# PRIVACY POLICY

This privacy policy (“Privacy Policy” or “Policy”) is applicable to us, Zktube Labs Pty Ltd. (hereinafter, “zkTube”, "we", "us" or "our") and to all users ("you", "your" or "Users") of the website, application or web service owned or operated by zkTube (collectively the “App” or “website”).

# A.Introduction

This Privacy Policy describes the information that we collect, how we collect it, the purpose of such collection, processing of this information, how and why we share this information, and the period of retaining this information with us. By using or accessing the website, you hereby agree to the terms of this Privacy Policy, especially the terms with respect to collection, storage, processing and sharing of your information. If you disagree with this Privacy Policy please do not use or access our website. This notice applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

This Privacy Policy does not apply to any website(s), mobile sites and mobile apps of third parties, even if their websites/products are linked to our Platforms. Users should take note that information and privacy practices of our business partners, advertisers, sponsors or other sites to which zkTube provides hyperlink(s), may be materially different from this Privacy Policy. Accordingly, it is recommended that you review the privacy statements and policies of any such third parties with whom they interact.

# B.Purpose of Privacy Policy

The purpose of this Privacy Policy is to set out in an accountable and transparent way the collection and use of information by zkTube.

# C.Personal Information

"Personal information" refers to information that can identify you personally or that can reasonably determine your identity. This may include but is not limited to:

  1. We may collect your name, bank card number, phone number (mobile phone number registration method), email address (mail registration method), etc.
  2. zkTube may collect contact storage addresses to facilitate the investigation of data on the chain.
  3. The blockchain wallet address connected to zkTube.
  4. Ethereum network information related to the transaction.
  5. Due to your interaction with zkTube, we may receive Ethereum network information from you.
  6. zkTube may need to use MetaMask, and may obtain additional information related to Ethereum addresses and transactions from MetaMask.
  7. Since you need to mine, we may collect, including but not limited to, IP address, operating system and browser type.
  8. zkTube uses Google Analytics to monitor network traffic. Trading Information collected through Google Analytics is controlled by Google.

# D.Purpose of Personal Information collection

Personal Information is collected in order to: 1.Enable your use of the services and features on the website; 2.Inform you about new features on the website; 3.Develop, enhance, market and deliver products and services to you; 4.Understand your needs and your eligibility for products and services; 5.send statements, invoices and payment reminders to you, and collect payments from you; 6.enable you to download information/white papers/documents you have requested; 7.Conduct surveys and receive feedback from you; 8.Meet zkTube’s legal and regulatory requirements, comply with KYC, AML and other applicable laws; 9.keep our website secure and prevent fraud; 10.We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

# E.Security, Protection and Use of Personal Information

1.zkTube may disclose your personal information to any of our employees insofar as reasonably required.

2.zkTube may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably required.

3.zkTube may disclose your personal information:

(a) to the extent that we are required to do so by law; (b) in connection with any ongoing or prospective legal proceedings; (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); (d) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

4.Except as provided in this policy, we will not provide your personal information to third parties.

5.Information that zkTube collects may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

6.Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: Australia, and Canada.

7.Your agreement with zkTube’s Terms of Use constitutes your consent to the collection and use of Personal Information as described in this Privacy Policy. zkTube reserves the right to use and disclose Personal Information without your knowledge or consent as permitted by applicable law.

8.You hereby agree and accept to transfer of Personal Information as described in this Policy.

# F.Disclosure of Personal Information

1.We use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law. We may make available the Personal Information that you provide to us to our affiliates, agents, representatives, service providers and contractors for these purposes. We also reserve the right to disclose Personal information that zkTube believe, in good faith, is appropriate or necessary to enforce our Terms of Use, take precautions against liability or harm, to investigate and respond to third-party claims or allegations, to respond to a court order or official requests, to protect security or integrity of zkTube and to protect the rights, property or safety of zkTube, our uses or others.

2.Financial transactions relating to [our website and services] [are] OR [may be] handled by our payment services providers, [identify PSPs]. We will share transaction data with our payment services providers only to the extent necessary for the purposes of [processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds]. You can find information about the payment services providers' privacy policies and practices at [URLs]

3.If you request it in writing, we may share your Personal Information with your nominated advisers. Except where disclosure of your Personal Information is required by law or requested by you, we will generally require any third party which receives or has access to Personal Information to protect such Personal Information and to use it only to carry out the services they are performing for you or for us, unless otherwise required or permitted by law. We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will take reasonable steps to ensure that contracts we enter with such third parties binds them to terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.

4.In the event that zkTube is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment or the application of laws or change of control, there may be a disclosure of your information to another entity related to such an event.

5.You acknowledge that the personal information that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

# G.Access and Changing of Personal Information

You have the right to access the Personal Information we hold about you, and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us. We will usually respond to your request within 21 days. You may also request the deletion or destruction of your Personal Information, your Account details or your Transaction details by sending an email to us. zkTube will act on your request only when it is not inconsistent with its legal and regulatory obligations and compliance procedures. Upon your written request, we will inform you of the use and general disclosure of your Personal Information. Depending on the nature of your request, there may be a minimal charge for accessing your Personal Information.

# H.Security

We take reasonable steps to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure, including implementing appropriate security measures. The security measures in place will, from time to time, be reviewed in line with legal and technical developments. However, we give no guarantee that such misuse, loss, unauthorised access, modification or disclosure will not occur. There are protective measures that you should take which as well include but are not limited to changing password regularly, not sharing your Personal Information with other unless you clearly understand the purpose of their request and you know with whom you are dealing.

# I.Retention of Personal Information

We will hold your Personal Information only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements. In general, Personal Information relating to your Account for at least a period of five years after your Account is closed. Similarly, we usually retain information about Transactions on your Account for a period of 5 years from the date of the transaction. Personal Information which is collected for other purposes will be discarded in accordance with our policies in place from time to time.

We will retain your personal data as follows: (a) Account Transaction data will be retained for a minimum period of 3 months following the date of the transaction, and for a maximum period of 5 years following that date; (b) Usage data will be retained for 5 years following the date of collection.

# J.Rights of Users

Your principal rights under data protection law are: (a) the right to access - you can ask for copies of your personal data; (b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data; (c) the right to erasure - you can ask us to erase your personal data; (d) the right to restrict processing - you can ask us to restrict the processing of your personal data; (e) the right to object to processing - you can object to the processing of your personal data; (f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you; (g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and (h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

# K.Users Under Age of 13

zkTube does not knowingly collect or store any personal information about children under 13 without verifiable prior parental consent. If you believe such information have been inadvertently collected, we shall take necessary steps in order to remove such information from our database. Users under 13 must seek and obtain parental consent to use this website.

There may be links from our website to other websites and resources provided by third parties. This Privacy Policy applies only to our website. Accessing those third-party sites or sources requires you to leave our website. We do not control those third-party websites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party websites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those websites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each website that you visit.

# M.Cookies

We use cookies to protect and improve the services provided through our App, increase the ease of access to users, show you relevant content, monitor and analyse the performance, operation, and effectiveness of the App, and to serve you tailored advertising.

A cookie is a small data file that is transferred to your device). For example, a cookie could allow us to recognize your browser, while another could store your preferences. Cookies also allow ease of access, by logging you in without having to type your login name each time (only your password is needed); we may also use such cookies to display any advertisement(s) to you while you are on the website or to send you offers aligning with your interests.

We also use other technologies with similar functionality to cookies, such as web beacons, pixels, mobile identifiers, and tracking URLs, to obtain Log Data. For example, our email messages may contain web beacons and tracking URLs to determine whether you have opened a certain message or accessed a certain link.

# N.Changes

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of changes to this policy by email or Third-party media to notify

# O.Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy and/or practices, please contact us at [email protected].

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