Citizenship by Investment
Privacy Policy
Zenturo Ltd. (“Zenturo,” “we” or “us”) is committed to protecting
your privacy. This Privacy Policy explains how information about
you or associated with you is collected, used and shared by Zenturo.
This Privacy Policy applies to our websites and other services and
applications we may provide (collectively, our “Service”).
By accessing or using our Service, you signify that you have read,
understood and agree to our collection, storage, use and disclosure
of your personal information as described in this Privacy Policy.
If you do not agree with this policy, do not access or use our Service
or interact with any other aspect of our business.
Table of Contents
● INFORMATION WE COLLECT
● HOW WE USE INFORMATION WE COLLECT
● HOW WE SHARE INFORMATION WE COLLECT
● STORAGE AND SECURITY OF INFORMATION
● YOUR CHOICES REGARDING YOUR INFORMATION
● UPDATES TO OUR PRIVACY POLICY
● CONTACTING US
● LAST REVISION DATE
INFORMATION WE COLLECT
We collect information about you when you provide it to us, when
you use our Service, and when other sources provide it to us, as
described below.
● Information you provide
○ We may collect information you enter in our Service or provide
to us in some other manner, including your name, email address,
and phone number.
○ We may collect any communications between you and us, as well
as any additional information you provide.
● Information we collect automatically when you use our Service
○ Cookies and Other Tracking Technologies. We automatically collect
certain types of usage information when you visit our website or
use our Service. When you visit our website, we may send one or
more cookies - a small text file containing a string of alphanumeric
characters - to your computer that uniquely identifies your browser.
● A cookie may convey information to us about how you use our Service
(for example, the pages you view, the links you click, how frequently
you access our Service, and other actions you take on our Service),
and allow us to track your usage of our Service over time.
○ We may employ clear gifs (also known as web beacons) which
are used to anonymously track the online usage patterns of our users.
In addition, we may also use clear gifs in HTML-based emails sent
to our users to track which emails are opened and which links are
clicked by recipients. The information allows for more accurate
reporting and improvement of our Service.
○ Device and Connection Information. We may collect log file
information from your browser or mobile device each time you access
our Service. Log file information may include Internet Protocol
(“IP”) address, browser type, information about your mobile device,
referring / exit pages and URLs, number of clicks and how you interact
with links on our Service, domain names, landing pages, pages viewed.
When you access our Service by or through a mobile device, we may
collect and store unique identification numbers associated with
your device or our mobile application, mobile carrier, device type,
model and manufacturer, mobile device operating system brand and
model, and phone number.
● Information collected through the use of our Service
○ Information you provide through the use of our Service such
as self-reported information.
● Information we receive from third parties
○ We may receive information about you and your activities on
and off our Service from public sources and third-party partners,
such as advertising and market research partners who provide us
with information about your interest in, and engagement with, our
Service and online advertisements.
HOW WE USE INFORMATION WE COLLECT
● To provide our Service
○ We use information about you to provide our Service to you,
including to provide customer support, and to monitor, operate and
maintain our Service.
● To communicate with you
○ We may send you Service-related emails or messages that may
contain personal information.
○ Please be aware that communications via email over the internet
are not encrypted. Although unlikely, there is a possibility that
information in an email can be intercepted and read by other parties
besides the person to whom it is addressed. If you have concerns
about the use of email, you may contact us as provided in the Contacting
Us section to request assistance.
● To market, promote, and drive engagement with our Service
○ We may use your information to help us measure traffic and
usage trends for our Service, to understand more about the demographics
of our users, and to provide custom, personalized content and information,
including targeted content and advertising for other Zenturo products.
HOW WE SHARE INFORMATION WE COLLECT
We share information about you with third parties that help us operate,
provide, improve, integrate, customize, support, and market our
Service.
● Service providers
○ We may work with third party businesses, consultants and other
providers that perform services on our behalf or with which we partner
to offer you those services.
● Compliance with enforcement requests and applicable laws; Enforcement
of our rights
○ We may share information as required to satisfy any applicable
law, regulation, court order, legal process or other government
request, to enforce our Terms of Service (including the investigation
of potential violations thereof), or to investigate and defend ourselves
against any third party claims or allegations.
● Links to third party websites
○ Our Service may contain links to and from third party websites.
If you follow a link to any of these websites, please note that
these websites have their own privacy policies and that we do not
accept any responsibility or liability for their policies. Please
check the individual policies before you submit any information
to those websites.
● Aggregated data
○ We may share information in an aggregated and anonymous form
that does not identify you directly as an individual.
STORAGE AND SECURITY OF INFORMATION
● Storage and international transfers of your information
○ Your information collected through the Service may be stored
and processed in Malta or another country in which Zenturo, our
affiliates, or service providers maintain facilities.
○ We may transfer information to a country and jurisdiction that
does not have the same data protection laws as your jurisdiction,
and you consent to the transfer of your information to Malta or
any other country in which Zenturo, our affiliates, or service providers
maintain facilities and the use of your information as described
in this Privacy Policy.
● Security of your information
○ We take reasonable physical, administrative, and technological
safeguards to preserve the integrity and security of your information.
However, no security system is impenetrable and we cannot guarantee
that your information is completely safe from intrusion.
○ In the event that any information under our control is compromised
as a result of a breach of security, we will take reasonable steps
to investigate the situation and where appropriate, notify those
individuals whose information may have been compromised and take
other steps in accordance with any applicable laws and regulations.
● How long we keep your information
○ We will retain your information for as long as your account
is active or as needed to provide you our Service. We also retain
some of your information as necessary to comply with our legal obligations,
to resolve disputes, to enforce our agreements, to support business
operations and to continue to develop and improve our Service.
○ Where we retain information for improvement and development
of our Service, we take steps to eliminate information that directly
identifies you as an individual.
○ We retain information about your marketing preferences unless
you specifically ask us to delete such information. We retain information
derived from cookies and other tracking technologies for a reasonable
period of time from the date such information was created.
● Persons under the age of 13
○ Our Service and its content are not directed at children under
the age of 13. In the event that we learn that we have collected
information from a child under age 13 without parental consent,
we will take steps to delete such information.
○ If you believe that we might have any information collected
from a child under 13, please contact us as provided in the Contacting
Us section.
YOUR CHOICES REGARDING YOUR INFORMATION
You have certain choices available to you when it comes to your
information, as stated below. You may contact us as provided in
the Contacting Us section to request assistance.
● Access and update your information
○ You may access and update your information by contacting us
as provided in the Contacting Us section. For example, you can update
your email address by contacting us.
● Delete your information
○ You may request that we delete or anonymize certain information
about you. Please note, however, that we may need to retain certain
information for record keeping purposes, to complete transactions
or to comply with our legal obligations.
● Request that we stop using your information
○ You may ask us to stop accessing, storing, using and otherwise
processing your information where you believe we don't have the
appropriate rights to do so. For example, if you believe a Services
account was created for you without your permission or you are no
longer an active user, you can request that we delete your account
as provided in this policy.
○ Where you gave us consent to use your information for a limited
purpose, you may withdraw that consent, but this will not affect
any processing that has already taken place at the time. You can
also opt-out of our use of your information for marketing purposes.
● Opt out of communications
○ You may opt out of receiving promotional communications from
us and to have your contact information removed from our promotional
email list or database.
● "Do Not Track" Signals
○ Some browsers have "Do Not Track" (DNT) features that can send
a signal to the websites you visit indicating you do not wish to
be tracked. Because there is not yet a common understanding of how
to interpret the DNT signal, our Service do not currently respond
to browser DNT signals.
● Copy of your information
○ Upon your request, we will provide you or a third party that
you designate with an file of your basic account information in
a structured, electronic format.
Your request and choices may be limited in certain cases: for example,
if fulfilling your request would reveal information about another
person, or if you ask to delete information which we are permitted
by law or have compelling legitimate interests to keep.
Where you have asked us to share data with third parties, for example,
you will need to contact those third-party service providers directly
to have your information deleted or otherwise restricted.
If you have unresolved concerns, you may have the right to complain
to a data protection authority in the country where you live, where
you work or where you feel your rights were infringed.
UPDATES TO OUR PRIVACY POLICY
We may modify this Privacy Policy from time to time. If we make
any changes to this Policy, we will change the "Last Revision" date
below and will post the updated Privacy Policy on this page.
CONTACTING US
If you have questions about this Privacy Policy, please contact
us at service@Zenturo.com or by writing to us at:
Zenturo Ltd.
Attn: Privacy Officer
394A / 395A, Triq il-Kbira San Guzepp
Santa Venera SVR 1016, Malta
When contacting us, please include sufficient information for us
to identify all of your records, such as your name, address, and
a telephone number where we can contact you. Zenturo will consider
your request and provide you a response within a reasonable timeframe.
LAST REVISION DATE
This Privacy Policy was last revised on January 01, 2023.
ZENTURO LTD. MAKES NO WARRANTY THAT THE SITE OR SERVICES WILL MEET
YOUR REQUIREMENTS, OR WILL BE TIMELY, SECURE, CURRENT, ACCURATE,
COMPLETE, OR ERROR-FREE, OR THAT THE RESULTS OBTAINED BY USE OF
THE SITE AND/OR OUR SERVICES WILL BE ACCURATE OR RELIABLE. YOU UNDERSTAND
AND AGREE THAT YOUR SOLE AND EXCLUSIVE RIGHT AND REMEDY WITH RESPECT
TO ANY DEFECT IN OR DISSATISFACTION WITH THE SITE AND/OR OUR SERVICES
OR ANY OTHER GRIEVANCE SHALL BE YOUR DISCONTINUATION OF ACCESS TO,
OR USE OF THE SITE AND/OR SERVICES.