Privacy Policy

This Privacy Policy (“Policy”) explains how ZKE Global Limited (incorporated in The Bahamas) and its affiliates (collectively, “ZKE,” “we,” “us,” “our,” or the “Platform”) collect, use, share, retain, transfer, and protect your Personal Information when you access or use any website, app, H5 pages, APIs, campaign pages, and other related services that link to or reference this Policy (collectively, the “Services”), and describes your rights and choices.

If you do not agree with this Policy, please stop using the Services. By continuing to use the Services, you acknowledge that you have read and understood this Policy and agree to the processing of your Personal Information as described herein (where consent is required, we will obtain it separately).

1. Data Controller / Operator and Contact

1. Data Controller / Operator: ZKE Global Limited (The Bahamas)
2. Privacy & Support Contact Email: support@zke.com
3. If your jurisdiction requires us to appoint a Data Protection Officer (DPO) or local representative, we will disclose the relevant information through announcements or updates to this Policy.

Note: Certain Services may be supported by our affiliates, processors, and partners (e.g., KYC providers, risk control vendors, cloud providers, messaging/email providers). We remain responsible for Personal Information processed on our behalf and require such parties to protect your information in accordance with applicable laws and contractual obligations.

2. Scope of This Policy

This Policy applies to your use of our crypto exchange-related Services, including but not limited to:

• Account registration/login, identity verification, and security settings
• Deposits, withdrawals, transfers, and spot/derivatives trading (if offered)
• APIs and developer features
• Customer support, tickets, live chat, complaints, and dispute handling
• Marketing campaigns, referral programs, and rewards programs
• Risk control, fraud prevention, and compliance checks (KYC/AML/sanctions screening)
• Analytics, operational optimization, and security audits

Not covered: Third-party websites/services. If you access third-party services via links or integrations, their privacy policies apply.

3. What Personal Information We Collect

We follow a “data minimization” principle and collect information depending on how you use the Services.

3.1 Information You Provide

• Account Information: email address, phone number, username/nickname, UID
• Identity & Compliance (KYC) Information: full name, ID type/number, ID images/videos, facial verification data (for verification), date of birth, nationality, country/region of residence, residential address (as required)
• Payment & Funds-Related Information: bank/beneficiary details, wallet addresses, information required for fiat on/off-ramps (if any)
• Security Settings: 2FA binding details, withdrawal whitelist settings, API Key labels/permissions
• Support & Communications: ticket content, chat logs, attachments, complaints/appeal materials
• Campaign & Referral: referral relationships, invitation codes, task submission materials (if any)

3.2 Information We Collect Automatically (Device/Log/Usage)

• Device & Network: IP address, device identifiers, browser type, OS, language, time zone, network type, device model
• Login & Security Logs: login time, approximate location (based on IP), login method, failure reasons, risk-control hits, security incident records
• Usage & Interaction: page views, clicks/operations logs, preference settings, crash/error logs, performance metrics
• Trading & Account Activity: order placement/cancellation/fills, account ledgers, deposit/withdrawal records, risk-control triggers

We do not store your password in plain text. Passwords are stored/validated using secure hashing/encryption mechanisms.

3.3 Information From Third Parties

Where compliant and necessary, we may receive information from third parties, such as:

• KYC/identity verification providers: verification results, risk flags, authenticity checks
• Anti-fraud/risk vendors: device risk signals, fraud indicators, anomaly scores
• Sanctions/blacklists/PEP databases: screening match results (for compliance)
• Payment/fiat providers (if any): payment status, chargeback risk, settlement status

4. Purposes for Processing

We process Personal Information for the following purposes:

1. Providing and performing the Services
   • Registration, login, and account management
   • Trade matching/execution, settlement, deposits/withdrawals
   • API access control and developer services
   • Customer support, notices, and communications
2. Security and risk control
   • Account security, abnormal login detection, anti-account-takeover
   • Fraud prevention, AML/CTF, sanctions screening
   • Preventing abuse of campaigns (wash trading, cheating, malicious arbitrage, etc.)
3. Compliance and legal obligations
   • Meeting regulatory/law enforcement requirements where applicable
   • Retaining identity/trading records for statutory retention obligations
   • Handling disputes, arbitration/litigation, and regulatory inquiries
4. Product improvement and analytics
   • Troubleshooting, performance optimization, improving availability and user experience
   • Statistical analysis, reporting, and improving risk models
   • A/B testing and feature iteration (with choices where appropriate)
5. Marketing and campaigns (where consent is required)
   • Sending campaign/reward/promotional notifications
   • Personalized recommendations (you may opt out)
   • Validating and administering referral/rewards programs

5. Legal Bases for Processing

Where required by applicable law, we process Personal Information based on one or more of the following legal bases:

• Contract performance: necessary to provide the Services
• Legal obligations: KYC/AML/sanctions checks, regulatory requests, statutory recordkeeping
• Legitimate interests: security protection, fraud prevention, service improvement (balanced against your rights)
• Consent: marketing messages, non-essential cookies, certain personalization features (you can withdraw consent at any time)

6. Cookies and Similar Technologies

We use cookies, pixels, local storage, and similar technologies for:

• Strictly necessary purposes: authentication, session security, CSRF protection, load balancing
• Functional preferences: language/currency/theme settings
• Analytics: traffic statistics, page performance, error rates
• Advertising/marketing (if enabled): measuring ad performance and personalization (you can opt out where available)

You can manage cookies via your browser settings. Disabling certain cookies may affect functionality. If we provide a cookie banner or privacy settings panel, you may manage preferences there as well.

7. Sharing, Transfers, and Disclosures

We do not sell your Personal Information. We may share or disclose Personal Information (on a minimum-necessary basis) in the following situations:

7.1 Service Providers / Processors

Examples include cloud hosting, data storage, SMS/email delivery, customer support systems, analytics, risk/fraud prevention, KYC services, and payment services (if any).

We require service providers to:

• process data only under our instructions
• implement appropriate security measures
• not use data for their own purposes
• delete/return data upon termination as required by contract

7.2 Affiliates

We may share necessary information with our affiliates for unified operations, compliance, risk control, security, and service delivery, subject to appropriate safeguards.

7.3 Corporate Transactions

If we undergo a merger, acquisition, reorganization, or asset sale, your information may be transferred as part of that transaction. We will provide notice where required and ensure continued protection.

7.4 Legal Requirements and Protection

We may disclose information where we believe disclosure is necessary to:

• comply with applicable laws, regulations, or requests by regulators/law enforcement
• protect the rights, property, or safety of you, other users, the Platform, or the public
• prevent fraud, cyberattacks, money laundering, or other illegal activities
• resolve disputes, enforce agreements/rules, or pursue legal remedies

8. International Transfers and Data Storage Locations

We may use global infrastructure and service providers. Your Personal Information may be stored or processed in The Bahamas and other jurisdictions. We take appropriate safeguards for international transfers, including:

• access control and least-privilege principles
• encryption in transit and at rest where appropriate
• contractual data protection terms
• vendor security assessments and audits

9. Data Retention

We retain Personal Information only for as long as necessary to fulfill the purposes described in this Policy, and then delete, anonymize, or isolate it unless a longer retention period is required by law.

Typical examples:

• Account & KYC information: typically 5–10 years after account closure (for AML/regulatory/dispute purposes, depending on legal requirements)
• Trading and funds records: typically 5–10 years
• Security logs (IP/device/risk): typically 6–24 months
• Support/ticket records: typically 2–5 years or until disputes are resolved
• Marketing subscription records: retained for the minimum period necessary to honor your opt-out and suppression lists

Note: If you request deletion, we will honor the request where possible, subject to legal obligations (e.g., AML recordkeeping).

10. Security Measures

We implement layered security measures (but no system can be 100% secure), including:

• secure transmission (e.g., TLS) and encryption of key data where appropriate
• password hashing, data masking, and key management
• access controls, least privilege, and audit logging
• risk/fraud systems, monitoring, and alerting
• security testing, patching, backups, and disaster recovery

Your role in security:

• use strong passwords and enable 2FA
• never share verification codes, keys, or API keys
• log out on shared devices
• beware of phishing sites and fake support channels

If a Personal Information security incident occurs, we will take remediation steps and provide notices where required by applicable law.

11. Your Rights and Choices

Depending on applicable law, you may have rights such as:

1. Access and copy your Personal Information
2. Correct inaccurate or incomplete information
3. Delete your information (subject to AML/regulatory retention obligations)
4. Restrict processing in certain circumstances
5. Object to processing based on legitimate interests
6. Data portability (where applicable)
7. Withdraw consent (for consent-based processing; withdrawal does not affect prior lawful processing)
8. Marketing opt-out (unsubscribe from promotional emails/SMS/push notifications)

How to exercise your rights

Contact us at support@zke.com with your request. We may need to verify your identity and locate your data securely. We will respond within a reasonable timeframe, typically within 30 days (complex requests may take longer; we will inform you if so).

12. Children’s Privacy

Our Services are not intended for individuals under 18. If we learn that we have collected Personal Information from a minor without appropriate authorization, we will take steps to delete such information and restrict access to the Services.

13. Automated Decision-Making and Profiling (If Applicable)

For security and compliance, we may use automated tools (including algorithms/models) to assess account and transaction risks (e.g., fraud detection, abnormal login detection, AML risk scoring, campaign abuse detection).

If automated processing leads to significant effects (such as withdrawal/trading restrictions), we generally provide appeal/review channels, subject to applicable law and Platform rules.

14. Public Blockchain Information

Blockchain transactions may be publicly visible (e.g., transaction hashes, addresses, on-chain amounts). We cannot control public blockchain visibility. Third parties may analyze and link wallet addresses and transactions. Please understand these privacy implications when using blockchain services.

15. Third-Party Links and SDKs

Our Services may include third-party links or integrate third-party SDKs/services (e.g., analytics, customer support, payments, KYC). These third parties may process information under their own policies. We aim to select reputable partners, but their practices are outside our direct control. Please review their privacy policies.

16. Updates to This Policy

We may update this Policy to reflect business, compliance, or technology changes. We may notify you via platform announcements, in-app messages, pop-ups, or other reasonable means.

Your continued use of the Services after the effective date of an update constitutes acceptance of the updated Policy. If you do not agree, you should stop using the Services and close your account (where applicable).

17. Contact Us

If you have any questions, concerns, or complaints about this Policy or our processing of Personal Information, please contact:

• Email: support@zke.com

18. Language and Interpretation

If multiple language versions of this Policy exist, the English version shall prevail in the event of any inconsistency.