Privacy Policy
Millionero Privacy Policy
This Privacy Policy (“Privacy Policy”) for Millionero Exchange (Operated by Zanixo LLC, a Company incorporated under the laws of Saint Vincent & Grenadines and having registration number 2249) and its affiliates collectively (“Millionero Operators”, “Platform”, “Millionero”, “we”, “us” or “our”) describes how we collect, use and disclose information through your use of the Internet site (“the Site”), applications, email, social media, and online services (collectively, the “Services”) operated by, controlled by or affiliated with us.
“Millionero Operators” refer to all parties that run the Platform, including but not limited to legal persons, unincorporated organisations and teams that provide the Services and are responsible for such Services. For the avoidance of doubt, the “Platform”, “we”, or “us” includes the Millionero Operators. Under this Agreement, the Millionero Operators may change as our business adjusts, in which case the changed operators shall perform their obligations under this Agreement and provide the Services to you, and such change does not affect your rights and interests under this Agreement. Additionally, the scope of Millionero Operators may be expanded due to the provision of new Services, in which case, if you continue to use the Services, it is deemed that you have agreed to jointly execute this Agreement with the newly added Millionero Operators. In case of a dispute, you shall determine the entities by which this Agreement is performed with you and the counterparties of the dispute, depending on the specific Services that you use and the particular actions that affect your rights or interests.
By using the Site, you agree to the practices described in this Privacy Policy and any updates posted here from time to time. To make sure you stay informed of all changes, you should check this Privacy Policy periodically. Updates will be referenced by the “Last Revised” date shown above.
01) What Data We Collect
We collect data from you in several ways on the Site, including personal data and data about your usage of the Site, which does not identify you personally. Personal data means information or a combination of information that can reasonably be used to identify you personally (such as your name, phone number, address, and email address).
1.1) Information You Provide to Us Voluntarily
We collect personal data that you voluntarily provide to us when you use our Services. This includes your account information, your communications with us, surveys, and interactive features (such as forums, blogs, Discord community posts, and social media pages). You decide how much information you share with us in most cases, but in some cases, not sharing data may limit your ability to engage with all of our Services.
a) Account Creation.
To create an account with us and use our Services, we may collect the following information from you:
1) Identification information: First and last name, date of birth, gender, phone number, email, government identification number (including but not limited to tax identification, driver’s license number and passport number) and other information necessary to verify your identity to comply with our regulatory obligations under financial, privacy, or anti-money laundering laws;
2) Institutional information: If you are an institutional customer, we may collect your institution’s legal name, Employer Identification Number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), and personal identification information for all material beneficial owners;
3) Financial information: Bank account information, routing number, transaction history, trading data and/or tax identification;
4) Transaction information: Information about the transactions you make using our Services, such as the name of the recipient and the trading amount;
5) Employment information: Your job title, office location, or source of income;
6) Correspondence: Information you provide to our support teams.
b) Your Communications with Us.
We collect personal information from you, such as email address, phone number, or mailing address, when you request information about our Services, request customer or technical support, apply for a job or otherwise communicate with us.
c) Surveys.
We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.
d) Social Media Content.
We may offer forums, blogs, newsletters, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
e) Registration for Sweepstakes or Contests.
We may run sweepstakes and contests. The contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes if permitted by law. In some jurisdictions, we are required to publicly share information about winners.
1.2) Information Collected Automatically
When you access and use the Site, our technology and tools may automatically collect and record certain data about your use of and interaction with the Site that does not personally identify you. This data includes such as your IP address, browser type, the make and model of the device used to view the Site, unique device identifiers, the referring webpage, pages visited, and search terms. All of the information we collect is used in line with this Privacy Policy.
We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services, including information about you when they tag you.
1.3) Information Collected by Third-Parties
Some content on the Site may be served by third-party content providers and may also use cookies, pixel tags, or other similar tracking technologies to automatically collect data about you, both on the Site and throughout the Internet. We do not control the technologies of those third parties. Data collection and use by those third parties are subject to the privacy policies of those third parties. It is up to you to review the terms of use and privacy policies of those third parties.
02) How We Use Your Collected Data
We may use your data for a variety of purposes. Some of these include:
2.1) Providing Services and Requested Information
Some of the data we collect is integral to the operation of our Services. We may use it to:
a) Fulfil our obligations with respect to the reason you voluntarily provided the data (such as responding to an inquiry or providing you with information, products, or services that you request from us or that may be of interest to you);
b) Allow you to participate in certain features of the Site;
c) Improve the Site or our products, events, and services and for other business or commercial purposes;
d) Optimize your experience on the Site (such as troubleshooting technical programs or storing your preferences);
e) Provide co-branded services and features (such as contests, sweepstakes, or other promotions);
f) Notify you about changes to the Site (including this Privacy Policy);
g) Carry out any other purpose described to you at the time the data was collected; and
h)Carry out any other purpose with your express consent or as permitted by law.
2.2) Analyse and Improve our Services
Some of the activities we undertake to analyze and improve our services include:
a) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
b) Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
c) Undertaking research for technological development and demonstration;
d) Researching and developing products, services, marketing, or security procedures to improve their performance, resilience, reliability, or efficiency;
e) Improving, upgrading, or enhancing our Services or those of our Providers;
f) Developing new products and Services;
g) Ensuring internal quality control;
h) Verifying your identity and preventing fraud;
i) Debugging to identify and repair errors that impair existing intended functionality;
j) Enforcing our terms and policies;
k) Complying with our legal obligations, protecting your vital interest, or as may be required for the public good;
l) Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;
m) Auditing relating to interactions, transactions, and other compliance activities; and
n) Other purposes you consent to, are notified of, or are disclosed when you provide personal information.
2.3) Marketing Our Products and Services
Additionally, we may use your data for marketing our products and services to you. We use it to:
a) Provide you with additional information regarding products, events, promotions, and services from Millionero and third parties that may be of interest to you via email, text message, or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit; and
b) Develop, improve, and target our promotional messaging to you and others via retargeting online behavioral advertising and social media platform tools for advertising (such as creating Facebook Lookalike Audiences).
2.4) De-Identified and Aggregated Information Use
We may use personal information and other data about you to:
a) Create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.
b) De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
2.5) Automated profiling
We may use technologies considered automated decision-making or profiling. We will not make automated decisions about you that would significantly affect you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology. You may escalate any concerns you have by contacting us below.
a) Cross-Device Tracking
Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this, our technology partners may share data, such as your browsing patterns, geo-location, and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
b) Share Content with Friends or Colleagues.
Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
03) Disclosing Your Information to Third-Parties
We may disclose your personal information to third parties. Some of these third parties include:
3.1) Other Individuals or Organizations
You may instruct us to share personal information with other individuals and organizations. For example, to complete transactions using your wallet, we will need to share some of your personal information with the individual or organization with which you are interacting. In addition, if you instruct us to do so, your information may be shared with third-party developers to support transactions involving decentralized applications provided by the developers.
a) Service Providers and Business Partners & Affiliates
We may share any personal information we collect about you with our third-party service providers. The categories of service providers (processors) to whom we entrust personal information include IT and related services; banks and trust companies; information and services; payment processors; customer service providers; and vendors to support the provision of the Services.
We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
b) Advertising and Sales & Support Partners
Through our Services, we may allow third-party advertising partners to set up technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions mentioned below.
We may also share your name, phone number, and email with our Marketing & Support partners who may contact you through email and/or phone calls to explain our existing and new features/services; to address your queries regarding our platform functionality and; to take your feedback about the platform. The aforesaid phone calls made to you may be recorded for quality purpose and no additional consent would be required for this.
c) Disclosure in the event of Merger, Sale or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred without notice as part of such a transaction, as permitted by law and/or contract.
d) Legal and Compliance Requirements
We may be required to share information in order to comply with data protection laws and compliance requirements. This includes:
1) To comply with a court order or other legal obligation, to enforce the Site terms of use, to protect the rights, property, or safety of our users and other third parties, and
2) With government or law enforcement officials or private parties (including our legal or other professional advisors) as we determine, in our sole and absolute discretion, it is necessary or appropriate to respond to claims or to comply with legal processes, laws, regulations, or ordinances, or to prevent or stop the illegal, unethical, or actionable activity.
04) Transfer of Collected Data
The Site is operated in Saint Vincent and the Grenadines. If you are located in another jurisdiction, please be aware that the data we collect will be transferred to, stored, and processed in Saint Vincent and the Grenadines. By using the Site and/or providing us with any data, you consent to this transfer, processing, and storage of your data in Saint Vincent and the Grenadines, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen such as the European Union. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. We will take all necessary steps to ensure that your data is subject to appropriate safeguards and that your data is treated securely and in accordance with this Privacy Policy.
05) Data Security and Retention
We may disclose your personal information to third parties. Some of these third parties include:
We use commercially reasonable technical and organisational measures to help secure and safeguard your data in our possession. However, no data transmission over the Internet is completely secure, and no security mechanism is impenetrable. Therefore, although we take steps to protect your data, we cannot guarantee the security of the data that we collect from you or the security of our servers or the Site. By accessing the Site, any transmission of data is at your own risk, and you agree to assume all risk in connection with data sent to us or collected by us.
06) Children and Parents.
We do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.
07) Our “Do Not Track” (DNT) Policy
Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.
08) Your Data Preferences
8.1) Other Use of Collected Data
If you no longer want us to use your collected data as described above or want to revoke any of the permissions granted to us herein above, you may write to us on [email protected].
8.2) Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt-out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).
a) Cookies, Web Beacons, and Other Tracking Technologies
We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.
1) Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
2) Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collect information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
09) Analytics and Financial Data
We use third-party tools to monitor and analyse the use of our Services and to automate certain processes related to the development and operation of our Services:
Google Analytics and Others. We may use Google Analytics and other service providers to collect information regarding visitor behaviour and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/ .
For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/.
You can opt-out of Google’s collection and processing of data generated by your use of the website by going to tools.google.com/dlpage/gaoptout.
You may remove or reject cookies by adjusting settings on your browser and thus opt-out of certain features of the Site and the Site’s automatic collection of certain data. These tracking technology opt-out tools are device and browser-specific, so you must repeat the opt-out from each of your devices and browsers. Please note that removing or rejecting cookies could affect the functionality of the Site.
You may also remove certain tracking technologies and opt-out of online behavioural advertising messaging by using the opt-out tools available from the Digital Advertising Alliance (DAA Opt-Out Tool) and the Network Advertising Initiative (NAI Opt-Out Tools).
9.1) Advertising Preferences
You may adjust your advertising preferences on various social media websites by adjusting your Settings on a particular platform. For example, you may adjust the types of Facebook ads you receive on Facebook and the types of Google ads you receive on Google.
10) Third-Parties, Social Media, and Software Development Kits
The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such Services, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Facebook, LinkedIn, Google, etc. (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site. These features may collect your IP address and which page you are visiting on our site and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.
We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties, including analytics and advertising partners, to collect your personal information for various purposes, including providing analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
11) How We Use Automatic Collection Technologies
11.1) We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:
Some of the data we collect is integral to the operation of our Services. We may use it to:
a) Operationally Necessary This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behaviour, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
b) Performance Related We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services (see Analytics and Financial Data above). For example, we may track your activity on the Services, including recordings of your interactions with the Services;
c) Functionality Related We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign in to our Services or keeping track of your specified preferences, interests, or past items viewed;
d) Advertising or Targeting Related We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or third-party sites.
12) Changes to Privacy Policy
We may modify this Privacy Policy from time to time, in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make changes that are material, we will use reasonable efforts to attempt to provide notice to you and, where required by applicable law or otherwise, at our discretion, and we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on the Platform, or by other means consistent with applicable law. However, it is your sole responsibility to review the Privacy Policy from time to time to view any such changes. The updated Privacy Policy will be effective as of the time of posting or at such later date as may be specified in the updated Privacy Policy. If you do not agree to any future revisions to this Privacy Policy, please do not access or continue to our platform and services.
13) EU Privacy Terms
The GDPR provides residents of the EU with the following rights regarding their personal data:
a) Right to be informed about the collection and use of your personal data
b) Right to access your personal data
c) Right to have any inaccurate personal data corrected
d) Right to have your personal data erased
e) Right to restrict the use of your personal data
f) Right to personal data portability
g) Right to object to the processing of your personal data
h) Right to object to automated decision making
To exercise any of these rights, please submit a request by contacting us. We will respond to any requests within the time required by the GDPR. After you submit your request, you will be sent a confirmation email and need to click on the link provided to confirm your request. Please note that we may need additional information from you to verify your identity before we process your request.
13.1) Legal Basis for Processing Personal Data
To the extent you provide us with personal data, we are processing your personal data under one of the following lawful bases:
a) Consent By opting in, you consent to permit us to process your personal data for the purposes set forth in our Privacy Policy.
b) Compliance with Legal Obligations We may process your personal data in order to comply with certain of our legal obligations.
c) Performance of a Contract We may be required to process your data to comply with legal obligations.
13.2) Cookies, Pixel Tags, and Other Similar Tracking Technologies
To the extent required by applicable law, we will obtain your consent before collecting data using cookies, pixel tags, and other similar tracking technologies on the Site. If you have accepted our use of cookies, pixel tags, and other tracking technologies, we will collect your data in accordance with our Privacy Policy based on your affirmative informed consent, which you may withdraw through the methods provided herein. If you have not accepted, then we only collect your personal data based on our legitimate interests. To view additional information about behavioural advertising and manage your preferences, you can do so by visiting Your Online Choices.
14) Contact Us
To submit a request relating to Your Data Preferences or ask a question about this Privacy Policy, please email us at [email protected]. Please note that requests submitted through the form are processed more quickly than requests submitted by email or mail.