Welcome! This Privacy Notice explains how ZeroEx Inc. (“ZeroEx”, “Company”, “we”, “us”, or “our”) collects, uses, discloses, and otherwise processes personal information in connection with our websites, including https://www.0x.org/, https://matcha.xyz/ and other websites we own and operate that link to this Privacy Notice (collectively, the “Sites”) and the related content, platform, services, products, and other functionality offered on or through our online services (collectively, the “Services”). It does not address our privacy practices relating to ZeroEx employees and other personnel.
Please note that by virtue of the public nature of the blockchain, the holdings and transactions associated with your cryptocurrency wallet address will be publicly available and accessible to third parties. This includes, but is not limited to, your public sending address (including, but not limited to, cryptographically secure non-fungible tokens, and other blockchain based tokens), the public address of the receiver, the amount sent or received, and any other data a user has chosen to include in a given transaction. Information stored on the blockchain may not be able to be modified or deleted due to the immutable nature of the blockchain. Transactions and addresses may reveal information about the user's identity and information can potentially be correlated now or in the future by any party who chooses to do so. Please consider how privacy and transparency on the blockchain works.
We collect personal information in connection with your visits to and use of the Service. This collection includes information that you provide in connection with the Service, information from third parties, and information that is collected automatically such as through the use of cookies and other technologies.
We may collect the following personal information submitted to us by individuals through the Services:
As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual's device, browsing actions and website usage patterns automatically when visiting or interacting with our Services, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Services and any errors that may occur during the visit to our Services), analytics data (such as the electronic path taken to our Service, through our Services and when exiting our Service, as well as usage and activity on our Service) and location data (such as general geographic location based on the log data we or our third-party providers collect).
To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual's experience using our Services, as some features and offerings may not work properly or at all. Depending on an individual's device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
For more information about these practices and your choices regarding cookies, please see our Cookie Notice.
We also obtain personal information from third parties which we often combine with personal information we collect either automatically or directly from an individual.
We may receive the same categories of personal information as described above from the following third parties:
We may use personal information we collect to:
Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.
You may control your information in the following ways:
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.
Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to [email protected].
These Additional Disclosures set out information about how we use your personal data when you access our Service from the European Economic Area (“EEA”), United Kingdom ("UK"), and Switzerland. Please ensure that you have read and understood these Privacy Disclosures before you access or use the Services.
Personal Data: When we use the term “personal data” in these Privacy Disclosures, we mean information relating to an identified or identifiable natural person.
Controller: ZeroEx, Inc., a company duly incorporated and organized under the laws of United States of America, having its registered address at 575 Market St, San Francisco, CA 94105, is the “controller” responsible for the processing of personal data in connection with our Services. This means that we determine and are responsible for how your personal data is used.
We only process and retain your personal information as permitted under applicable law. For example, we will only process your information where we have established a lawful basis to do, as follows:
We are subject to a legal obligation: For any processing where we need to comply with laws and regulations related to bookkeeping, accounting, taxation and employment, for example for keeping records.
We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in this Privacy Notice, and in accordance with our legitimate business interests and applicable law. For example, if your personal information is subject to the EU GDPR or UK GDPR, the criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:
In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.
Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
International Transfers of Your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. If you are accessing our Services from the EEA, UK or Switzerland, your personal information will be processed outside of the EEA, the UK and Switzerland
In the event of such a transfer, we ensure that: (i) the personal information is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Notice.
From time to time we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our services. Most marketing messages we send will be by email. For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.
We will only send you such messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by contacting us at [email protected].
We may analyze personal data we have collected about you to create a profile of your interests and preferences to help us better understand and improve your use of the services, and so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively send product updates. We may also use personal data about you to detect and reduce fraud. The entering of personal data in our systems is optional and occurs only if consent is given to one of the purposes detailed in the Our Collection and Use of Personal Information section of the Privacy Notice; it automatically implies that ZeroEx personnel across the world, tasked with data processing, will be able to view the data, as well as to change and to update it.
You have the right to provide instructions regarding the retention, deletion and disclosure of your personal information after your death. In the absence of instructions from you, it is possible for your heirs to request the disclosure or deletion of your personal information.
You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner's Office and the Swiss Federal Data Protection and Information Commissioner If you wish to exercise one of these rights, we kindly ask you to contact us at [email protected]. Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.
Our Services use cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users of our Services. This helps us to provide you with a good experience when you browse our Services and also allows us to monitor and analyse how you use and interact with our Services so that we can continue to improve our Services. It also helps us and our partners to determine products and services that may be of interest to you. Please see our Cookie Notice for more information about these practices and your choices regarding cookies.
Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you. Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client - these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default. Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.
Personal data will be processed with IT-based tools and/or processed manually for the length of time needed to achieve the purpose for which it was collected. In particular, personal data collected for the purposes outline in the Our Collection and Use of Personal Information section of the Privacy Notice will be also processed with the usage of automated mechanisms based on procedures and logics that are strictly related to the purposes specified.
Unless otherwise expressly stated, terms in this notice have the same meaning as defined in the Privacy Notice.
This Cookie Notice supplements the information contained in the Privacy Notice and explains how we and our business partners and service providers use cookies and related technologies in the course of managing and providing our online services and our electronic communication to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.
In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information, please review the Privacy Notice.
As is common practice among websites, our Services use cookies, which are tiny files downloaded to your device that allow us and our third-party partners to collect certain information about your interactions with our email communications, websites and other online services, and that improve your experience. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, `“cookies”`).
We use the following types of cookies:
We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications and Services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. Our emails may also contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. We may also collect analytics data or use third-party analytics tools to help us measure usage and activity trends for our online services and better understand our customer base. We also may collect location data, including general geographic location based on IP address or more precise location data when a user accesses our online services through a mobile device.
When you access our Services from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device's location by analyzing other information, like an IP address.
We may also include or engage in the following as part of our Services:
You can learn more about our analytics providers' practices at the following URLs:
We use cookies for a variety of reasons outlined below:
Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in our Privacy Notice.
If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.
Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Online Ads: To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance's (DAA) resources and/or the Network Advertising Initiative's (NAI) online resources, at https://www.aboutads.info/choices, orhttps://www.networkadvertising.org/choices/, or if you are in the European Economic Area, United Kingdom or Switzerland:https://youronlinechoices.eu/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties' opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA's Principles.
If you are located in the EEA, UK, or Switzerland, you may take advantage of Your Online Choices. This service allows you to select tracking preferences for most of the advertising tools. As such, it is recommended that you make use of this resource in addition to the information provided in this document.