Malta Residency /
Citizenship by Investment
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.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, 2024.
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.