Privacy Policy

Last updated: December 11, 2023.

This Privacy Policy (the “Policy”) represents the policy of ZeGid LLC., a Wyoming company (together with all subsidiaries thereof, the “Company”) regarding the collection, use, and management of personal data belonging to:

• All visitors (“Site Visitors”) to the Company’s website located at https://www.zegidpay.com/ (the “Website”);
• Anyone who downloads or uses (“Application Users”) the Company’s mobile application (the “Application”)
• Anyone who enrolls for the Services of the Company (“Clients”)

Site Visitors, Application Users, and Clients are referred to collectively as “Users”. The Website and the Application together with the Services (as defined below) and all content contained therein are referred to collectively as the “Resources” as further described in the User Agreement.

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing your personal data. If you do not agree with our policies and practices, your choice is not to use the Resources. By accessing or using the Resources, you indicate that you understand, accept, and consent to the practices described in this Policy. Unless an alternative lawful basis for processing personal data is available to the Company, the Company requires Users' permission to collect, use, and disclose personal data, with some exceptions. The exceptions are determined by applicable law and can include times where legal, medical, or security reasons make it impossible or impractical to seek consent.

What data do we collect?

The Company collects the following data from all Users:

• Personal identification information, such as name, date of birth, email, address, and phone number;
• Supplemental identification information, such as government-issued identity documents, taxpayer identification number or national insurance number, and employment information;
• Financial information, including income/wealth verification documents or bank account statements;
• Information on your browser, IP address, location, and device;
• Information on your behavior on our website, including pages viewed, links clicked, keystrokes, and actions taken including copy/paste functions;
• Demographic information;
• Transaction information, including information related to the use of the Services, types of Services requested, dates and times of such requests, payment methods, the name of the sender, the name of the recipient, and other similar information;
• Location data, including User location searches;
• Communications data, including messages, comments, or file transmissions;
• Information about your internet connection, the equipment you use to access our Resources, and usage details;
• Information on your personal calendar;
• Additional information required by the Company (in its sole discretion) to verify a User's identity, which may include utility bills (for example, for proof of residency).

Children’s personal information

Our Resources are not intended for persons under 18 years of age. No one under age 18 may provide any information to or on the Resources. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information on this Resources or through any of its features, register on the Resources, make any purchases through the Resources, use any of the interactive or public comment features of this Resources, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 18, we will reject the application or close the account and delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@zegidpay.com or privacy@zegidpay.com.

How do we collect your data?

Users may provide data directly to the Company. The Company may also collect and process data, which may include personal data, when Users:

• Register online or place an order for any of our products or Services;
• Voluntarily complete a customer survey or provide feedback on any of our message boards or via email;
• Use or view the Site via its browser’s cookies;
• Download or use the Application;
• Submit content to the Site, like reviews, messages, or comments;
• Enable access to its device’s location tracking functionality, whether the Site or Application is running in the foreground (Application or Site open and onscreen) or background (Application or Site open but not on-screen). Certain functionality may be affected while location data is turned off.

How will we use your data?

The Company collects data from Users, which may include personal data, in order:

• To provide the Services and the other Resources to Users
• To enhance the safety and security of our Users and Services, including by protecting you and the Company from errors, misrepresentations, fraud, and/or contraventions of laws or criminal activity
• For customer support
• For research and development
• To enable communications between users
• To send marketing and non-marketing communications to users
• In connection with legal proceedings
• To carry out the Company's obligations and enforce its rights arising from any contracts with a User, including for billing and collection or to comply with legal requirements
• To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you
• To provide Users with information, products, or services that a User requests from the Company.
• To fulfill the purposes for which a User has provided the information or that were described when it was collected, or any other purpose for which a User provides it
• For any other purpose with a User's consent

The Company does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

How do we transfer and store your data?

The security of your personal data is very important to the Company. The Company uses physical, electronic, and administrative measures designed to secure Users' personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. The Company stores all information Users provide to it behind firewalls on our secure servers. Any payment transactions will be encrypted (using SSL technology). The safety and security of User data also depends on each User. Where the Company has given a User (or where a User has chosen) a password for access to certain parts of the Resources, each User is responsible for keeping its password confidential. The Company asks each User not to share its password with anyone.

The Company securely stores User data on servers leased from a reputable third-party hosting service located in the United States. Unfortunately, the transmission of information via the Internet is not completely secure. Although the Company does its best to protect Users' personal data, the Company cannot guarantee the security of Users' personal information transmitted to its Resources. Any transmission of personal data is at each User's own risk. The Company is not responsible for circumvention of any privacy settings or security measures contained on the Resources.

The Company may process, store, and transfer Users' personal data in and to a foreign country, with different privacy laws that may or may not be as comprehensive as the data privacy laws applicable to a particular User. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to a User's personal data through the laws of the foreign country.

Access to your contact list

With your express permission, we may access your contact list on your mobile device so that you can identify your contacts on LemFi to allow you to send money to friends and family on LemFi by searching for their phone number, email address, or username. We transmit and use this information to help you easily filter your friends on ‘LemFi’ and to help you transact with your friends and contacts if you choose to connect your contact list information with your Account. We only access your contact list information with your explicit permission. For example, when you provide us with information about your contacts, we may use it to let you know which of your contacts have also signed up for our Services so you can send money to them for free and quicker.

Data retention and deletion

The Company retains user profile, transaction, and other personal data for as long as a user maintains their account and except as otherwise permitted or required by applicable law or regulation, only for as long as necessary to fulfill the purposes the Company collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

The Company may also retain certain information if necessary, for purposes of safety, security, and fraud prevention. For example, if the Company deactivates a User’s account because of unsafe behavior or security incidents, the Company may retain certain information about that account to prevent that User from opening a new account in the future.

Users may request deletion of their account at any time. Following such requests, the Company deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, the Company retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, the Company may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, the Company will delete the account as described above.

If you decide that you no longer wish us to keep or use information or you want the information to be revised or updated, please feel free to contact us. We will remove or amend the information as appropriate in accordance with our Policy and applicable legislative and regulatory requirements.

Under some circumstances the Company may anonymize Users' personal information so that it can no longer be associated with a particular User. The Company reserves the right to use such anonymous and de-identified data for any legitimate business purpose without furData sharing and disclosurether notice to the relevant User or its consent.

Data usage and processing

We collect and use personal data only where we have one or more lawful grounds or basis for doing so under applicable privacy laws. Such grounds may vary depending on where our Users are located, but generally include processing personal data:

1. To provide requested Services and features:
   • User profile data, which we use to establish and maintain User accounts; verify User identity; communicate with Users about their orders and accounts; and enable Users to make or receive payments (as and if applicable);
   • Usage data, which is necessary to maintain, optimize, and enhance the Company’s Services
   • Transaction information
   • Information relating to customer support
2. For purposes of the legitimate interests of the Company or other parties:
   • This includes using personal data to maintain and enhance our Users’ safety and security. For example, we use personal data to prevent use of our Services by Users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned Users to prevent their use of the Application.
   • This also includes purposes such as combating fraud; improving our Services, direct marketing, research, and development; and enforcing the Company’s User Agreement.
   • In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.
3. To fulfill the Company’s legal obligations:
   • We collect and use personal data to comply with applicable laws. The Company may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes.
4. With consent:
   • The Company may collect and use personal data based on the User’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent. You can give consent in writing, as well as verbally, electronically, or through authorized representatives. In certain circumstances, it’s also implied.
   • A User who has provided consent to a collection or use of their personal data can revoke it at any time (subject to legal or contractual restrictions). However, the User will not be able to use any Service or feature that requires collection or use of that personal data.

Data sharing and disclosure

Some of the Company’s products, Services, and features require that we share data with other Users or at a User’s request. The Company may share the data, which may include personal data, we collect or a User provides:

1. With Other Users:
   • This includes sharing User’s personally identifying information shared on the Application, including to such User’s Profile on the Application.

2. At the User’s request:
   • This includes sharing data with:
     • Other people at the User’s request.
     • Company business partners. For example, if a User requests a service through a partnership or promotional offering made by a third party, the Company may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with the Company's APIs.

With the general public:

• Questions or comments from Users submitted through public forums such as the Company blogs and the Company social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a User.

With the User account owner:

• If an account is operated by a User other than the registered User account owner, we will share information with the registered User account owner.

With the Company subsidiaries and affiliates:

• We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, the Company processes and stores data in the United States on behalf of its international subsidiaries and affiliates.

With the Company service providers and business partners:

• The Company provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:
  • Payment processors and facilitators;
  • Background check and identity verification providers (as applicable);
  • Cloud storage providers;
  • Marketing partners and marketing platform providers, including social media advertising services;
  • Data analytics providers;
  • Research partners, including those performing surveys or research projects in partnership with the Company or on the Company’s behalf;
  • Vendors that assist the Company to enhance the safety and security of its applications;
  • Consultants, lawyers, accountants, and other professional service providers;
  • Insurance and financing partners;
  • Vehicle solution vendors or third-party vehicle suppliers.

7. For legal reasons or in the event of a dispute:
   • The Company may share Users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our User Agreement or other policies; to protect the Company’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.
   • This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

Marketing

• The Company may send its Users information about products and services of the Company, always with the consent of the User. Users may provide consent to marketing and promotional communication when they enroll for the Services pursuant to the User Agreement.
• If you have agreed to receive such marketing materials, you may always opt out at a later date. You have the right at any time to stop the Company from contacting you for marketing purposes.
• If you have agreed to receive such marketing materials, you may always opt out at a later date. You have the right at any time to stop the Company from contacting you for marketing purposes.

What are your data protection rights?

• It is important that the personal data that the Company holds about each User is accurate and current. Each User should keep the Company informed if its personal data changes.
• By law, each User may have certain rights regarding the personal data that the Company holds about such User and may be entitled to the following:
  • The right to access - You may have the right to request from the Company copies of your personal data. We may charge you a small fee for this service.
  • The right to rectification - You may have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete information you believe is incomplete.
  • The right to erasure - You may have the right to request that the Company erase your personal data, under certain conditions.
  • The right to restrict processing - You may have the right to request that the Company restrict the processing of your personal data, under certain conditions.
  • The right to object to processing - You may have the right to object to the Company’s processing of your personal data, under certain conditions.
  • The right to data portability - You may have the right to request that the Company transfer the data collected to another organization, or directly to you, under certain conditions.
• Users who voluntarily provide their personal data in order for the Company to provide Services do so pursuant to the Company’s User Agreement. The retention, return, transfer, and destruction of personal data provided for such purposes is subject to the Policy and to the terms of such User Agreement. If you make a request, the Company will respond to you within the period prescribed by applicable privacy law. If you would like to exercise any of these rights, please contact us at the information provided below.

Your California privacy rights

• California Civil Code Section 1798.83 permits residents of the State of California to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes. We are required to respond to a customer request only once during any calendar year. To make such a request you should contact the Company at the information provided below. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information sharing that is covered will be included in our response.

Verify your identity

• The Company may request specific information from a User to help the Company confirm its identity and its right to access, and to provide such User with the personal data that the Company holds about it or make its requested changes pursuant to applicable privacy law. Applicable privacy law may allow or require the Company to refuse to provide a User with access to some or all of the personal data that the Company holds about such User, or the Company may have destroyed, erased, or made such User's personal information anonymous in accordance with the Company's record retention obligations and practices. If the Company cannot provide a User with access to its personal information, the Company will inform such User of the reasons why, subject to any legal or regulatory restrictions. In order for the Company to verify a User's identity, it will generally either require the successful login to such User's account and/or the matching of sufficient information a User provides to the Company to such User's personal information maintained within the Company's systems. Although the Company tries to limit the personal data collected in connection with a User request to exercise its rights, certain requests may require the Company to obtain additional personal information from the relevant User. In certain circumstances, the Company may decline a request to exercise a User's right to know and right to deletion, particularly where the Company is unable to verify such User's identity. You consent to an electronic database search by us in order to verify your identity. We shall retain records of the contents and results of such searches in accordance with (this Policy and) all current and applicable laws. We further reserve the right, if considered appropriate at our sole discretion, to provide relevant information regarding you and your transactions to law enforcement agencies. If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. To do so, you must: (1) provide that authorized agent written and signed permission to submit such a request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. We will respond to your authorized agent's request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4121 to 4130. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.

As mentioned above in "Verify your identity," the rest of the content will be included in this section, including the remaining subpoints and content under "Verify your identity."

As mentioned above in "How to contact us," the content will be included in this section, including the subpoints and content under "How to contact us."

How to contact the appropriate authorities

• Should you wish to report a complaint or if you feel that the Company has not addressed your concern in a satisfactory manner, you may contact your local Data Protection Authority.
• In Canada:
  • Office of the Privacy Commissioner of Canada
  • 30, Victoria Street
  • Gatineau, QC K1A 1H3, Canada
  • www.priv.gc.ca/en/
• In the United Kingdom:
  • The Information Commissioner’s Office
  • Wycliffe House, Water Ln
  • Wilmslow SK9 5AF, UK
  • www.ico.org.uk

What are cookies?

• Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit the Site, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

How do we use cookies?

• The Company uses cookies and similar technologies for purposes such as:
  • Authenticating Users;
  • Remembering User preferences and settings;
  • Determining the popularity of content;
  • Delivering and measuring the effectiveness of advertising campaigns;
  • Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services.
• We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those.

How to manage your cookies?

• You can set your browser not to accept cookies, and you can remove cookies from your browser. However, in a few cases, some of the Site features may not function as a result.

Privacy policies of other websites

• The Site contains links to other websites. This Policy applies only to the Site. If you navigate to any other website from a link on the Site, you should review the privacy policy of such website.

Changes to our privacy policy

• It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users' personal information, through a notice on the Website home page or in the Application. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Resources and this Policy to check for any changes.

Data security breach notifications

• LemFI ensures that it appropriately manages any actual or suspected incidents relating to information systems and information within the custody of the organization. In the event of a data security breach that requires us to notify customers, LemFi will send notifications by email. Customers are therefore obliged to keep a registered email address current. Customers are required to promptly notify us of any change in their email address on record by contacting Support@zegidpay.com and providing an updated email address and contact information. A customer’s continued use of LemFi products and services constitutes consent to receive electronic notice in cases of a data security breach.