Privacy Policy

Last Updated: September 01 2023

This Privacy Policy is designed to help you understand how ZEBEDEE LLC (“ZEBEDEE,” “we,” “us,” or “our”) collects, uses, processes, and shares your personal information, and to help you understand and exercise your privacy rights.

1) SCOPE AND UPDATES TO THIS PRIVACY POLICY2) PERSONAL INFORMATION WE COLLECT3) HOW WE USE YOUR PERSONAL INFORMATION4) HOW WE DISCLOSE YOUR PERSONAL INFORMATION5) YOUR PRIVACY CHOICES AND RIGHTS6) SECURITY OF YOUR INFORMATION7) INTERNATIONAL DATA TRANSFERS8) RETENTION OF PERSONAL INFORMATION9) SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS10) SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS11) CHILDREN’S INFORMATION12) OTHER PROVISIONS13) CONTACT US

1) SCOPE AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called the “Services.”

An Important Note Regarding Blockchain Technologies: If you use our Services relating to the creation, management, participation, or operation of a decentralized autonomous organization (“DAO”) or with payment channels that may be used on a blockchain protocol network, smart contracts will be employed that necessarily collect information, such as your digital wallet address (which some legal jurisdictions may consider personal information), and that information will be stored on a public blockchain that we do not control. A smart contract is computer code that automatically processes events when certain conditions are met; for example, when a transaction is conducted between two individuals where each sign off to close a payment channel (in other words, settle the accounts between individuals to be then broadcast to the blockchain), a smart contract would automatically execute the proposed action. In these situations, your personal information will be stored on that blockchain through the execution of a smart contract and may not be able to be modified or deleted due to the immutable nature of the blockchain.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

2) PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly We may collect personal information that you provide to us.

B. Personal Information Collected Automatically We may collect personal information automatically when you use our Services.

Our uses of these Technologies fall into the following general categories:

C. Personal Information Collected from Other Sources

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.

Credit Bureaus and ID Verification Partners. We may obtain personal information about you from credit bureaus and identity verification partners.

Blockchain Information. We may obtain personal information about you through our analysis of blockchain information.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

3) HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services We use your information to fulfill our contract with you and provide you with our Services, such as:

B. Administrative Purposes We use your information for various administrative purposes, such as:

C. Marketing and Advertising our Products and Services We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

D. Other Purposes We also use your personal information for other purposes as requested by you or as permitted by applicable law.

4) HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services The categories of third parties with whom we may share your personal information are described below.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5) YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

6) SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7) INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

8) RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9) SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information ZEBEDEE has collected about them, and whether ZEBEDEE disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below, split by "Category of Personal Information Collected by ZEBEDEE", listing "Category of Third Parties Personal Information is Disclosed to for a Business Purpose":

A. Identifiers:

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)):

C. Protected classification characteristics under California or federal law:

D. Commercial information:

E. Internet or other electronic network activity:

F. Sensory data:

G. Professional or employment-related information:

H. Inferences drawn from other personal information to create a profile about a consumer:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

Additional Privacy Rights for California Residents:

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, ZEBEDEE does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in Contact Us below or logging into their account and removing the content or information using our self-service tools.

10) SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

11) CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent and, wish to review information collected from your child or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

12) OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If your personal information is subject to the applicable data protection laws of Brazil, the European Economic Area, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

13) CONTACT US

ZEBEDEE is the controller of the personal information we process under this Privacy Policy. If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: ZEBEDEE LLC Attn: Information Security Committee 50 Harrison St STE 472, Hoboken, NJ 07030 support@zebedee.io