Privacy Policy

Updated: November 30, 2023


Your trust is very important to us, we are well aware of the importance of personal information to you,and we will take corresponding security protection measures in accordance with the requirements of laws and regulations, and try our best to protect your personal information as safe and controllable. In light of this, as a provider of Zinvest (or simply "we", "us") and a "Policy") we have developed this Privacy Policy (hereinafter referred to as the "Policy") and remind you that:

This Policy applies to your use of Zinvest's products and services in any way. Before using Zinvest products or services, please be sure to carefully read and thoroughly understand this Policy, and use the relevant products or services after confirming that you fully understand and agree to them. Once you start using Zinvest products or services, it means that you have fully understood and agreed to this Policy. If the products or services provided by Zinvest are used in the products or services of our affiliates but do not have a separate privacy policy, this Policy will also apply to that part of the products or services.


This Privacy Policy will help you understand the following:

1.How we collect your personal information.

2.How we use the collected information.

3.How we share, transfer, and disclose your personal information.

4.How we protect your personal information.

5.How we store information.

6.Your rights to manage your own information.

7.How we protect the information of minors.

8.How your personal information may be transferred globally.

9.The types of information we may send to you.

10.Information you share with us.

11.How this policy is updated.

12.The scope of this policy.


We are committed to maintaining your trust and adhere to the following principles to protect your personal information: the principle of consistency between rights and obligations, the principle of clear purposes, the principle of choice and consent, the principle of minimum necessity, the principle of ensuring security, the principle of subject participation, and the principle of openness and transparency.


Ⅰ.Purpose, Method, and Scope of Obtaining Sensitive Information

1.of the sensitive information obtained1. In order to provide you with services, maintain the normal operation of Zinvest products and services, improve and optimize our service experience, and protect the security of your account, we will collect the information you voluntarily provide, authorize to provide, or provide based on your request when you register and use products and services, as well as the information generated based on your use of Zinvest services, for the following purposes and methods in this Policy:

(1)When you sign up for Zinvest with your mobile phone number and verification code, we will collect your mobile phone number. Mobile phone numbers are sensitive information, and such information is collected to meet the requirements of the online real-name system of relevant laws and regulations.

(2) When you need to use the photo when you use the Zinvest profile picture editing function and account opening, if you choose to use the "photo" or "photo" method, Zinvest will use the camera permission of the device; If you use the "Select from Album" method, Zinvest will use the device's photo permissions. Saving useful images found in Zinvest to your album when you need it will also use your device's photo permissions. The information about the photos and videos you upload will be stored on our servers, as storage is necessary to enable this function.

(3) When you use the reminder or major event notification function of Zinvest's market system, Zinvest will use the calendar permission of the device so that you can obtain relevant information in a timely manner. If you deny access, you will not be able to use the reminder feature, but it will not affect your use of other services of Zinvest.

(4) In order to ensure that you can normally receive and use the relevant market rights and services, we will use the fund account number, IP address, third-party account number, avatar, nickname, etc. provided by you to identify the region or account validity. If you do not agree with the above content, it may affect the validity judgment of the region or account, and then affect your access to and use of relevant market rights and services.

(5) When you use the push message service or the sharing function, we need to obtain the list of your software installations to determine the process used in the push and whether the client to share is installed. We do not store this information and do not use it for any purpose other than this function.

(6) When you use Zinvest, in order to ensure your normal use of our services, understand the adaptability of products, identify abnormal account status, and improve and optimize our service experience and protect the security of your account, we will collect information about the services you use and how you use them, and associate such information, including:

(i) Log information: When you use the products or services provided by our website or client, we will automatically collect the details of your use of our services and save them as relevant web logs. For example, your login account, search query content, IP address, browser type, telecommunications operator, network environment, language used, date and time of access, and your web browsing history, push open record, stay time, refresh record, publication record, follow and share. We will obtain the storage permission of your device to save the aforementioned log information.

(i) Log information: When you use the products or services provided by our website or client, we will automatically collect the details of your use of our services and save them as relevant web logs. For example, your login account, search query content, IP address, browser type, telecommunications operator, network environment, language used, date and time of access, and your web browsing history, push open record, stay time, refresh record, publication record, follow and share. We will obtain the storage permission of your device to save the aforementioned log information.

2.In addition, in accordance with relevant laws, regulations and national standards, we may collect and use your relevant personal information without your authorization and consent under the following circumstances:

(1) directly related to national interests such as national security and national defense security;

(2) It is directly related to major public interests such as public safety, public health, and public knowledge;

(3) Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;

(4) For the purpose of protecting the life, property, reputation and other major legal rights and interests of you or other individuals, but it is difficult to obtain the consent of the individual;

(5) The personal information collected is disclosed to the public by yourself;

(6) Personal information is collected from legally and publicly disclosed information, such as lawful news reports, government information disclosure, and other channels;

(7) Necessary for the conclusion and performance of a contract at your request;

(8) It is necessary to maintain the safe and stable operation of the products or services provided, such as discovering and disposing of faults in products or services;

(9) Where it is necessary to carry out lawful news reporting;

(10) Where it is necessary to carry out statistical or academic research in the public interest, and when it provides the results of academic research or descriptions to the outside world, the personal information contained in the results is de-identified;

(11) Other circumstances stipulated by laws and regulations.

3.Please understand that the functions and services we provide to you are constantly updated and developed, and if a function or service is not included in the above description and your information is collected, we will separately explain to you the content, scope and purpose of information collection through page prompts, interactive processes, website announcements, etc. 

4.We may obtain relevant information from affiliates and third-party partners that you are authorized to share. We will comply with relevant laws and regulations, and in accordance with the agreement with affiliates or third-party partners, and we believe that they will provide such servicesCollect and use your information on the premise that the source of the information is legitimate.

5.The above information provided by you may contain your personal sensitive information, such as bank account number, transaction records, virtual property information, system account number, email address and its related password, telephone number, web browsing history, and location information. Please be cautious and pay attention to your sensitive personal information, and you agree that your sensitive personal information may be handled for the purposes and in the manner described in this Privacy Policy.


Ⅱ.How We Will Use the Information

We CollectBased on the provisions of relevant national laws and regulations, as well as the purpose of providing you with services, improving service quality, and providing you with a safe, smooth, efficient and personalized experience, we will use the collected information for the following purposes under the premise of strictly abiding by the provisions of laws and regulations, this Privacy Policy and other agreements with you.

1. To provide you with various related services;

2. To enable us to understand how you access and use relevant services to meet your personalized needs;

3. Development and service optimization. For example, when our system fails, we will record and analyze the information generated during the system failure to optimize our services;

4. Evaluate and improve our promotion effect, etc.;

5. Management software. For example, software certification, software upgrades, etc.;

6. Invite you to participate in surveys about our services;

7. To prevent, detect, and investigate fraud, infringement, security endangerment, illegality, or violations of agreements, policies, or rules with us or our affiliates, and to protect the legitimate rights and interests of you, other users or the public, and us or our affiliates, we will use or integrate your personal information, service usage information, device information, log information, and our affiliates, The Partner obtains the information authorized by you or shared in accordance with the law to comprehensively determine the risks of your account and transactions, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

8. In order to ensure the security of the service and help us better understand the operation of our application, we may record relevant information, such as the frequency of your use of the application, crash data, overall usage, performance data, and the source of the application, but we will not combine the information we store in the analysis software with the personally identifiable information you provide in the application;

9. Other purposes authorized by you.

If we use your personal information beyond the scope of the purpose stated at the time of collection and are directly or reasonably related, we will inform you again and obtain your express consent before using your personal information.


Ⅲ.How We Share, Transfer, and Publicly Disclose Your Personal Information

1. SharingWe

will not share your personal information with companies, organizations and individuals other than Zinvest service providers, except in the following circumstances:

(1)Sharing with your consent:After obtaining your explicit consent, we will share your personal information with other parties.

(2) Sharing under statutory circumstances: We may share your personal information externally in accordance with laws and regulations, litigation and dispute resolution needs, or according to the requirements of administrative and judicial authorities in accordance with the law.

(3) Only by disclosing your information (such as your IDFA, network identifier, IP address, IMEI, MAC address and other relevant information) can we provide the third-party products and services you request, or use Zinvest to conduct data analysis or research and improve our products and services. At present, the third-party SDK services we access mainly include the following types:

● Provide IM message communication function;

● Provide data-free services;

● Report and analyze user behavior data;

● To provide payment services;

● Report the crash information of the program;

● Perform performance statistics;

● To provide browser services;

● For advertising statistics and monitoring;

● For third-party account login;

● To facilitate the sharing of Zinvest content with third-party platforms;

Such access to third-party services is operated by the relevant party and is subject to the third party's own terms of service and information protection statement (not this Privacy Policy)

If you are complained by others or you complain to others, we will provide your identity information and other complaint information to the relevant regulatory authorities for the purpose of resolving complaints and disputes. However, it is not expressly prohibited by laws and regulations.

(5) To exchange information with other companies and organizations in order to comply with laws, enforce or apply the conditions of use and other agreements of our services, or to prevent illegal activities such as fraud and reduce credit risk.

(6) Sharing with our affiliates: Your personal information may be shared with affiliates of Zunjia Group. We will only share personal information that is necessary and is subject to the purposes stated in this Privacy Policy. If the affiliate wants to change the purpose of processing personal information, it will ask for your authorization and consent again. Our affiliates include, but are not limited to, Velox Technology Limited, Velox Securities International Limited, Zunjia Asset Management Limited, Velox Clearing LLC, Zinvest FinancialService LLC

(7) Sharing with authorized partners: For the purpose stated in this Policy, some of our services will be provided by authorized partners. We may share some of your personal information with our partners to provide better customer service and user experience. For example, when you participate in a reward program we offer, we must share your personal information with our partners in order to arrange for the issuance of rewards or to arrange for partners to provide services. We will only share your personal information for legitimate, legitimate, necessary, specific and explicit purposes, and will only share the personal information necessary to provide services. Our partners are not authorized to use the shared personal information for any other purpose.

(8) Share with a third party in accordance with the relevant agreements with you in accordance with the Service Agreement of this software.

(9) Other agreements between you and us regarding information sharing.

We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

2. Except

for the following circumstances, we will not actively transfer your personal information to:

(1) the relevant operations have obtained your express consent in advance;

(2) In the event of a merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy, otherwise we will require the company or organization to seek your authorization and consent again;

(3) Other situations where it is necessary to transfer your personal information in accordance with the provisions of laws and regulations or the requirements of competent authorities.

3.Public disclosure

will only publicly disclose your personal information under the following circumstances:

(1) after obtaining your explicit consent;

(2) Public disclosure based on law: We may publicly disclose your personal information under the mandatory requirements of laws, legal procedures, litigation or government authorities;

(3) If we determine that you have violated laws and regulations or seriously violated the relevant rules of the Zinvest Agreement, or in order to protect the personal and property safety of Zinvest, its affiliates, users or the public from infringement, we may disclose your personal information with your consent in accordance with the laws and regulations or the relevant rules of the Zinvest Agreement. This includes the relevant violations and the actions already taken against you by Zinvest.

4. Exceptions to obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information:

(1) Related to national security and national defense security;

(2) Where it is related to public safety, public health, or major public interests;

(3) Where it is related to criminal investigation, prosecution, trial, or enforcement of judgments;

(4) For the purpose of protecting the life, property and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain the consent of the individual;

(5) Personal information that you disclose to the public;

(6) Personal information is collected from legally and publicly disclosed information, such as lawful news reports, government information disclosure, and other channels.

(7) Please note that, in accordance with the law, the sharing or transfer of anonymized personal information and ensuring that the data recipient cannot recover and re-identify the personal information subject is not an act of external sharing, transfer and public disclosure of personal information, and the storage and processing of such data will not need to be notified to you and your consent will be obtained.

Ⅳ.How We Protect Your Personal Information

We take every precaution to protect your personal information from loss, theft, misuse, unauthorized access, disclosure, alteration or destruction. To ensure the security of your personal information, we have strict information security regulations and procedures in place, and we have a dedicated information security team to strictly enforce the above measures within the company.

We will take all reasonably practicable steps to ensure that no irrelevant personal information is collected. We will only retain your personal information for as long as is necessary to achieve the purposes stated in this Policy, unless it is necessary to extend the retention period or permitted by law. 

The Internet is not a completely secure environment, and emails, instant messaging, and communication with other Zinvest users are not encrypted, so we strongly recommend that you do not send personal information through such means. 

We will establish an emergency response plan, and in the event of a security incident such as personal information leakage, we will activate the emergency response plan to prevent the security incident from expanding. We will promptly inform you of the relevant circumstances of the incident by email, letter, telephone, push notification, etc., and if it is difficult to inform the Personal Data Subject one by one, we will take reasonable and effective measures to make an announcement. The Internet environment is not 100% secure, and although we have these security measures, please be aware that there are no "perfect security measures" on the Internet, and we will do our best to ensure the security of your information.

Ⅴ.How we store information

1.In accordance with relevant laws and regulations, we will store your personal information collected within the territory of the People's Republic of China within the territory of the People's Republic of China and keep such information strictly confidential in accordance with the law. In some cases, if it is necessary to transfer the relevant users' personal information collected in China to overseas institutions, we will implement it in accordance with laws, administrative regulations and relevant regulatory departments, and require the overseas institutions to keep confidential your personal information obtained through effective measures such as signing agreements and on-site verification.

2.In general, we will only retain your personal information for the minimum time necessary to achieve the purpose. However, we may change the storage period of personal information in the following circumstances to comply with legal requirements:

(1) to comply with applicable laws and regulations;

(2) to comply with court judgments, rulings or other legal procedures;

(3) To comply with the requirements of relevant government agencies or legally authorized organizations;

(4) Purposes reasonably necessary for the implementation of relevant service agreements or this Policy, safeguarding the public interest, and protecting the personal and property safety or other legitimate rights and interests of our customers, us or our affiliates, other users or employees.

 3.How do I cancel my account? Go to the My Page of the APP, select Account & Security, and select Cancel Account.

Ⅵ.Your Rights to Manage Your Personal Information

1.manage your own information1. During your use of Zinvest's services, in order to make it more convenient for you to access, correct, and delete your personal information, and to protect your right to withdraw your consent to the use of personal information and cancel your account, we provide you with the following operation settings in the product design, including but not limited to:

(1) access your account information, if you wish to access or edit the profile information in your account, change your password,Bind the device, etc., you can do this by visiting Zinvest-[My];

(2) Modify personal information, you can do so by visiting Zinvest-[My];

2.If you find that we have collected and used your personal information, it is in violationIf you have violated the provisions of laws and administrative regulations or violated the agreement with you, you can request the deletion of your personal information collected under the violation by contacting us.

3.If you find that your personal information collected and stored by us is incorrect, you can contact us through service@us.zinvestglobal.com and request us to correct it in a timely manner.

Ⅶ.How we protect minors' information

We attach great importance to the protection of the personal information of minors. In accordance with the provisions of relevant laws and regulations, if you are a minor under the age of 18, it is recommended that your parents or guardians carefully read this Policy and submit your personal information after obtaining the consent of your parents or guardians, and at the same time recommend that you use our services under the guidance of your parents or guardians, otherwise you must immediately terminate the submission of information or terminate the use of our services, and notify us of this situation as soon as possible, so that we can take effective measures. At the same time, we will only use or disclose the information of minors when permitted by laws and regulations, with the explicit consent of parents or guardians, or when it is necessary to protect your rights and interests. If you are the parent or guardian of a minor, if you have any questions about the personal information of the minor under your guardianship, please contact us through the contact information on the first page of this Privacy Policy or Article 14.


Ⅷ.How your personal information is transferred

globallyIn principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. Since we provide products or services through resources and servers around the world, this means that, after obtaining your authorization and consent, your personal information may be transferred to or accessed from the overseas jurisdictions of the country/region where you use the products or services. Such jurisdictions may have different data protection laws, or may not have such laws at all. In such cases, we will ensure that your personal information receives an adequate level of equivalent protection within the territory of the People's Republic of China. For example, we will ask for your consent to the cross-border transfer of personal information, or implement security measures such as data de-identification before cross-border data transfers.


Ⅸ.The Information We May Send to You

1.When you use our Services, we may send you emails, text messages, newsletters, or push notifications. You can opt out of your subscription on your device by following our prompts.

2.We may issue service-related announcements to you when necessary (e.g., when a service is suspended due to system maintenance). You may not be able to cancel these service-related announcements that are not advertisements in nature.

Ⅹ.Integrated third-party SDKs

1."In order to provide you with one-click sharing service, our product integrates Umeng+ U-Share SDK, which will collect your device identification information (such as IMEI/android ID/IDFA, etc.) and the public information of your social account that you need to share, so as to complete the one-click sharing service. For the security of your information, we have entered into data security and confidentiality agreements with third-party SDK service providers, and these companies will strictly abide by our data privacy and security requirements. We will not share your personally identifiable information with them unless we have your consent to do so. In order to help you better understand the types and purposes of data collected by [Umeng+] and how to protect your personal information, you can log in tohttps://www.umeng.com/policy to learn about the privacy policy of [Umeng+].

2.In order to be able to push important information to you in a timely manner, we use a third-party push SDK module, which may still be stored independently by other users or unaffiliated third parties not under our control.

Use SDK name: Pigeon SDK

Service Type: Push Message Service

Type of personal information collected: Device informatio

Ⅺ.How to update this PolicyWe will update

this Privacy Policy in a timely manner in accordance with the requirements of relevant laws and regulations, business changes or other necessary circumstances, without your explicit consent, we will not reduce your rights in accordance with this Privacy Policy, and we will publish the changes made to this Policy on this page. and notify the revised policy by posting on the official website or other means that may be appropriate for you to receive notice. In this case, if you continue to use our services, you agree to be bound by the revised and updated policy.

Ⅻ.Scope of Application ofthis Policy

1.Except for the services that we have expressly stated that require our other separate privacy policies or terms to be formulated, this Policy applies to all services provided by all companies within the Zunjia Group that you use. However, some services have set their own specific privacy guidelines/notices as needed, and if there is any inconsistency between this Policy and the privacy guidelines/statements of a specific service, the specific privacy guidelines/statements shall prevail.

2.The headings of all clauses of this Policy are for convenience only and have no actual meaning, and cannot be used as the basis for the interpretation of the meaning of this Policy.