Privacy Policy

Last Updated: January 1, 2025  |  Effective Date: January 1, 2025

1. Introduction

Zula LLC ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information in connection with our cryptocurrency wallet services, digital asset transfers, and related services (collectively, the "Services").

By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the terms herein, please do not use our Services.

2. Information We Collect

2.1 Identity Verification Information (KYC)

As a registered Money Services Business, we are required by law to collect and verify certain personal information. This includes:

• Full legal name
• Date of birth
• Government-issued photo identification (passport, driver's license, state ID)
• Residential address and proof of address
• Tax identification number (as required)
• Social Security Number (for U.S. persons, where required by law)

2.2 Account and Transaction Information

• Account registration details (email address, phone number)
• Transaction history, including amounts, dates, and counterparties
• Wallet addresses associated with your account
• Source of funds declarations (where required)

2.3 Technical and Usage Information

• IP address and device identifiers
• Browser type and operating system
• Pages visited on our website and time spent
• Log data and error reports

2.4 Communications

• Records of communications you send to us (email, phone)
• Support tickets and correspondence history

3. How We Use Your Information

We use the information we collect for the following purposes:

• KYC / Identity Verification: To verify your identity as required by federal and state law
• Service Provision: To create and manage your account, process transactions, and provide our Services
• Regulatory Compliance: To comply with the Bank Secrecy Act, FinCEN regulations, OFAC requirements, and applicable state laws
• AML Monitoring: To monitor transactions for suspicious activity and file required reports
• Security: To detect, prevent, and investigate fraud and other illegal activities
• Communication: To send you service-related notices and respond to your inquiries
• Legal Obligations: To comply with court orders, subpoenas, and other legal processes

4. How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following circumstances:

• Regulatory Authorities: We are required by law to report certain transactions and information to FinCEN, OFAC, the IRS, and other regulatory agencies
• Law Enforcement: We may disclose information in response to lawful subpoenas, court orders, or law enforcement requests
• Service Providers: We may share information with third-party vendors who assist in providing our Services (e.g., identity verification providers), subject to confidentiality agreements
• Business Transfers: In the event of a merger, acquisition, or sale of assets, customer information may be transferred as part of the transaction
• With Your Consent: We may share information in any other circumstances with your explicit consent

5. Data Retention

We retain personal information for as long as required by law and as necessary to fulfill the purposes described in this policy. Under the Bank Secrecy Act, we are required to retain certain records for a minimum of five (5) years. Identity verification records and transaction records may be retained for longer periods as required by applicable law.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, and security monitoring. However, no system is entirely secure, and we cannot guarantee absolute security of your information.

7. Your Rights

Depending on your state of residence, you may have certain rights regarding your personal information, including the right to access, correct, or delete information we hold about you. Please note that our ability to fulfill certain requests may be limited by our legal obligations, including BSA recordkeeping requirements.

To exercise any applicable rights, please contact us at support@zulallc.it.com.

8. Cookies and Tracking

Our website may use cookies and similar tracking technologies for operational purposes, including maintaining session state and security. We do not use cookies for advertising or third-party tracking purposes. You may configure your browser to refuse cookies; however, this may affect the functionality of our Services.

9. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us immediately at support@zulallc.it.com.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post the updated policy on our website with a revised effective date. Your continued use of our Services following any changes constitutes acceptance of the updated policy.

11. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

Zula LLC
15035 Military Rd S, SeaTac, WA 98188
Email: support@zulallc.it.com
Phone: +1 (206) 995-8492