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Privacy Policy

Last Update: 02/24/2025

At Zhero B.V., a private limited liability company organized and existing under the laws of the Netherlands, having its registered office at Westerdoksdijk 423 in (1013 BX) Amsterdam, the Netherlands and at its subsidiaries and affiliates (collectively, “Zhero”, “we”, “us” or “our”), your privacy is very important to us.

1. Introduction

This policy (the “Privacy Policy") explains how we collect, use, store, share, disclose and protect your personal information and your rights in connection thereto under applicable privacy laws, including European Regulation 2016/679 (the “GDPR”). For purposes of GDPR, Zhero B.V is the data controller of your personal information.

This Privacy Policy applies to the personal information that we may collect from you via this website (the “Website”), or that we may otherwise collect from you through any other means, such as email, phone, or face to face communications. In addition, this Privacy Policy also applies to any personal information that we may collect about you from third party sources while operating our business.

We may provide you additional privacy notices when we collect your personal information to supplement this Privacy Policy (including to supplement any requirements applicable to a particular jurisdiction).

2. Information We Collect

We collect several types of information for various purposes, including:

  • Personal data. We may collect personally identifiable information that you provide to us, including:
    • Name
    • Email address
    • Phone number
    • Address
    • Payment information (if applicable)
    • Any other data you provide through forms or interactions with us.
  • Usage data. We may also collect information about how you access and use our Website, including:
    • Your IP address
    • Browser type
    • Device information
    • Pages visited
    • Time spent on pages
    • Referring/exit pages
  • Cookies and tracking technologies. We use cookies and similar tracking technologies to monitor activity on our website and to enhance your experience. You can control cookie settings through your browser settings. Please refer to our Cookie Policy.
  • External sources. Some personal information about you may be provided to us from our vendors, business partners, or industry contacts. We may combine personal information from external sources with other data we obtain from you.

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3. How We Use Your Information

We use the information we collect in the following ways:

  • To provide and maintain our services
  • To personalize and improve your experience on our Website
  • To process transactions and send related information (e.g., order confirmations)
  • To communicate with you, including sending marketing materials if you have opted-in
  • To analyze website usage and trends
  • To comply with legal obligations and enforce our policies

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4. Legal Bases for Processing (EEA)

If you are in the European Economic Area (EEA), we rely on the following legal bases to process your personal data:

  • Consent. When you provide us with personal information, such as subscribing to our newsletter or filling out forms. If applicable laws require so, we will process your personal data upon your (explicit) consent (for example, to use non-essential cookies), in which case you will have the right to withdraw your consent at any time.
  • Contractual necessity. To manage and perform our contract with you.
  • Legitimate interest. When we process data based on our legitimate interest, such as improving our services or properly manage and administer our relationship with you and to ensure that we are as effective and efficient as we can be.
  • Compliance with legal obligations. When processing is necessary to comply with laws and regulations (including our obligations under applicable tax laws, our legal administration obligations, to cooperate with supervisory authorities).

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5. Data Retention

We retain your personal information for as long as necessary for the purposes described in this Privacy Policy or to achieve the purposes for which the information was collected, or as may otherwise be permitted under applicable law or when is necessary for defending our interests in the context of legal proceedings. In determining retention periods, we consider factors such as our legal and contractual obligations, as well as the amount, nature, and sensitivity of personal information, the purposes for which we process the personal information, and the potential risk of harm that may result from unauthorized processing of the personal information.

Where your personal information is used for more than one purpose, we will retain it until the last retention period is met, at which time our goal is to process effective disposition of the information in accordance with company policies and processes. For more information about our retention policies, please contact us using the contact details at the end of this Privacy Policy.

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6. Sharing Your Information

We may share your information with third parties under the following circumstances:

  • Legitimate business purposes. We may make certain disclosures permitted by law for our business purposes, such as disclosures to our affiliates and our and their accountants, auditors and lawyers.
  • Third-party service providers. We may disclose information as needed to third-party service providers that help us operate and improve the Website, such as for hosting and maintenance, analytics and security operations.
  • For corporate transactions. We disclose information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
  • Legal compliance. When required by applicable law or requested by regulators or governmental authorities. Applicable law may require us and third parties that perform services on our behalf to comply with a legal process (such as a court order, subpoena, or search warrant) or in connection with a government or regulatory request or investigation. In addition, we may disclose information for the prevention or detection of crime (subject in each case to applicable law). For example, we may be required to provide to the federal government identifying information about our clients and other persons pursuant to regulations designed to detect or prevent money laundering or fraud.

    Nothing in this Privacy Policy prevents reporting possible violations of law to any governmental authority or other disclosures protected under the whistleblower provisions of applicable law.
  • To protect and enforce legal rights. We also may disclose information:
    • if disclosure would mitigate our liability in an actual or threatened lawsuit;
    • as necessary or advisable to protect the legal rights, property or safety of Zhero, our clients, investors or other third parties;
    • to enforce our agreements with you; and
    • to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
  • At your request or with your consent. In certain circumstances, we may ask for your consent to share your information with third parties. When we do, we will make clear why we want to share the information.

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7. Your Rights

Your rights may vary depending on the privacy laws applicable in your jurisdiction. If you are in the EEA, you may have the following rights regarding your personal data (subject to the exceptions set forth under applicable law):

  • Right to Access. The right to request a copy of the personal data we hold about you.
  • Right to Rectification. The right to correct any inaccurate or incomplete information.
  • Right to Erasure. The right to request the deletion of your personal data, subject to certain conditions.
  • Right to Restriction of Processing: The right to request the restriction of processing under certain circumstances.
  • Right to Object. The right to object to the processing of your personal data, including for direct marketing purposes.
  • Right to Data Portability. The right to request a copy of your personal data in a structured, commonly used, and machine-readable format.

To exercise these rights, you can write to us at legal@zhero.net. We will respond to your request in accordance with applicable law.

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8. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Any changes will be posted on this page, and the "Last Updated" date at the top will be revised accordingly. We encourage you to review this Privacy Policy periodically for any updates.

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9. Security

The security of your information is important to us and we will use reasonable security measures to prevent the loss, misuse or unauthorized alteration of your information under our control. However, given the inherent risks, we cannot guarantee absolute security and consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

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10. Data Transfers

We may transfer, disclose, and store your personal information in any jurisdiction where we or our business partners or vendors, who process data on our behalf, operate. The data protection and privacy laws in such jurisdictions may offer a lower level of protection than the applicable laws in your jurisdiction. We take appropriate measures in compliance with applicable law to protect any personal information that we transfer to another jurisdiction, including safeguards legally required to protect personal information during transfer and other processing outside the jurisdiction where it was collected.

If you are located in the EEA, we will implement appropriate measures when it is transferred outside of the EEA by processing it in a territory which the European Commission or other regulator has determined provides an adequate level of protection for personal information or by otherwise ensuring appropriate safeguards are in place to protect your personal data, such as entering into the Standard Contractual Clauses approved by the European Commission.

By using our Website, or otherwise submitting your personal information to us, you agree to the processing of your personal information in the jurisdictions in which we operate.

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11. Children’s Privacy

Our Website is not directed to and we do not knowingly collect or solicit personal data from individuals under the age of 13 (in the United States) or under the age of 16 (in the EEA) (such individuals as applicable in the relevant jurisdiction, “Childrens”). However, despite our commitment to controlling and preventing the processing of personal data from Childrens, we cannot guarantee the total avoidance of such processing.

If you are a parent or guardian and you believe that we have collected personal data from your child, please contact us at legal@zhero.net so that we can take the necessary actions.

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12. Third Party Links

Our Website may contain links to other websites that are not operated by us. This Privacy Policy does not address the privacy policy and other practices of any third parties, including any third party operating any website or service that may be accessible via a link on the Website. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

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13. Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your data, please contact us at:

• Email: info@zhero.net

• Address: Westerdoksdijk 423 in (1013 BX) Amsterdam, the Netherlands

We will address your questions concerns in accordance with applicable law.

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