Privacy Policy

Last Updated: July 15, 2019

At Zooch, we pride ourselves on our commitment to protecting your privacy. This Privacy Policy describes in greater detail the privacy practices of Freedom Stack Limited and its affiliates and subsidiaries, meaning companies related by common ownership or control (“Zooch,” “us,” “we,” “our”) responsible for collecting and maintaining certain information collected about you.

If you have questions or complaints regarding our Privacy Policy or practices, please contact us as detailed under the "How to Contact Us" heading below.

1. WHEN THIS PRIVACY POLICY APPLIES. This Privacy Applies to all Services that we provide to you (including via the Zooch Mobile App, Zooch.com and Freedomstack.com).

This Privacy Policy (“Privacy Policy”) applies to our sites, products, and services (collectively, "Services") that link to this Privacy Policy. Freedom Stack Limited is the responsible entity for all Personal Information (as such term is defined in Section 2.a below) subject to this Privacy Policy.

2. WHAT WE DO WITH YOUR INFORMATION. We want to be clear about what information we collect and how we use it to deliver our Services to you, operate our business, and help make our Services useful, more intelligent, and work better for you. We do not sell or share your Personal Information with third parties for their own commercial uses without your consent.

a) Types of Information We Collect. In connection with accessing our Services, we may collect information from you which can be used to identify you ("Personal Information"), such as your name, shipping/billing address, email address, phone, username and password.We may request copies of your identification (including, without limitation, your passport) and proof of residence such as utility bills.

We may collect information when you interact with our Services, including, without limitation, when you register or open an account, sign in, initiate a trade, purchase a Service, call us for support, or give us feedback. We may also get information from other companies or third parties, such as when you sync or configure a third party account or service with our Services, or when we may use service providers to supplement the Personal Information you give us (e.g., validate your mailing address) to help us maintain the accuracy of your data and provide you with better service. Finally, we also collect content or other information that you may provide or create when you interact with our Services.

We may also automatically collect certain usage information when you access or use our Services ("Usage Data"), including, without limitation, Internet Protocol (“IP”) addresses, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, and other usage information collected from cookies and other tracking technologies (as further set forth below). For example, we collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate to our Services. We also collect IP addresses from users when they log into the Services as part of our log-in and security features. We may also, when you enable location-based Services (if any), collect Global Positioning System (GPS) location data and/or motion data.

Our Services may change over time and we may introduce new features that may collect new or different types of information.

b) How We Use Your Information. Unless prohibited by law, regulation, or a contractual obligation, we may use your information, including your Personal Information, for the following purposes: 

Account Registration . We may use your name, address, phone number, and email address to register your Zooch Account for certain Services we provide and to communicate important information to you. We may obtain additional Personal Information about you, such as address change information, from commercially-available sources, to keep our records current. If you set up an administrator account that may be accessed by people other than you, please note that they may see and have the ability to change or delete your Personal Information.

Communicate with You and Tell You About Other Services . We may use your information to communicate with you about our Services and to give you offers for third party products and services that we think may be of use to you. Please see below under "What You Can Do to Manage Your Privacy" for the choices you have regarding these communications.

To Improve Services and Develop New Services . We will use your information to personalize or customize your experience and the Service, develop new features or services, and to improve the overall quality of Zooch's Services. 

To Provide Our Services and Operate Our Business . We may use your information to operate our business, including providing Services that you requested, provide you with support related to our Services, and to help us protect our Services, including to combat fraud and protect your information and the information of other users.

Customer Service and Technical Support . We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer or mobile device configuration to resolve questions you may have about our Services and to follow up with you about your experience. We may also offer various Internet chat services, for example, to speak with a Zooch support representative. Internet Chat transmissions are encrypted but you should not supply more Personal Information, including financial data, than is required to address your specific issue. A transcript of the session is retained to resolve questions or issues related to our Services.

Feedback . We may use any information you volunteer in surveys you answer for us and combine them with answers from other customers in order to better understand our Services and how we may improve them. Answering any survey is optional.

Research, Including Publishing or Sharing Combined Information from Many Users, But Only in a Way that Would Not Allow You or Any Other Person to be Identified . Only in a way that would not allow you or any other person to be identified, we may prepare and share information about our customers with third parties (including other customers) for commercial and non-commercial purposes, such as advertisers or partners, including, without limitation, for research, academic, trading strategy, testing, marketing and/or promotional purposes. For example, (i) we may share demographic data that describes the percentage of our customers who use mobile services or who use a particular operating system, and (ii) we may share usage data and trading data (including trading trends and strategies) with other customers or third-party partners. We or our third-party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow you or any other person to be identified.

c) Zooch Single Sign-On (Zooch Account). Zooch Single Sign-on is a Service that allows you to sign-in to a variety of Zooch Services with a single Zooch Account. We will collect certain information for security purposes in order to verify your authorized access to an account or to reset your password if you cannot access your Zooch account. Some Services may require added security and you may be asked to provide additional information. The email address and password that you use to sign up for a Zooch account are your "credentials" that you will use to authenticate with our network. We assign a unique ID number to your credentials to track you and your associated information. Zooch Services do not allow sharing of accounts between users or individuals.

d) How We Share Your Personal Information. From time to time, we may need to share your Personal Information with others. 

Third Party Service Providers . We may share your information, including Personal Information and Usage Data, with third party service providers (including MixPanel) who perform various functions to enable us to provide our Services and help us operate our business, including, without limitation, website design, sending email communications, fraud detection and prevention, customer care, performing analytics (including with respect to usage and trading data), or formulating and providing trading strategies. Our contracts with these third parties require them to maintain the confidentiality of the Personal Information we provide to them, only act on our behalf and under our instructions, and not use Personal Information for purposes other than the product or service they're providing to us or on our behalf.

Response to Subpoenas and Other Legal Requests . We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we're required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.

Protection of Zooch and Others . We may share account information, Personal Information and Usage Data when we believe it is appropriate to enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Zooch, our Services, our users, or others. This includes, without limitation, exchanging information with other companies and organizations for fraud protection and credit risk reduction; provided, however, that this does not include selling, renting, sharing, or otherwise disclosing Personal Information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.

Reporting to Credit Bureaus . We may share your information with credit bureaus, consumer reporting agencies, and card associations. Late payments, missed payments, or other defaults on your account may be reflected in your credit report and consumer report. We may also share your information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.

Information Sharing Between Zooch Entities . We may share your information, including your Personal Information, with and among our affiliates and subsidiaries, except where prohibited by law, regulation, or a contractual obligation. The protections provided in this Privacy Policy apply across all Zooch entities. Affiliates and subsidiaries mean companies related by common ownership or control. The reasons why we may share your information include for our everyday business purposes, such as to: process your transactions, maintain your accounts, operate our business, facilitate Zooch Single Sign On to your Zooch Account, etc. We will also share your information in order for us to be able to offer our products and services to you. We may also share information about your creditworthiness, your transactions and experience so that we can operate our business effectively, detect and prevent fraud, and improve our Services.

Sale of Our Business . If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you'd like to stop receiving promotional information following any such transfer.

With your Consent . Other than as set out above, we will provide you with notice and the opportunity to choose when your Personal Information may be shared with other third parties.

e) Syncing, Linking, Connecting Your Third-Party Accounts or Other Third-Party Services with Your Zooch Service.

You may choose to sync certain Zooch Services with information from other accounts you maintain (including, without limitation, financial brokerages and crypto currency exchanges). To sync your account information, we need to access your online account(s) with the provider of such account(s). We will request your user name, password, and any other login data that you have set up with such third-party provider(s) to enable access. We use this information to update and maintain the account information you download or connect, to assist with the download or connection process, and to enhance the Services that we may provide in the future.

We work with other companies or developers to offer you products and services and you may choose to sync, link or connect other third party services with your Zooch Service. Sometimes Zooch may let you know about the service or product, or another company may let you know about a Zooch service or product. It will be clear who is referring the service or product, and who is providing the service or product. If you choose to accept these services, providing your consent to either the third party or to us, we may exchange your information, including your Personal Information, as well as information about how you interact with each company's service or product. This exchange of information is necessary to maintain business operations and to provide the ongoing service you've requested. By requesting or accepting these products or services, you are permitting us to provide your information, including your Personal Information, to the other party.

3. WHAT YOU CAN DO TO MANAGE YOUR PRIVACY. You can view and edit information that identifies you online through your Zooch Service. How you can access and control information that identifies you will depend on which Services you use.

a) Managing Marketing Communications From Us. We will honor your choices when it comes to receiving marketing communications from us. 

You have the following choices if you have been receiving marketing communications from us that you no longer wish to receive:

b) Updating Your Personal Information. In connection with your right to manage your Personal Information you provide to us, you may access, update, change, correct or request deletion of your information either through the Service or through our customer support. You can reach our customer support by using the contact information provided in the "How to Contact Us" section of this Privacy Policy.

c) Cookies and Similar Tracking Technologies. The following is a high-level summary of our practices and your controls for cookies and other tracking technologies.

In accordance with applicable law, Zooch and our service providers may use commonly-used tools to recognize your visit and track your interactions with our Services such as cookies, web beacons, pixels, local shared objects, and similar technologies (collectively, "Cookies"). Sometimes this tracking is necessary in order for us to provide you the Service you requested. Other times, we combine Usage Data collected from Cookies with that of other customers to improve your and other customers' experience. You have control over some of the Usage Data we collect from Cookies and how we use it. Information on changing your browser settings to opt out of Cookies can be found in your browser settings. 

d) Do not Track. Like most other companies, our Services are not currently configured to respond to browsers' "Do Not Track" signals because at this time no formal "Do Not Track" standard has been adopted. Click here for more information on "Do Not Track."

e) Social Media Features. Many of our Services may use social media features, such as Facebook sharing ("Social Media Features"). These features may collect your IP address and which page you are visiting within our Service, and may set a cookie to enable the feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the Privacy Policy of the company providing the relevant Social Media Features.

4. DATA RETENTION AND YOUR ACCESS RIGHTS

a) Data Retention. In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable regulations and Zooch's records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud. 

b) Your Access Rights.

5. SECURITY OF YOUR INFORMATION. Keeping your Information safe is important to us.

We provide reasonable and appropriate security measures in connection with securing Personal Information we collect.

For example, we:

6. INTERNATIONAL DATA TRANSFERS.

In accordance with and as permitted by applicable law and regulations, we reserve the right to transfer your information, process and store it outside your country of residence to wherever we or our third-party service providers operate.

7. HOW TO CONTACT US. If you have questions or comments about this Privacy Policy, please contact us. We want your feedback and comments.

a) Via Email. If you have questions or complaints regarding our Privacy Policy or practices, please contact us by email at support@freedomstack.com.

b) Via Direct Mail. Freedom Stack Limited, Attention: Privacy, Global Gateway 8, Rue de la Perle, Providence, Mahe, Seychelles.

8. CHANGES TO OUR PRIVACY POLICY. From time to time we may change or update our Privacy Policy. We reserve the right to make changes or updates at any time. More information about how we will notify you is below.

If we make material changes to the way we process your Personal Information, we will provide you notice via our Service or by other communication channels, such as by email or community post. Please review any changes carefully. If you object to any of the changes and no longer wish to use our Services, you may close your account(s). All changes are effective immediately upon posting and your use of our Service after a notice of material change or posting of an updated Privacy Policy shall constitute your consent to all changes.

9. COLLECTION AND USE OF CHILDREN'S PERSONAL INFORMATION. We do not knowingly collect information from minors.

Zooch’s Services are intended for and directed to adults. Our Services are not directed to minors and we do not knowingly collect Personal Information from minors .

10. YOUR CALIFORNIA PRIVACY RIGHTS.

We do not share your Personal Information with third parties for their marketing purposes without your consent.

11. MOBILE APPS.

If you use location-enabled Services, we will be collecting location information and other technical information from your devices. We only collect this data with your consent. Depending on the Service you use, we may also collect other information about your mobile phone, such as the type of your phone, your carrier, and other data such as software version so that we can improve our Services. By necessity, your requests/messages from your mobile devices may go through your/our mobile carrier's network. This means that your carrier may have access to your requests and messages, and our/your carrier's privacy policies apply.