Zabo
Privacy Policy

Last Updated: April 2, 2020

Modular, Inc. d/b/a Zabo (“Zabo,” “we,” “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy. This privacy policy explains our policies and procedures regarding the collection, use, disclosure, and security of certain information that we receive, including information that would be considered “personal data” within the meaning of the EU General Data Protection Regulation (“GDPR”). As used in this privacy policy, “personal data” refers to information about an identified or identifiable individual, such as their name or email address.

Zabo provides an API-driven platform (the “API”) that enables users (“End Users” or “you”) to aggregate their account information and data, from the data sources where these End User’s End User Data (as defined below) are stored (as modified from time to time, the “Zabo Services”). “End User Data” means financial account information and data, including (a) account name, account type and public wallet or deposit addresses, (b) information related to account balances account transactions, in both amounts and in other currency equivalents (e.g. US Dollars), (c) information about account transactions, including amount, date, time, type, location, price, cost basis, fees, quantity, sender and recipient and (d) information about the End User as the account owner, such as publicly provided name.

Zabo also provides the API, the Zabo Services, the website at https://www.zabo.com (the “Website”), the dashboards, the related tools and other products or services (collectively the “Developer Services”) to our developers and customers (collectively, “Developers” or “you”) that can use these Developer Services to integrate the API and Zabo Services into their applications or third-party applications (collectively, the “Zabo Enabled Applications”).

End Users can currently only access and use their End User Data through a Zabo Enabled Application.

For the purposes of the GDPR, Zabo is considered the data controller in some situations and the data processor in other situations. When we are acting as the data controller, we are responsible for deciding how we use the information that we hold. When we are acting as the data processor, Developers and their End Users are responsible for deciding how we use the information that we hold. We are a Delaware corporation registered in the United States with an office at Modular, Inc. d/b/a Zabo, 251 SW Wilshire Blvd, Ste 124, Burleson, TX 76028.

The GDPR applies to you if you are located in the European Economic Area, the United Kingdom or Switzerland (an “EEA Individual”).

Please note that by accessing and using the API, the Zabo Services, the Developer Services and the various related services, features, functions, software, applications, websites and networks associated with Zabo (together with the API, the Zabo Services and the Developer Services, collectively, the “Services”), you are accepting the practices described in this privacy policy, subject to any rights or restrictions that might apply under the GDPR if you are an EEA Individual, including the rights described in the European Privacy Rights for EEA Individuals provisions below. This privacy policy is incorporated by reference into (a) the Terms of Service for End Users that govern the access and use of the API, the Zabo Services and the other Services and (b) the Terms of Use for the Developers or the subscription agreement for certain other customers that govern (i) the access and use of the Developer Services (or other similar services) and the other Services and (ii) the provision of the API and the Zabo Services to End Users through a Zabo Enabled Applications (collectively, the “Terms”).

This policy describes the types of information we may collect from you or that you may provide when you access or use the API, the Zabo Services, the Developer Services or any of the other features, functions, services, and products, and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect or may collect:

It does not apply to information collected by:

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your only choice is not to use the API, the Zabo Services, the Developer Services or any of the other Services. By accessing or using any of the Services, you agree to this privacy policy. This policy may change from time to time. Your continued use of the API, the Zabo Services, the Developer Services and/or any of the other Services, after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Minors under the Age of 18

None of the Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Zabo Services or the other Services. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on or through any of the Services or any of its features or register on use any of the interactive or public comment features of any of the Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name, username you may use or any pictures of you. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at support@zabo.com.

Information We Collect About You and How We Collect It

We collect or may collect several types of information from and about users of the API, the Zabo Services, the Developer Services and the other Services, including:

For End Users:

For Developers:

We collect this information:

Certain transactions may also involve you calling us or our calling you. Please be aware that we may monitor, and in some cases, record such calls for staff training or quality assurance purposes.

Data Minimization

We take every reasonable step to limit the volume of your personal data that we process to what is reasonably necessary.

We do not Engage in Automated Decision-making without Human Intervention

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

Consequences of not providing Personal Data

You are not required to provide all personal data identified in this privacy policy to interact with us offline, but if you do not provide the personal data, we may not be able to respond to your requests, provide access to the Developer Services, or provide you with marketing that we believe you would find valuable.

Use of Cookies and Other Tracking Technologies.

The technologies we use for automatic data collection may include:

Do Not Track Policy

Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services. At present, no universally accepted standards exist on how companies should respond to do-not-track signals. In the event a final universally accepted standard is established, we will assess and provide an appropriate response to these signals

Third-party Responsibilities and Services.

We may use or partner with third-parties, agents or contractors for various purposes in connection with our business and operations (collectively, “Service Providers”), including, storage of access credentials and End User Data, the provision of the API and the Zabo Services through a Zabo Enabled Application and billing and payment services. In the course of performing these responsibilities and providing such services, these other companies may have access to your personal information. We may also share information, including your personal information, with these Services Providers in order to enable them to perform these responsibilities and to provide these services. Many Services Providers have adopted their own privacy policies, which are not subject to control by Zabo. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information. We do not list our current Service Providers because they change from time to time. If you would like the names of any of Service Providers, please email us at support@zabo.com.

We use commercially reasonable efforts to ensure that Service Providers that have access to your personally identifiable information in connection with providing services are required to keep your personal information confidential and are not permitted to use this personal information for any purpose other than to fulfill the services in connection with the Zabo Services, the Developer Services or the other Services.

Google Analytics

We use a tool called “Google Analytics” to collect information about use of the Services. Google Analytics collects information such as how often users visit the Website or use the other Services, what pages they visit when they do so, and what other sites they used prior to coming to the Website. We use the information we get from Google Analytics to improve the API, the Zabo Services, the Developer Services and the other Services and their related features, functionality and performance. Google Analytics collects only the IP address assigned to you on the date you visit the Website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Website by disabling cookies on your browser.

DoubleClick: We may use Google Analytics remarketing codes to log when users view specific pages or take specific actions on a website.

Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions on its website.

Intercom

We use Intercom (a) to collect data for analytics purposes when you visit our Website or use any of the Services and (b) as our message and customer service tool. For information about Intercom’s Privacy Policy click here.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data:

For End Users:

For Developers:

Some of the information that we collect automatically is statistical data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Developer Services and the other Services, and to deliver a better and more personalized service, including enabling us to:

Storage and Transfer of Your Information

We may store any data or other information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us, our affiliates, agents or Service Providers. If you access or use the API, the Zabo Services, the Developer Services or any of the other Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by Zabo and you. By allowing Zabo to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open and view content faster.

Although users from all over the world may access the API, the Zabo Services, the Developer Services and the other Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.

Disclosure of Your Information

We may disclose aggregated or anonymized information about our users, and information that does not include any personal data, without restriction.

We may disclose End User Data to our Developers in connection with provision of the Zabo Services through their Zabo Enabled Application.

We may disclose personal data that we collect or you provide as described in this privacy policy:

We may also disclose your End User Data or personal data:

We may share information that is anonymized or in an aggregated form that does not include any personal data about you and we may use and share any such information for any purpose without restriction so long as it does not violate the terms of this privacy policy or any applicable law. We may use, disclose or sell that anonymized or aggregated information without restriction so long as we do not disclose any of your personal data or violate the terms of this privacy policy or any applicable law.

Choices About How We Use and Disclose Your Personal Data

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your personal data:

We do not control third parties’ collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe’s Preference Manager at http://preferences-mgr.truste.com.

Our Legal Bases for Handling Your Personal Data

GDPR and the laws in some other jurisdictions require companies to tell you about the legal bases that they rely on to use or disclose your personal data. To the extent that those laws apply, we rely on the following legal grounds to process your personal data:

Accessing and Correcting Your Personal Data

End Users may change, correct or delete any personal data that they have provided to the Developer providing the Zabo Enabled Application through which you are accessing the API and the Zabo Services as directed by such Developer.

Developers may change, correct or delete any personal data that they have provided to us through their dashboard or by emailing us at support@zabo.com.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@zabo.com or write to us at: Modular, Inc. d/b/a Zabo, 251 SW Wilshire Blvd, Ste 124, Burleson, TX 76028.

European Privacy Rights for EEA Individuals.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your personal data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data. You can also exercise the right by contacting us directly.

If you are an EEA Individual and GDPR applies and we hold your personal data in our capacity as a controller, you may request that we:

We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern, as we would be happy to try to resolve it directly. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

If you are an EEA Individual in France, you also have the right to set guidelines for the retention and communication of your personal data after your death.

If you reside in a jurisdiction other than the European Economic Area, you may also have similar rights to the above. Please contact us at support@zabo.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

In addition, where you believe that we have not complied with its obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office. Here is a list of local data protection authorities in EEA countries.

You can exercise any of these rights by contacting us at support@zabo.com or write to us at: Modular, Inc. d/b/a Zabo, 251 SW Wilshire Blvd, Ste 124, Burleson, TX 76028.

How Long We Store Your Personal Data

We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfill the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Data Security

We understand that the security of your access credentials, End User Data and personal data is very important.

For End Users, Zabo will encrypt the access credentials that you use to access your End User Data and employ other commercially reasonable security measures to protect End User Data in accordance with good industry practice and all applicable laws.

For Developers, we provide reasonable administrative, technical, and physical security controls to protect your personal data.

Despite our efforts, however, no security controls are 100% effective. Zabo cannot ensure or warrant the security of your credentials, End User Data or personal data. Any transmission of your credentials, End User Data or personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on or through the Website.

The safety and security of your data also depends on you. Where you have chosen (or we have given you) a password for access to and use of certain parts of the Developer Services, the API, the Zabo Services and/or the other Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the home pages of for at least 30 days. If we make material changes to how we treat our users’ personal data that are materially less protective than provided in this policy, we will use reasonable efforts to notify you by e-mail to the e-mail address specified in your account and/or through a notice on the home pages of and to attempt to get your consent to the changes. The date the privacy policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting and this privacy policy to check for any changes. Like our Terms, of which this privacy policy is a part, your use, and/or continued use after our efforts to contact you, of the API, the Zabo Services, the Developer Services or any of the other Services, means that you agree to be bound by such changes.

Survival

The policies indicated in this privacy policy will remain effective, even if the applicable Terms and the other agreements between us are terminated and you are no longer using the API, the Zabo Services, the Developer Services or any of the other Services.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices or need to reach us for any other reason, you may contact us by e-mail at support@zabo.com or by mail at Modular, Inc. d/b/a Zabo, 251 SW Wilshire Blvd, Ste 124, Burleson, TX 76028.