Welcome to the website (the “Site”) of ZenLabs FZCO (“ZenAcademy,” “we,” “us,” or “our”).
- the categories of personal information we collect;
- why we collect an individual's personal information;
- how personal information will be used and who it will be disclosed to;
- the legal basis of our processing of personal information;
- your rights in relation to the personal information we collect; and
- your rights and interests that will be affected if you elect not to provide your personal information.
This policy was last updated: November 28, 2022.
- Membership Services means the suite of membership services that grant you access to a private ZenAcademy Discord server or another platform for educational and informative discussions about Web3 and Non-Fungible Tokens (NFT) and such other services and tools that you have access to based on your membership tier with ZenAcademy.
- Personal information means any information or an opinion about an identified or reasonably identifiable natural person.
- Sensitive information is a sub-category of personal information which includes information about an individual's racial or ethnic origin, political opinions, membership of political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record, health information, genetic or certain biometric information.
WHO ARE WE
ZenAcademy is an educational platform and community where members join to discuss Web3 and NFTs with one another. We provide content for informational purposes only to aid your NFT learning journey.
WHAT PERSONAL INFORMATION DO WE COLLECT, FOR WHAT PURPOSE AND LEGAL BASIS?
We collect information about you and your interactions with us. The types of personal information we may collect about you will depend upon the nature of our interaction with you.
Specifically, ZenAcademy may collect and process personal information for the purposes and legal basis stated below:
Personal information collected:
- Name: In order to identify and communicate with you, to enable us to provide you with the requested information, products, or services, to send support messages, technical notices, updates, security alerts, and information to you to respond to any queries or complaints you have made, to manage our promotions, competitions, and giveaways. Legal basis for processing: Consent.
- Address: In order to ship merchandise from your orders, if any. Legal basis for processing: Consent, Legitimate business purposes.
- Email addresses: To send you email newsletters to keep you up to date about our products, services, and news. Legal basis for processing: Consent.
- Discord username: To enable us to identify you and add you to the relevant ZenAcademy Discord server. Legal basis for processing: Consent, Legitimate business purposes.
- IP addresses: To manage ZenAcademy competitions, events, giveaways or prize draws. Legal basis for processing: Consent, Legitimate business purposes.
- Ethereum addresses: To determine whether you hold one of our NFTs so we may determine your membership eligibility and to provide you access to the Membership Services and perks. Legal basis for processing: Legitimate business purposes.
If you do not provide all or some of the personal information we request, we may not be able to provide our products or services to you.
We collect and record personal information about individuals such as:
- our members;
- our suppliers, potential suppliers and their representatives, directors, partners, proprietors and shareholders;
- our contractors, subcontractors, potential contractors and subcontractors and their representatives in relation to providing goods and services to us;
- our employees or contractors past and present; and
- any other person who comes into contact with us.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We may collect personal information directly from you or from a third-party. We will collect personal information from third-parties such as[b]:
- Discord Inc;
- Premint Inc;
- Substack Inc; or
- publicly available sources of information or registers.
We may collect this information when you communicate with us through the Discord server, our website, by e-mail or via third-party platforms we use. In some circumstances, the collection of personal information may be required by law.
Specifically, we may collect your personal information when[c]:
- you participate in our Membership Services, such as accessing a ZenAcademy Discord server or connecting your wallet to our website;
- when you register for our newsletter mailing lists;
- when you register for a giveaway via Discord or from one of our third-parties;
- when you purchase a ZenAcademy NFT;
- when you provide feedback to us;
- when you contact us by email, Discord or social media; and
- when we are otherwise required or authorized by law.
If the personal information we collect includes sensitive information, we will ask for your consent to collect this sensitive information, unless the law allows us to collect the information without your consent.
We may use your personal information to offer you our products and services and provide you with information we believe may be of interest to you.
When you receive electronic marketing communications from us, you may opt-out of receiving further marketing communications by following the opt-out instructions provided in the communication.
TO WHOM WE DISCLOSE PERSONAL INFORMATION
We may disclose your personal information to the following third-parties for the purposes listed above:
- to your nominated representatives;
- other organizations or individuals who assist us in providing products, events, services and programs to you or to administer our business;
- professional service providers and advisors who perform functions on our behalves, such as lawyers and accountants; and
- Government, regulatory authorities or other organizations as required or authorized by law.
We may disclose your personal information to external service providers so that they may perform services for us or on our behalf or to assist us in providing our products and services or managing our business.[d]
When we disclose personal information to third-parties, we make all reasonable efforts to ensure that we disclose only relevant information and that it is accurate, complete and up to date and that the third-party will comply with any jurisdictionally relevant Privacy Policies in relation to the use, disclosure and storage of your information.
OTHER PERMITTED DISCLOSURES
We may disclose personal information in other circumstances, where the person concerned has consented to the disclosure, or where we are expressly permitted to do so by law. These other disclosures may include where:
- you would reasonably expect the disclosure to occur;
- we are authorized or compelled by law to disclose;
- it will prevent or lessen a serious threat to someone's life, health or safety or a threat to public health or safety;
- it is necessary as part of the establishment or defense of a legal claim;
- it is requested by an enforcement agency such as the police; or
- it is a necessary part of an investigation following a complaint or incident.
OTHER USES AND DISCLOSURES
Our business operates on the internet and can be accessed anywhere with an internet connection. Therefore, ZenAcademy does not operate under traditional geographical borders. We may store and transfer personal information on servers and equipment located in countries where our service providers are located, including the United States, European Union, and United Arab Emirates.
In certain circumstances, we may need to disclose or transfer your personal information to countries outside the country in which your personal information was collected (or, in the case of personally collected within the European Economic Area ("EEA") or United Kingdom, to countries outside the EEA/United Kingdom).
Where applicable, international transfers of your personal information are protected by appropriate safeguards or undertaken in accordance with legally compliant mechanisms, such as the standard data protection model clauses adopted by the European Commission or any other supervisory authority, which we will incorporate into our agreements with such transferees of personal information.
INFORMATION COLLECTED ON OUR WEBSITE
The information generated by the cookie about your use of our website (including their IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of compiling reports on our website's activity and providing other services relating to the website and internet usage. Google may also transfer this information to third-parties where required to do so by law, or where such third-parties process the information on Google's behalf. Google will not associate a person's IP address with any other data held by Google.
You can opt-out of the collection of information via Google Analytics by downloading the Google Analytics Opt-out browser add-on here.
Our website may link to other websites which are outside our control, and other websites outside our control may link to our website. Whilst we try to ensure that we link to websites that share our privacy and security standards, once you have left our website we cannot be responsible for the protection and privacy of any information which you provide on other websites. You should exercise caution and review third-party website privacy statements.
SECURITY OF YOUR PERSONAL INFORMATION
We store information about you in computer systems and databases operated by either us or our external service providers.
We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorized access, modification or disclosure.
However, there are inherent risks in transmitting information across the internet, including the risk that information sent to or from a website may be intercepted, corrupted or modified by third-parties.
If the personal information we store is no longer required by us for any purpose for which it was collected and is no longer required by law to be retained by us, we will destroy or de-identify the personal information.
If you are a "data subject" under certain data protection laws in regions or countries, including the European Union, United Kingdom or China, you may have the following rights in relation to your personal information held by ZenAcademy:
Right to Access: you may request confirmation from ZenAcademy as to whether we process your personal data, and if so, you may request a copy of that personal data. However, it may not be possible to give you a copy of the information if it was provided anonymously or if it may lead to harm being done to another person.
Right to Rectification: you have the right to request that we rectify or update any personal information that is inaccurate, incomplete or outdated without undue delay.
Right to Erasure: you have the right to request that we erase your personal information without undue delay in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent.
Right to Restriction of Processing: you have the right to request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, for example, a request that we update your personal information.
Right to Withdraw Consent: When you have given us consent to process your personal information, you have the right to withdraw your consent.
Right to Data Portability: you have the right to request that we provide you with a copy of your personal information in a structured, commonly used and machine-readable format in certain circumstances.
ZenAcademy considers a child to be anyone under the age of 18. Our website and the Membership Services are not intended for or targeted at children under 18, and we do not knowingly or intentionally sell products or services for purchase by children or collect personal information from or about children under 18, without the consent of a parent or guardian. If you believe that we have collected personal data about a child, please contact our Privacy Officer using the below contact details.
If ZenAcademy becomes aware that personal information that we collect relates to a child without the consent of a parent or guardian, ZenAcademy will use reasonable efforts to delete that personal data from its files as soon as possible. If deletion is not possible, ZenAcademy will ensure that the personal information is not used for any purpose.
HOW CAN I MAKE A COMPLAINT?
If you have a complaint or concern about our handling of your personal information or you think your privacy has been affected, you should contact us using our contact details set out below to raise your complaint or concern.
We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
- wish to make a complaint about the way we have collected, used, held or disclosed your personal information;
- would like to opt out of receiving our newsletter or information about ZenAcademy products or services,
please contact us using the following email address:
- Email: email@example.com