tZERO GROUP PRIVACY POLICY

This Privacy Policy was last revised and updated on April 24, 2020.

Thank you for your interest in tZERO. tZERO Group, Inc. (tZERO, we, or us) is committed to protecting the privacy of our users, and we strive to provide a safe and secure user experience.

This Privacy Policy describes how we collect and use the information we collect through the website at www.tzero.com, other websites and applications owned and operated by tZERO, and offline when you contact us electronically, by mail or through our customer service center (together, our Service).

This Privacy Policy does not apply to websites, mobile applications or services operated by third parties, including affiliates of tZERO, including tZERO ATS, LLC, SpeedRoute, LLC, tZERO Markets and tZERO Crypto. Please refer to the privacy policies for those other websites and mobile applications for the data collection, use, and sharing practices applicable to those websites and mobile applications.

This Privacy Policy includes the following Sections. You can jump to particular topics by clicking the headings below:

What Information We Collect AND WHY

Personal Information means anything that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We collect the following types of information:

ContextTypes of DataPrimary Purpose for Collection and Use of Data
Account InformationWe collect your name and contact information, such as email address, mailing and physical address, phone or mobile number, zip code, date of birth, information about your spouse, location data, photographs, videos, comments, passport or driver’s license numbers, and other identification verification when you create an account. We also collect information relating to the actions that you perform while logged into your account.We use this information to provide account related functionalities to our users, including creating, maintaining, and securing your account, and to perform our contract to provide Services to you. In some circumstances, we also collect this information to comply with laws, including "know your customer" laws.
Commercial InformationWe collect details of queries, complaints, feedback or issues with your Service; and credit card information, banking information and other payment processing information.We collect this information in order to fulfill our contract to provide you Services, to respond to your queries, complaints, or feedback. In some circumstances, we also collect this information to comply with laws, including "know your customer" laws.
Cookies and first party trackingWe use cookies and clear GIFs. "Cookies" are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our "How We Collect Information" section for more information.We use this information to make sure our website operate efficiently.
Cookies and Third Party TrackingWe participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our "How We Collect Information" section for more information.We engage in behavior-based advertising and capturing website analytics.
Email InterconnectivityIf you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.We use this information to understand how you interact with our communications to you.
EmploymentIf you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.We use information about applicants to evaluate you for possible employment. We use information about current employees to facilitate the employee relationship. In some contexts, we are also required by law to collect information about our employees and applicants.
Feedback/SupportIf you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.We use this information to improve our services.
Mailing ListWhen you sign up for one of our mailing lists we collect your email address or postal address.We share information about our services with individuals who agree to receive such information.
Website InteractionsWe use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.We use this information to understand how you interact with our website to better improve it, to understand your preferences and interests in order to select offerings that you might find most useful, and to detect and prevent fraud.
Web LogsWe collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.We use this information to monitor our networks and the visitors to our websites. Among other things, it helps us.
How We Collect Information

We Collect Information Using Cookies and Other Technologies

In addition to collecting data directly from you, we use cookies, tracking pixels/web beacons and or other technologies to receive and store certain types of information, including your Direct Identifiers and Internet Activity Information. Cookies are pieces of information that can be placed on your computer, tablet, or device for the purpose of facilitating and enhancing your communication and interaction with our Service.

We use cookies and these other technologies to collect information as follows:

  • Category 1: Strictly necessary. These cookies and other technologies are strictly necessary to enable you to use our Service, for example providing you the Service you have requested.
  • Category 2: User choices. These cookies and other technologies allow us to remember the choices you have made, for example your user name, language used, or country. They may be used for user preferences purposes.
  • Category 3: Third-Party Analytics. These cookies and other technologies are placed by our third-party partners for web analytics purposes. Examples of these cookies and other technologies include Google Analytics and Adobe Analytics. You can opt out of Google Analytics by following the instructions provided at https://tools.google.com/dlpage/gaoptout.

Generally, you may stop or restrict the placement of our cookies on your computer by adjusting your web browser preferences, but please note that this may impact your ability to use our Service, for example, some Cookies we place are to verify your identity and are therefore an important aspect of maintaining security.

We Collect Information from Other Sources

We may also obtain your personal information from third parties, including business partners, affiliates, associated trust entities, and publicly available sources, that can enhance and add to our information about you (e.g., adding address information). This may improve our ability to contact you and improve the relevancy of our marketing by providing better recommendations or special offers that we think may interest you.

How We Protect the Information We Collect

No method of transmission over the Internet, or method of electronic processing or storage, is fully secure. While we maintain reasonable security measures to protect the confidentiality and security of information we hold, we cannot guarantee the security of your information. In the event that we are required by law to inform you of a breach of your information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

How We Share the Information We Collect

Our Affiliates and Associates

We may share your information with our corporate affiliates and associates (e.g., parent company, sister companies, associated trust entities, subsidiaries, joint ventures, or other companies under common control). We have a legitimate business interest to share data with our group as it allows us to better understand the performance of our Services and how to offer and improve our product offerings across the group. It also assists us with finding operational efficiencies (such as financial efficiencies through sharing IT infrastructure), making use of group level software solutions and improving our technological offerings which form an integral part of our Service.

Service Providers

We share your information with service providers that provide services to us. Among other things, these service providers help us with the administration, operation, and marketing of the Service and our product offerings across our group. This includes hosting, communications, printing, marketing, data enhancement, technical support, payment or transaction processing, and fulfillment of services. Our service providers may only process your personal information for the purposes of providing services to us.

Other Third Parties

We share your information with nonaffiliated third parties, for example, for them to develop their own products or market to you, where we and they have established requisite legal permission(s) to do so. Such use is not governed by this Privacy Policy.

Legal Requirements

We may disclose information when we believe disclosure is appropriate to comply with the law, to enforce or apply applicable terms and conditions and other agreements, or to protect our rights, property or safety or the rights, property or safety of our affiliates or associated trust entities, users, or third parties. For example, we may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.

When You Direct Us

We may share your information at your direction or request, through our Service, or otherwise.

With Your Consent

We may ask if you consent to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and may share your information with your consent.

Business Transfers

If another entity acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage. We also may retain a copy of that information.

How Long We Retain Your Information

We will retain your information for as long as necessary for the purposes described in this Privacy Policy and in accordance with the following principles:

  • For the duration required pursuant to a legal obligation;
  • For the period required by applicable law and regulations, for the activities relating to the service; or
  • For the duration of legal proceedings and the related limitation periods, for processing activities necessary to protect against legal liability and enforce our rights.
International Data Transfers

Our Service is controlled and operated from facilities within the United States. Nonetheless, where required and possible, we take steps to treat your information using the same privacy principles that apply pursuant to the law of the country in which we first received your data.

If you are located in the European Union (EU) or your data is otherwise governed by EU privacy laws, we may transfer your personal information to countries outside the European Economic Area (EEA) for processing in accordance with this Privacy Policy and as permitted by applicable laws. Where this is the case, we will ensure that any transfer is necessary for the performance of a contract between us or a contract in your interest, or any entity receiving your information is subject to laws ensuring an adequate level of data protection as determined by the relevant EEA regulatory authority or will ensure that an adequate level of data protection will be available on the basis of standard contractual clauses that will allow you to directly enforce your rights as a third-party beneficiary.

What Choices and Rights You Have Regarding Your Information

We offer you the rights and choices described in this section. Note that if your information was collected by another party under their privacy policy, we may refer you to that party in order to exercise the choices regarding your data.

Rectify Your Information

We rely on you to update and correct your information. Note that we may keep historical information in our backup files as permitted by law. If our Services do not permit you to update or correct certain information, contact us at the address described below to ask us to rectify information that you think is inaccurate or incomplete.

Opting Out of E-mail, Telephone and Text Message Marketing

When we send you promotional emails based on your consent or as permitted by applicable laws, you have the right to unsubscribe. You also have the ability to unsubscribe to promotional e-mails by following the unsubscribe instructions in e-mails. Please allow us up to 10 business days to implement your request to unsubscribe. Note that even if you decide not to receive promotional emails, we may still send you service related communications.

We may distribute mobile coupons and text messages to your mobile device if you have requested this information via an opt-in request. You may opt out of receiving text messages and mobile coupons via the texts you receive.

If you do not wish to receive promotional telephone communication from us, call us at (800) 843-2446 to opt out. This opt out does not apply to operational communication, for example, confirmation of delivery address.

Additional Rights for Individuals Located in Certain Jurisdictions, including California

In some circumstances we may be subject to additional data protection laws that give you additional data protection rights, for example if you are located in certain jurisdictions. To the extent required by these applicable laws, we will grant you the following additional rights, provided we can adequately verify your identity:

  • Access to Your Personal Information. You may request access to your personal information by contacting us. If permitted and required by law, we will grant you reasonable access to the data that we have about you.
  • Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of data, or request that we delete your personal information by contacting us at the address described below. If permitted and to the extent required by law we will grant a request to delete personal information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, in pursuit of a legal action, to detect or monitor fraud, to resolve disputes, or to enforce our agreements with you.

Your California Privacy Rights

In addition to the access and deletion rights described above, California residents are entitled to the following privacy rights. California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are collected, secondaryTitle or transferred for an organization's business purpose (as those terms are defined under California law). You can find a list of the categories of information that we collect and share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than you.

  • The right to opt out of the sale of your personal information. You have the right to opt out of the sale of your personal information. tZERO does not and will not sell your Personal Information. If we change our business practices, we will notify you and honor your right to opt out of the sale of your personal information.
  • The right to equal service. If you choose to exercise any of these rights, tZERO will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of tZERO’s websites or services.

To exercise your right to know or your right to deletion, contact us at (855) 334-8608 or complete our California Consumer Request form available here.

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected personal information. If you have an Account with us, we will use our existing Account authentication practices to verify your identity. If you do not have an Account with us, we may request additional information about you to verify your identity. We will only use the personal information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your personal information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

Shine the Light: This Policy describes how we may share your information, including for marketing purposes. California residents are entitled to request and obtain from tZERO once per calendar year information about any of your personal information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. You may submit your request to [email protected] and include Shine the Light in the subject line of your email.

Additional Information

Important Notices and Transactional E-mail

From time to time, we may send non-commercial electronic email messages with important information about us or our Service to your email address. Please note that any opt-out will not apply to other communications that will be provided to you or any entity or trust that you are the contact point for in relation to your transactions with us, in agreement with us, or where required by law.

Third Party Websites and Services

Our Service contains links to other websites and services not maintained by us or our affiliates or associates. In addition, other websites and services may also reference or link to our Service. Use of such third-party websites is subject to the terms of use and privacy policies of those third parties. We do not control the privacy policies or practices of these third-party websites. We encourage you to be aware when you enter or leave our Service, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.

Compliance with State and Federal Laws

Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our membership. We may also be required to maintain certain of your information to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.

Do Not Track

We do not currently recognize automated browser signals regarding tracking mechanisms, which may include Do Not Track instructions.

Privacy Policy Revisions

We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. We will note the effective date of the latest version at the beginning of the Privacy Policy.

How To Contact Us Regarding This Privacy Policy

If, at any time, you have questions or concerns about this Privacy Policy, please contact us through our contact page or at:

tZERO Group, Inc.
285 Fulton Street, FL 58
New York, NY 10007
[email protected]
(855) 334-8608