are regulated financial institutions, such as credit institutions, E-money institutions or similar are obliged under AML laws to make risk profiling of their customers upon opening of the relationship and constantly during the relationship and this is a legitimate reason. In case you do not wish us to process your personal data for certain specific purposes, which are legitimate purposes to us, you shall have to close your account or we may have to stop providing you some or all of the Services, subject to all conditions for the closing of the account, specified above in this Section.

Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to the contact e-mails below.

4.7 Lodging Complaints.

4.7.1. You should in first place try to resolve the matter by sending an e-mail to the respective Data Controller under this Privacy Policy from your registered e-mail for the Service:

info@ZOTTO.IO

Unit 6 Queens Yard, White Post Lane, London, England, E9 5EN

4.7.2 Competent Regulator. In case you are not satisfied with the reply or resolution of the respective Data Controller, you have the right to lodge complaints about the data processing activities carried out by us before the competent data protection supervisory authorities as described below.

If the Data Controller responsible for the respective data processing, subject to your complaint, is ZOTTO Ltd. you have the right to file a complaint with its lead supervisory authority, the Information Commissioners Office, UK:

Address: Wycliffe House, Water Lane, Willmslow Cheshire, SK9 5AF, UK

Tel: +44 (0)1 625 545 745

e-mail: casework@ico.org.uk

5. OPERATING GLOBALLY

To facilitate our global operations, we may be required to transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer store and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

6. INTERNATIONAL TRANSFERS

6.1 EU-US & Swiss-US Privacy Shield.

Where we disclose any of your collected personal information outside EEA to USA (if applicable), we shall comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework and any other adequacy decision.

6.2 Other Means to Ensure an Adequate Level of Data Protection.

In case personal information is shared with corporate affiliates or third-party service providers outside the EEA in absence of an adequacy decision, we have – prior to sharing your information with such corporate affiliate or third-party service provider – established the necessary means to ensure an adequate level of data protection. We will provide further information on the means to ensure an adequate level of data protection on request.

7. SECURITY

We take the responsibility to ensure that your personal information is secure, kept in an encrypted from on servers, collocated in Special data centers in Class A jurisdictions in Europe. To prevent unauthorized access or disclosure of information we maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard non-public personal information. Once you are logged into your Account, all internet communication is secured using Secure Socket Layer (SSL) technology with High-grade security Encryption (AES-256, 256 bit keys, certified by StartCom Ltd). We restrict access to your personally identifiable information only to employees who need to know that information in order to provide products or services to you.

If you know or have reason to believe that your ZOTTO Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your ZOTTO Account, please contact us following the instructions in the Contact Us section below. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.

8. Can Children Use Our Services?

ZOTTO Service are not designed to individuals under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use ZOTTO Service. If we obtain actual knowledge that we have collected Personal Data from an individual under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under the age of 18.

9. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on ZOTTO Platform. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of ZOTTO Platform will be subject to the revised Privacy Policy.

10. CONTACT US

If you have any questions about this Privacy Policy or how we use Personal Information, please contact ZOTTO Support: support@ZOTTO.IO