Privacy Policy - ZStack Capital Affiliate Program

In order to receive information about your Personal Data, the purposes for which the Data is collected and processed, and the parties with which the Data is shared, please contact the Owner.

Owner and Data Controller

ZStack Capital is the Owner and Data Controller of all Personal Data collected through this Application.

Types of Data Collected

The Owner does not provide a detailed list of Personal Data types collected.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in this document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published, or shared through this Application and confirm that they have obtained the third party's consent to provide the Data to the Owner.

Mode and Place of Processing the Data

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of the Data. Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain persons involved with the operation of this Application (such as in administration, sales, marketing, legal, or system administration) or to external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, or communications agencies) appointed as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal Basis of Processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt‑out”), without having to rely on consent or any other legal basis. This does not apply when processing is subject to European data protection law.
  • Provision of Data is necessary for the performance of an agreement with the User and/or for any pre‑contractual obligations thereof.
  • Processing is necessary for compliance with a legal obligation to which the Owner is subject.
  • Processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Owner.
  • Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement or is necessary to enter into a contract.

Place of Processing

The Data is processed at the Owner's operating offices and in any other locations where the parties involved in the processing are based. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. For details on the place of processing of such transferred Data, please refer to the relevant sections of this document.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization (such as the UN) and about the security measures taken by the Owner to safeguard their Data.

Retention Time

Personal Data shall be processed and stored for as long as required by the purposes for which it was collected.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the Owner’s legitimate interests shall be retained as long as needed to fulfill those purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
  • The Owner may retain Personal Data for a longer period if the User has given consent, as long as that consent is not withdrawn. The Owner may also be obliged to retain Personal Data for a longer period whenever required for legal obligations or by order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, rights to access, erasure, rectification, and data portability cannot be enforced after the retention period expires.

The Rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to:

  • Withdraw consent at any time.
  • Object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access their Data, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data.
  • Verify the accuracy of their Data and request corrections.
  • Restrict the processing of their Data under certain circumstances (in which case the Owner will only store the Data).
  • Obtain the deletion or removal of their Data under certain circumstances.
  • Receive their Data in a structured, commonly used, machine-readable format and, if technically feasible, have it transmitted to another controller without hindrance.
  • Lodge a complaint with a competent data protection authority.

Details about the Right to Object

If Personal Data is processed for public interest, in the exercise of official authority, or for the purposes of legitimate interests pursued by the Owner, Users may object by providing a ground related to their particular situation.

Note that for direct marketing purposes, Users may object at any time without providing any justification.

How to Exercise These Rights

Requests to exercise User rights can be directed to the Owner using the contact details provided below. These requests are free of charge and will be addressed as soon as possible, and at the latest within one month.

Additional Information

Legal Action: The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading up to legal action arising from improper use of this Application or its services. The User acknowledges that the Owner may be required to reveal personal data upon request by public authorities.

System Logs and Maintenance: For operation and maintenance purposes, this Application and any third-party services may collect system logs and other Personal Data (such as IP addresses) for troubleshooting and performance monitoring.

Do Not Track: This Application does not support “Do Not Track” requests. To determine whether any third-party services honor these requests, please refer to their respective privacy policies.

Changes to this Privacy Policy: The Owner reserves the right to modify this privacy policy at any time by updating this page and/or sending notice to Users via available contact information. Users are encouraged to review this policy periodically.

Contact Information

If you have any questions regarding this privacy policy or wish to exercise your rights, please contact the Owner at [email protected].

Latest update: January 1, 2025