Zenvest – PRIVACY POLICY




Welcome to Zenvest. 



The security and protection of your personal data is of utmost importance at Zenko.AI SA, the Swiss Company established under Swiss laws (hereafter: “Zenvest”, “We”, “Our”, or “Us”). 



This Privacy Policy (hereinafter: the “Policy”) outlines our practices regarding the collection, use, and sharing of personal information of users (hereinafter: “You” or “User” or “Users”) while using the following Website: https://zenvestmarket.com and https://www.zenvest.app (hereinafter: the “Website”) and the associated services (the “Services”). This Privacy Policy further aims to protect the privacy and the fundamental rights of when their personal data are processed by Zenvest, such as their fundamental right while using the Website and accessing the Services. 



Zenvest uses privacy by default and privacy by design standards and undertake to store your personal data in a secured manner and to process your personal data with all appropriate care and attention in accordance with the Swiss Federal Data Protection Act, the Swiss Ordinance on Data Protection (hereinafter: “Swiss Regulations”) and the General Data Protection Regulation from the European Union (hereinafter: the “GDPR”).



  1. SCOPE



This Policy details the data processing activities specifically related to the access and/or use of the Website and its related Services. 



This Policy shall apply to any access and/or use of the Website and its related Services, whatever the method or medium used. It details the conditions at which, Zenvest may collect, keep, use and save information that relates to you, as well as the choices that you have made in relation to the collection, utilization and disclosure of your personal data.



  1. ACCEPTANCE



By using the App, Users acknowledge that Zenvest may collect and process a certain number of personal data that relate to them and that they have read and understood this Policy and agree to be bound by it and to comply with all applicable laws and regulations. Users understand and agree that Zenvest is free to use these personal data within the limit provide by law and this Policy.



Your consent is given once you tick the box in the pop-up window which appears upon your first use of the Website and which says: “I warrant that I read and understood the “Zenvest – PRIVACY POLICY” and I agree to be bound by it”.



If you do not agree with the terms of this Policy, please refrain from accessing or using the Website and its related Services.








  1. PRINCIPLES FOR PROCESSING PERSONAL DATA



While processing personal data, Zenvest will respect the following general principles:



a. Fairness and Lawfulness



When processing personal data, the individual rights of users are protected. Personal data are collected and processed lawfully, in a fair manner, in good faith and are proportionate to the objective.



b. Restriction to Specific Purpose



Personal data handled by Zenvest are adequate and relevant to the purpose for which they are collected and processed. This requires, in particular, ensuring that the types of personal data collected are not excessive for the purpose for which they are collected. Subsequent changes to the purpose are only possible to a limited extent and require substantiation.



c. Transparency



The user is informed of how his/her personal data is being handled. When the personal data is collected, the user must be informed of:



  • the existence of the present Policy;



  • the identity of the Data Protection Officer;



  • the purpose of personal data processing;



  • third-parties to whom the data might be transmitted.



d. Consent of The User



Personal data must be collected directly from the individual concerned and the consent of the user may be required before processing personal data. The consent is obtained in writing or electronically for the purposes of documentation. The consent is valid only if given voluntarily. If, for any reason, the consent of the user is not given before processing personal data, this one should be secured as soon as possible after the beginning of the processing.



Personal data can be processed without consent if it is necessary to enforce a legitimate interest of Zenvest. Legitimate interests are generally of a legal (e.g. filing, enforcing or defending against legal claims) or financial (e.g. valuation of companies) nature. The processing of personal data is also permitted if national legislation requests, requires or allows this.



e. Accuracy



Personal data kept on file must be correct and if necessary, kept up to date. Inaccurate or incomplete personal data should not be kept on file and deleted.



  1. PRIVACY BY DESIGN AND BY DEFAULT



Zenvest will, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organizational measures, such as pseudonymization, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the Processing in order to meet the requirements of Swiss Regulations and GDPR and protect your rights.



Zenvest will implement appropriate technical and organizational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed. This obligation applies to the amount of your personal data we collect, the extent of their processing, the period of storage and their accessibility. These measures will ensure that by default your personal data are not made accessible without your intervention to an indefinite number of third parties.




  1. COLLECTED DATA 



This Policy applies to all information which is received during your usage of the Website and its related Services. Users acknowledge that Zenvest may collect and process a certain number of personal data that relate to them and that they have read and understood this Policy and agree to be bound by it and to comply with all applicable laws and regulations.



When you use the Website and its related Services, Zenvest automatically: 



  • collects your cookies;

  • uses Google Analytics;

  • uses Meta Pixel;

  • uses TikTok Pixel; 

  • your IP address.


  1. USE OF DATA




The following paragraphs describe the various purposes for which Zenvest uses your personal data. Please note that not all of the uses below will be relevant to every individual. By using our App, you acknowledge and agree to the collection, storage, and utilization of this data.



Generally, the main reason why we collect personal data is to enable you to enjoy and easily use the App. 



a. Cookies Collection:



We use cookies to enhance your Zenvest experience. These small files are stored on your device to improve site functionality and offer a more personalized experience. You have the option to accept or decline cookies. By using the Website and its related Services, you consent to the use of cookies as described in our Cookies Policy www.Zenvest/cookies .



b. Use of Google Analytics



Our Website uses Google Analytics to gather information about how users engage with our Website. This includes details about your visit, such as the pages you view, the time spent on each page, the links you click, and other actions you take while on our App. Google Analytics may collect information such as your IP address, browser type, and operating system. This information is used to analyze user behavior and improve our services. Google Analytics operates independently and may have its own privacy policy, which we encourage you to review.



c. Meta Pixel



Our Website uses Meta pixels, which enables us to track user activity and conversions from Meta applications, ads, optimize ad targeting, and create custom audiences. The information collected is used in accordance with Meta's data usage policy.



d. TikTok Pixel



Similarly, our Website uses TikTok pixels to track user activity from TikTok, aiding in measuring ad performance and enabling targeted advertising. The data collected via TikTok pixels is subject to TikTok's privacy policy.



e. IP Addresses



We may collect your IP address for various purposes, including but not limited to analyzing and managing our App's usage, diagnosing server issues, and preventing fraudulent activity.



e. Record of Correspondences



We may record and store communications, such as emails or messages exchanged, for purposes such as quality assurance, customer service, and record-keeping.




  1. THIRD PARTY DISCLOSURE



Zenvest may share your personal data to any other relevant third parties, in particular if we are requested to do so to comply with a court order or law enforcement authorities request, or if we find it necessary, as determined in Zenvest’s sole discretion, to investigate, prevent or take action regarding illegal activities, to defend our interest or as otherwise required or permitted by law.



Zenvest ensures that an adequate protection is guaranteed for personal data to be transferred outside of Switzerland and the European Union (hereinafter: the “EU”). In some specific cases when this level of protection is not guaranteed, Zenvest will obtain your prior consent or establish with the recipient of personal data a contractual framework or sufficient safeguards that ensure an adequate level of protection abroad. You may request access to a copy of these safeguards by contacting Zenvest.



Unless otherwise stated, the third parties who receive data from Zenvest are prohibited to use this personal data beyond what is necessary to provide the product or service to you, directly or by participating to Zenvest’s activities.




  1. STORAGE OF YOUR PERSONAL DATA



In principle, your personal data will be stored in Europe. You agree that Zenvest may store your personal data in any country of the EEA, including Switzerland. 



The storage as well as the processing of your personal data may require that your personal data are ultimately transferred/transmitted to, and/or stored at, a destination outside of your country of residence, notably Switzerland. Where permitted by law, by accepting the terms of this Policy, you agree to such transferring, transmission, storing and/or processing. You also agree that such activities may take place to or in countries offering a lower level of protection than your country of residence.




  1. RETENTION OF YOUR PERSONAL DATA



In accordance with applicable laws, Zenvest will use your personal data for as long as necessary to satisfy the purposes for which your personal data was collected or to comply with applicable legal requirements.




  1. SECURITY OF YOUR PERSONAL DATA



We take data security seriously and employ industry-standard measures to protect your information, including data encryption, access controls, and blockchain technology. However, no method of transmission over the internet or electronic storage is completely secure. Therefore, while we make every effort to protect your data, we cannot guarantee absolute security.



In the event of a personal data breach, Zenvest shall without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the breach to the competent supervisory authority, unless said breach is unlikely to result in a risk to your rights and freedoms. If the breach is likely to result in a high risk to your rights and freedoms, Zenvest shall communicate this breach to you, if it is feasible, without undue delay.




  1. ACCESS TO YOUR DATA AND INFORMATION RIGHTS



You have the right to request access to or information about the personal data relating to you which are processed by Zenvest. 



Where provided by law, you, your successors, representatives and/or proxies may (i) request deletion, correction or revision of your personal data; (ii) oppose the data processing; (iii) limit the use and disclosure of your personal data; and (iv) revoke consent to any of our data processing activities, if Zenvest is relying on your consent and does not have another legal basis to continue processing your data.



These rights can be exercised by contacting us through our contact form or writing to us at: legal@Zenvest attaching a copy of your ID. If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected. The request is free of charge unless your request is unfounded or excessive (e.g. if you have already requested such personal data multiple times in the last twelve months or if the request generates an extremely high workload). In such case, Zenvest may charge you a reasonable request fee according to applicable laws.



Zenvest may refuse, restrict or defer the provision of personal data where it has the right to do so, for example if fulfilling the request will adversely affect the rights and freedoms of others.



  1. PORTABILITY OF YOUR DATA



You also have the right to receive your personal data, which you have provided to Zenvest with, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Zenvest.



This right can be exercised by contacting us through our contact form or writing to us at: support@zenvest.app, attaching a copy of your ID. If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected.



The request is free of charge unless your request is unfounded or excessive (e.g. if you have already requested such personal data multiple times in the last twelve months or if the request generates an extremely high workload). In such case, Zenvest may charge you a reasonable request fee according to applicable laws.



Zenvest may refuse, restrict or defer the provision of personal data where it has the right to do so, for example if fulfilling the request will adversely affect the rights and freedoms of others.




  1. CONTACTING ZENVEST AND COMPLAINTS



Zenvest hopes to be able to answer any questions or concerns you have about your personal data. You have the right to make a complaint if you feel your personal data has been mishandled or if Zenvest has failed to meet your expectations. You are encouraged to contact Zenvest about any complaints or concerns, but you are entitled to complain directly to the relevant supervisory authority.




  1. CHANGES TO THE PRIVACY POLICY



Zenvest may modify this Policy from time to time and will post the most current version on the Website. If a modification reduces your rights, it will inform you immediately when you will use our Zenvest, and you will have to accept the changes.




  1. LEGAL DEPARTMENT AND DATA PROTECTION OFFICER



Legal department is responsible for ensuring compliance with the applicable provisions on data protection. If you have concerns regarding data protection, you may send them to us at the following address:



Zenvest SA, rue des Prés 33, 2017 Boudry, Switzerland, rue des Prés 33, 2017 Boudry, Switzerland ; legal@zenko.ai.



At European level, the Date Protection Officer responsible for ensuring compliance with GDPR is: 



compliance@zenko.ai.



Svjetlana Dragicevic.



  1. LINKS



The App may contain links which direct you to third party websites. Zenvest rejects any liability relating to the privacy policy in force on said third party sites, the collection and use of your Personal data by the latter and relating to the contents of said sites (whether the links are hypertext links or deep-links).



Furthermore, the Data subject acknowledge and agree that using Website and its related Services could imply to download others applications or using other websites. Under no circumstances Zenvest shall be liable for the utilization of others applications or website, especially regarding to the Data protection rules.




  1. JURISDICTION AND GOVERNING LAW



This Policy and any questions relating thereto shall be governed by the laws of Switzerland, to the exclusion of any rules of conflict resulting from private international law.



Any dispute relating to this Policy must exclusively be brought before the courts of Neuchâtel, Switzerland, subject to an appeal to the Swiss Federal Court.




  1. CONTACT



To ask questions or make comments on this Policy or to make a complaint about our compliance with applicable privacy laws, please contact us through:



a. our contact form available on our website: www.zenvestmarket.com

b. our email address: legal@Zenvest.ai; or

c. our address: Zenvest.AI SA, rue des Prés 33, 2017 Boudry, Switzerland.



We will acknowledge and investigate any complaint pursuant to this Policy.