ZERϴ NETWORK: PRIVACY POLICY

Last Updated: November 12, 2024

Zero Network Foundation (hereafter “Foundation”, "we", "us", "our") respects your privacy and takes all necessary measures to protect the personal data of those who are interacting with Zero Network, a layer-2 protocol based at the ZkSync stack and scales Ethereum (“ZERϴ”, “ZERϴ Network”, or “Network”), as well as accessing content related to ZERϴ and functionality through websites located at https://explorer.zero.network/, which includes https://bridge.zero.network/bridge, https://docs.zero.network/ (each, a “Website” and collectively, the “Websites”).

This privacy policy (“Privacy Policy”) applies to all Personal Data (defined below) collected through the Websites as well as marketing campaigns, and product feedback forms (collectively, the “Services“). We collect and use your Personal Data in accordance with this Privacy Policy and in compliance with applicable data protection legislation, including but not limited to the Cayman Islands Data Protection Act (as amended), EU General Data Protection Regulation ((EU) 2016/679) (“GDPR“), and EU Privacy and Electronic Communications Directive (2002/58/EC).

KEY TAKEAWAYS:

Foundation does not collect and store personally identifiable data, such as first name, last name, street address, or date of birth.
Foundaton collects non-identifiable public on-chain data, like transaction details, assets held in the wallet, and other information, to provide you services via the Websites.
Foundation collects non-identifiable off-chain data, such as device type, browser version, IP address, etc. This data is used to help drive production vision, not to track.

WHAT INFORMATION WE COLLECT

We want to share with you how we collect personal data when you are using our Services and advise on how you can preserve your privacy.

AUTOMATICALLY COLLECTED DATA : ‍

Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
Online activity data includes pages or screens viewed, how long you spent on a page or screen, browsing history at the Websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Usage information, such as information about how you use the Websites and interact with them, including information associated with any content you upload to the Websites or otherwise submit to us, and information you provide when you use any interactive features of the Websites.

INFORMATION YOU PROVIDE TO US

Personal information that you may be asked to provide. When you visit the Websites, you may be asked to provide the following information to us:

Wallet Information
Your public wallet address provided while connecting the wallet to the Interface.
Contact details
Email address: in case you want to connect your wallet via email address, or in case you provide your email address to our Customer Support team to resolve your request.
Information provided by you to our Customer Support team.

We don’t link your contact details with the public wallet addresses unless you provide this data together; in case it happens, we never share such data with third parties and keep it strictly confidential for you.

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INFORMATION WE COLLECT FROM OTHER SOURCES

Publicly-available Blockchain Data

We collect your publicly available blockchain (transaction details, assets held in the wallet, and other information) to reflect at the Interface actual data related to your transaction.

The nature of a public blockchain means that certain information is publicly available, including but not limited to: your wallet address; the address of a sender initiating a transaction; the address of a recipient (whether an Ethereum address or a smart contract address); the maximum amount of gas fees that the sender is willing to allocate for executing the transaction; the price the sender is willing to pay per unit of gas; the nonce (a sequential number issued by the sender’s address); the cryptographic signature generated using the sender’s private key; and any additional data needed for the transaction, such as invoking functions in a smart contract or providing arguments for those functions.

When you authorize (i.e., use a crypto wallet to “sign”) a blockchain transaction through any of the Websites, you are authorizing us to collect and use all information associated with that transaction which we will do in accordance with this Privacy Policy. Note that we are not able to control whether or how third parties use information that is stored on the blockchain, and we expressly disclaim responsibility for any such activities by third parties.

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TOOLS USED FOR AUTOMATIC DATA COLLECTION

We use a variety of techniques to automatically collect information through the Websites, including:

Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
Local storage technologies, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

For more information on these tools, please read our Cookie Policy.

HOW WE USE YOUR PERSONAL INFORMATION

To operate the Websites. We use your Personal Information to: provide, operate, maintain, secure and improve the Websites; provide information about the Websites; communicate with you about the Websites, including by sending support and administrative messages; understand your needs and interests, and personalize your experience; and respond to your requests, questions and feedback and to provide support. We use this information to perform our obligations to you or when it is in our legitimate business interests to do so.
For research and development. It is in our legitimate business interests to use your Personal Information to analyze and improve the Websites and to develop new products and services, including by studying use of the Websites.
To conduct surveys. It is in our legitimate interest to conduct surveys and collect feedback from you.
Marketing and advertising. Except where consent is required, and unless you have opted out of receiving marketing communications, it is in our and our marketing partners’ legitimate interests to collect and use your Personal Information for marketing and advertising purposes.
For compliance, fraud prevention, and safety. We use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities. We use your Personal Information to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Websites; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. In these circumstances, we will process your Personal Information to either comply with a legal obligation or when it is in our legitimate business interests. Furthermore, the IP addresses may be evaluated, together with other data, in case of attacks on the network infrastructure or other unauthorized use or misuse of the Websites, for the purpose of intelligence and protection, and if appropriate, used in criminal proceedings for identification and civil and criminal proceedings against the relevant users. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR.
To create anonymous data. It is in our legitimate business interests to create anonymous data from Personal Information collected by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Websites and promote our business.

HOW WE SHARE YOUR PERSONAL INFORMATION

With the exception of the provider(s) of the Websites, we do not make your Personal Data available to third parties unless you have expressly consented to it, if we are legally obligated to, or if this is necessary to enforce our rights concerning a contractual relationship. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR.

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Service providers. We may share your Personal Information with third party companies and individuals that provide services on our behalf or help us operate the Websites (such as customer support, hosting, analytics, email delivery, marketing, identity verification, and database management services).

Web3 projects and collaborators. We may share your Personal Information with web3 projects and collaborators as necessary to provide the Websites and Services.
Professional advisors. We may disclose your Personal Information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your Personal information for compliance, fraud prevention, and safety purposes described above.
Business transfers. We may sell, transfer or otherwise share some or all our business or assets, including your Personal Information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

HOW WE PROTECT AND STORE INFORMATION

We endeavour to protect the privacy of personal data we hold in our records. However, unauthorised entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. We protect your personal data from potential security breaches by implementing specific technological security measures, including encryption, ﬁrewalls, and secure socket layer technology. We also seek to protect personal data by refraining from collecting personal data where possible. However, these measures do not guarantee that your personal data will not be accessed, disclosed, altered or destroyed by a breach of such ﬁrewalls and secure server software.

We retain your personal data only for as long as necessary to fulfil the purposes set out in this Privacy Policy. Please note that we don’t store any data related to the user for longer than five (5) years after the user erased his wallet (account). All data contained in logs is stored only for fourteen (14) days.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

You have certain rights with respect to your personal data, including those set forth below. For more information about these rights or to submit a request, please email privacy@zero.network. In some cases, we may also need you to provide us with additional information, which may include personal data, if necessary, to verify your identity and the nature of your request.

Access: You can request more information about the personal data we hold about you and request a copy of such personal data. You can also access certain of your personal data by visiting the Interfaces.
Rectiﬁcation: If you believe that any personal data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can correct some of this information directly by editing them on the Interfaces.
Erasure: You can request that we erase some or all your personal data from our systems, provided that this will not erase any personal data you have submitted to the Ethereum network.
Withdrawal of Consent: If we are processing your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time by sending your request to privacy@zero.network or accessing our Customer Support team.
Portability: You can request a copy of your personal data in a machine-readable format. You can also request that we transmit the data to another controller where it is technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your personal data for certain purposes.
Restriction of Processing: You can ask us to restrict further processing of your personal data.
Right to File Complaint: You have the right to lodge a complaint about Zero Network Foundation’s practices with respect to your personal data with the supervisory authority of your country or European Union Member State.

THIRD-PARTY LINKS AND SERVICES

The Websites may contain links to other websites, mobile applications, blockchain protocols, blockchain applications, blockchain exchanges and other online and blockchain services (collectively, “Third Party Resources”) operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included in Third Party Resources that are not associated with us. We do not control Third Party Resources, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your Personal Information. We encourage you to read the privacy policies of the Third-Party Resources you use.

TRANSFERS OF PERSONAL DATA

By using the Websites, you understand and acknowledge that we may transfer your Personal Information to service providers or other third parties who are located in countries which may not provide the same protections as the data protection laws where you are based. This includes service providers of the Websites and e-commerce providers such as payment solution providers to assist us in the processing of your online payments. When we transfer your Personal Data to third parties abroad for the purposes of the data processing described in this Privacy Policy, unless we can rely on a derogation provided under data protection law, we will ensure that relevant safeguards are in place to afford adequate protection for your Personal Information and we will comply with applicable data protection laws, in particular if you reside in the Cayman Islands, UK or the EEA by relying on a UK government adequacy regulation or adequacy decision by the European Commission, or on contractual protections for the transfer of your Personal Information. For more information about how we transfer Personal Data internationally, please contact us as set out in the “Contact us” section below.

CHILDREN'S PERSONAL DATA

The Services are intended for a general audience and are not directed at children. If we learn that we have received any information directly from a child under age 13 without ﬁrst receiving his or her parent's veriﬁed consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Websiite and subsequently, we will delete that information. If you believe we have received personal data about a child under the age of 18, please contact us at privacy@zero.network.

CHANGES TO THIS POLICY

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by means of a notice on our Website or other Interface before the change becomes effective or as otherwise required by law.

СONTACT US

Zero Network Foundation is the entity responsible for the processing of your Personal Information in connection with the Websites and Services and is the data controller in respect of such processing. If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Information, please contact us by email at privacy@zero.network.

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