Article 2.1: Legal Basis for Processing
Zelencio processes your personal data only when there is a valid legal ground to do so. These grounds include:
2.1.1. Contractual Necessity: To perform the services you requested, such as executing a crypto swap, facilitating a P2P trade, or maintaining your digital wallet.
2.1.2. Legal Obligation: To comply with global and local financial regulations, including Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and "Know Your Customer" (KYC) mandates.
2.1.3. Legitimate Interest: To protect the platform and its users from fraud, hacking, and platform abuse.
2.1.4. Explicit Consent: For specific actions such as accessing your GPS location, sending marketing communications, or processing biometric data for liveness verification.
Article 2.2: Facilitation of Financial Services
We use your Identity and Transactional data to:
2.2.1. Account Management: Create and maintain your unique user profile, Zelencio Identity Number (ZIN), and associated wallet addresses.
2.2.2. Transaction Execution: Process and record deposits, withdrawals, internal transfers, and algorithmic swaps on the Zelencio Internal Ledger.
2.2.3. P2P Marketplace & Escrow: Facilitate the direct exchange of assets between users and digital product trades within the Escrow Hub. This includes sharing limited payment info (e.g., bank account details) with your specific trading partner to complete a transaction.
Article 2.3: Security and Fraud Prevention
Protecting user assets is our primary technical objective. We process Technical and Log data to:
2.3.1. Unauthorized Access Detection: Monitor device fingerprints and IP addresses to identify suspicious login attempts from unrecognized devices or locations.
2.3.2. Anti-Fraud Screening: Utilize AI-driven behavior analysis to detect "Triangular Scams," "Wash Trading," or other prohibited market manipulations.
2.3.3. Identity Confirmation: Use liveness videos and facial mapping to ensure that the individual attempting to withdraw funds is the same verified individual who owns the account.
Article 2.4: Regulatory Compliance (AML/CTF)
As a Virtual Asset Service Provider (VASP), Zelencio is legally required to:
2.4.1. Sanctions Screening: Screen user data against global and regional sanctions lists to ensure the platform is not used by prohibited persons or entities.
2.4.2. Transaction Monitoring: Identify and investigate high-value transactions or patterns that suggest money laundering (e.g., rapid movement of "Zelencio Codes").
2.4.3. Reporting: Maintain audit-ready records to cooperate with financial intelligence units (such as the SEC or EFCC in Nigeria) and other regulatory bodies.
Article 2.5: User Support and Dispute Resolution
We process Communication and Support data to:
2.5.1. Resolve Inquiries: Provide 24/7 technical assistance through our AI and human support teams.
2.5.2. Mediate Disputes: Review chat logs and uploaded evidence (Item Proof) within the Escrow Hub to provide a final, binding judgment in the event of a trade conflict.
Article 2.6: Platform Optimization and Marketing
To improve the user experience, we may use anonymized usage data to:
2.6.1. Technical Improvement: Analyze which features (e.g., SOMD or One-Click Swap) are most used to prioritize future development.
2.6.2. Referral and Reward Distribution: Track referral links and daily task completions to accurately calculate and distribute USDC or promotional bonuses.
2.6.3. Communications: Send system alerts regarding account security, price updates, or new platform features. You may opt out of promotional messages at any time within the "Notifications" settings.