Effective Date: April 1, 2025
Last Updated: March 1, 2026
Article 1.1: Commitment to Privacy
Zelencio (“the Platform,” “the Company,” “we,” “us,” or “our”) recognizes the importance of data privacy and the sensitivity of financial information. This Privacy Policy serves as a comprehensive disclosure of our practices regarding the collection, processing, and protection of your Personal Identifiable Information (PII). By interacting with the Zelencio mobile application or website, you provide your explicit consent for the data practices described in these articles.
Article 1.2: Identity and KYC Verification Data
In order to maintain the integrity of our digital asset ecosystem and comply with international Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations, Zelencio enforces a mandatory multi-tiered Know-Your-Customer (KYC) framework. We collect the following data points directly from the User:
1.2.1. Basic Identifiers: Full legal name, gender, nationality, and date of birth.
1.2.2. Contact Information: Verified email address and mobile phone number (processed via SMS-based One-Time Password protocols).
1.2.3. Government-Issued Documentation: Live high-resolution captures of valid identification documents, including but not limited to: International Passports (IP), Voter’s Cards (VC), Driver’s Licenses (DL), and Resident Identity Cards (RI).
1.2.4. Biometric Liveness Data: During the verification phase, the Platform performs a "Liveness Check" involving the capture of facial selfie videos and images. This data is utilized to perform mathematical facial mapping to ensure the user is a living person and matches the provided ID.
1.2.5. Proof of Residency: Official documentation such as utility bills, bank statements, or government-issued residency certificates, which contain your full street address, city, state/province, and postal code.
1.2.6. Financial Background: For high-limit accounts (Tier 3), we may collect "Proof of Funds" or "Source of Wealth" documentation, including employment records or business registration data.
Article 1.3: Technical and Automated Data Collection
To ensure account security, detect unauthorized access, and prevent fraudulent multi-account creation, Zelencio’s systems automatically log technical metadata during every session:
1.3.1. Device Fingerprinting: Hardware model, device name, operating system version (Android/iOS), and unique device identifiers (IMEI/UUID).
1.3.2. Network and Connectivity: Internet Protocol (IP) address, network type (Wi-Fi, 4G, 5G), and Internet Service Provider (ISP) data.
1.3.3. Geolocation Services: Zelencio processes your approximate location derived from your IP address and, with your explicit OS-level permission, your precise GPS coordinates. This is used to maintain regional geofencing and to alert you of suspicious logins from unrecognized locations.
1.3.4. Session Logs: Timestamps of login/logout actions, internal navigation paths, and feature usage duration.
Article 1.4: Transactional and Ledger Information
As a Virtual Asset Service Provider (VASP), Zelencio maintains an exhaustive "Internal Ledger" of all financial movements:
1.4.1. Wallet Data: Public blockchain addresses generated for your account and your Zelencio Identity Number (ZIN).
1.4.2. Transaction History: Comprehensive records of on-chain deposits/withdrawals, internal transfers (ZIN/Email), Zelencio Code (Voucher) creation and redemption, and asset swaps. This includes amounts, assets (USDT, BTC, etc.), and Order IDs.
1.4.3. P2P and Escrow Data: We record all data shared within the P2P/C2C marketplace, including bank names, account numbers, and beneficiary names required to facilitate cash-to-crypto exchanges.
Article 1.5: User-Generated Content and Media
Zelencio provides social and community features where users may voluntarily upload content:
1.5.1. Profile Customization: Profile pictures or avatars uploaded by the user.
1.5.2. Communication Data: All messages, images, and transaction receipts shared within the P2P Trade Chat or the Escrow Hub dispute system.
1.5.3. Support Records: Audio or text recordings of interactions with our 24/7 Support team and AI-driven support interfaces.
Article 1.6: Data Source and Accuracy
User Provision: Most data is provided directly by you during registration and KYC.
Verification Services: We may supplement the data you provide with information from third-party identity verification services to ensure the validity of government IDs.
Obligation of Accuracy: Users are legally obligated to provide truthful and current data. Providing false information for KYC purposes is a violation of our Terms of Service and may be reported to local authorities.