YOUR DATA.
YOUR SIGNAL.

Controller and scope

ZORBI Ltd (“ZORBI”, “we”, “us” or “our”) is the controller responsible for personal data described in this Policy. This Policy covers our websites, account interface, support channels and other services that link to it. Third-party websites, wallets, blockchains, exchanges and social networks operate under their own privacy terms.

Personal data we collect

Depending on how you use the Service, we may collect:

• Account data: name, email address, username, password hash, referral relationship and account preferences.
• Verification data: identity, residency, sanctions-screening, source-of-funds or similar information where required for compliance or security.
• Transaction data: selected asset and network, wallet address, public TXID, amount, conversion information, plan activity, account ledger entries, release and withdrawal requests.
• Technical data: IP address, device and browser information, language, timestamps, referring URL, diagnostic events and security logs.
• Communications: support messages, attachments, survey responses and correspondence with us.
• Public or partner data: information from public blockchains, fraud-prevention services, analytics providers, payment or conversion providers, and compliance databases.

Please do not send passwords, authentication codes, wallet seed phrases or private keys. We do not need them to provide support.

Why and how we use data

We process personal data where necessary to provide the Service and perform our agreement with you; comply with legal obligations; protect legitimate interests such as security, fraud prevention, service improvement and dispute handling; and, where required, based on consent.

Specific purposes include creating and securing accounts, recording instructions, displaying balances and history, processing support requests, verifying transactions, preventing abuse, communicating service notices, improving usability, maintaining records, enforcing terms and complying with lawful requests.

Where marketing consent is required, you may withdraw it at any time. Service and security messages may still be sent because they are necessary for your account.

When data is shared

We do not sell personal data. We may disclose only what is reasonably necessary to:

• hosting, infrastructure, security, email, analytics and customer-support providers;
• digital-asset, conversion, blockchain-data, fraud-prevention and compliance providers;
• professional advisers, auditors and insurers under appropriate confidentiality duties;
• authorities or other parties where required by law, court order, legal process, protection of rights or prevention of harm;
• a successor in connection with a merger, acquisition, restructuring or transfer of business, subject to applicable safeguards.

Providers process data under contractual or legal duties appropriate to their role.

Public blockchain information

Public blockchains are designed to preserve transaction records. A wallet address, token balance, transaction amount and TXID written to a public network may be visible permanently and may be associated with other information by third parties. ZORBI cannot erase, alter or control records maintained by a decentralized network.

Do not treat a public wallet address as private. Consider using appropriate wallet practices and avoid publishing information that unnecessarily links your identity to an address.

International processing and transfers

ZORBI is based in Belize and may use service providers or infrastructure in other countries. Those countries may have privacy laws different from the laws where you live. Where required, we use contractual, organizational or other lawful safeguards for international transfers.

Security and retention

We use reasonable technical and organizational measures designed to protect personal data, such as access controls, secure transport, monitoring, authentication controls and restricted staff or provider access. No online system, blockchain interface or storage method is completely secure, so absolute security cannot be guaranteed.

We retain data only for as long as reasonably necessary for the purposes described in this Policy, including account operation, legal compliance, fraud prevention, tax or accounting requirements, dispute resolution and enforcement. Retention periods vary by data type, account status and legal requirement. Data may be deleted, anonymized or securely archived when no longer required.

Your privacy rights

Subject to applicable law and permitted exceptions, you may request information about processing; access to your personal data; correction of inaccurate or incomplete data; erasure; restriction; portability; or objection to certain processing, including direct marketing. Where processing relies on consent, you may withdraw it without affecting prior lawful processing.

We may ask you to verify your identity before acting on a request. Some data cannot be deleted immediately where retention is required by law, necessary for security or dispute handling, or recorded on a public blockchain beyond our control.

Send a request to support@zorbi.to. You may also raise a concern with the competent data-protection authority where applicable.

Cookies and similar technologies

We may use essential cookies or local storage to maintain sessions, remember security choices, route requests and keep the Service functioning. We may also use limited analytics or performance technologies to understand aggregate usage and diagnose problems. Where required, non-essential technologies will be presented through a consent choice.

You can control cookies through browser settings, but disabling essential storage may prevent login or other account features from working.

Children, updates and contact

The Service is not directed to anyone under 18, and we do not knowingly permit minors to create accounts. If you believe a minor has provided personal data, contact us.

We may revise this Policy to reflect changes in the Service, law or processing practices. The effective date at the top identifies the current version. Material changes may also be communicated through the Service or registered email.

Contact the controller

For questions, complaints or privacy-rights requests, use the Support Center or email support@zorbi.to.