> For the complete documentation index, see [llms.txt](https://zerotick-trade.gitbook.io/documentation.v1.2/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://zerotick-trade.gitbook.io/documentation.v1.2/zerotick-ambassador-program-privacy-policy.md). # ZeroTick Ambassador Program Privacy Policy **Effective Date: 28.04.2026** ### 1. About this Policy This Ambassador Program Privacy Policy(**"Policy"**) explains how the **ZeroTick team** (**"ZeroTick"**, **"we"**, **"us"**, **"our"**) collects, uses, shares, and protects personal data in connection with the ZeroTick Ambassador Program (the **"Program"**). This Policy supplements the general ZeroTick [Privacy Policy](https://zerotick-trade.gitbook.io/documentation.v1.1/privacy-policy). Where there is a conflict in respect of the Program, **this Policy governs**. For the purposes of UK GDPR / EU GDPR (where applicable), the data controller for Program data is ZeroTick, the operator of the Program. Contact for data protection: . *** ### 2. Data we collect #### 2.1 Application data (via the application form) * Full name * Email address * Country / time zone * Primary platform handle * Other platform handles (X, TikTok, YouTube, Discord, Other) * Proof-of-engagement URL * Follower count on primary platform * Engagement rate over recent posts * Tier you are applying to * Why-apply text * X Premium (blue check) subscription confirmation * Briefing acknowledgement * Technical metadata (IP address, user-agent, timestamp) #### 2.2 Verification data * Public information from social-media accounts and content URLs you submit * Communications with ZeroTick during review * Onboarding-call recordings or notes (with your consent) * KYC / identity-verification data, where required for ZTCK distribution #### 2.3 Participation data * Activity metrics (content publication frequency, content URLs, engagement metrics) * Community-channel activity * Performance assessments by the Program team * Communications with ZeroTick * Records of ZTCK accruals, multipliers, and distributions * Records of referrals and referral activity #### 2.4 Tax / payment data * Wallet addresses for ZTCK distribution * Tax-identification information where required by law *** ### 3. Why we collect it (lawful bases) #### 3.1 To evaluate your application Lawful basis: **your consent** and our **legitimate interest** in evaluating prospective Participants. #### 3.2 To operate the Program Onboarding, communicating, tracking participation, calculating discretionary Recognition, distributing ZTCK at TGE, managing referrals. Lawful basis: **performance of the Ambassador Program Terms** (where applicable), **legitimate interest**, **consent**, and **legal obligation** (for KYC/AML). #### 3.3 To verify ongoing eligibility Lawful basis: our **legitimate interest** in ensuring eligibility criteria continue to be met. #### 3.4 To comply with legal obligations Tax reporting, sanctions checks, AML/CTF, regulatory inquiries, court orders. Lawful basis: **legal obligation**. #### 3.5 To improve the Program Aggregate analytics, trend analysis, performance reviews. Lawful basis: **legitimate interest**. #### 3.6 To send you Program communications Application status, onboarding, ongoing Program updates, Briefing/Handbook updates. Lawful basis: **consent** or **legitimate interest**. *** ### 4. Who we share it with #### 4.1 Service providers (data processors) * **Supabase** (database hosting, US) — application data, participation records, including the IP address and browser user-agent recorded with your submission. * **Resend** (transactional email) — your name and email for sending Program emails. * **Discord** (team notifications) — your name, tier, key application details, sent to a private internal Discord channel for the Program team. * **Google (Google Sheets via Google Apps Script)** — a copy of application rows is mirrored to a private team spreadsheet for review and tracking. * **Cloudflare (Turnstile bot protection)** — when you submit the application form, Cloudflare Turnstile processes technical browser signals to distinguish humans from automated bots. Cloudflare acts as a processor for this check. * **Vercel** (hosting and serverless functions) — your application form submissions transit through Vercel infrastructure. * Future service providers we engage in good faith — listed in this Policy or notified in advance. All processors are contractually bound to process data only on our instructions and to maintain appropriate security. #### 4.2 ZeroTick personnel Members of the ZeroTick team responsible for operating the Program — founders, Program leads, content reviewers, finance / tax personnel. #### 4.3 Public-facing recognition (with your consent) If you consent (e.g., as part of testimonial collection), we may publish your name, handle, photo, tier, and a quote on ZeroTick's public properties. We will not do this without explicit consent. #### 4.4 Legal recipients * Regulators, law-enforcement, courts where required by law. * Tax authorities for required reporting. * Sanctions screening providers. * Potential acquirers in connection with a corporate transaction (subject to confidentiality undertaking). #### 4.5 We do not sell your data We do not sell personal data and do not share it with third parties for their independent marketing purposes. *** ### 5. Where we store data and international transfers Personal data is stored on infrastructure located primarily in the United States (Supabase, Resend, Vercel). When you submit data from outside the US, your data is transferred internationally. For data subject to UK GDPR / EU GDPR, transfers to non-adequate jurisdictions are protected by Standard Contractual Clauses where applicable. You may request a copy of these clauses. *** ### 6. How long we keep it | Data category | Retention | | -------------------------- | -------------------------------------------------------------- | | Declined-application data | 90 days from decision, then deleted | | Active-Participant data | Duration of participation + 7 years (for tax / audit purposes) | | Removed-Participant data | 7 years from removal | | Tax / KYC data | As required by applicable law (typically 5–10 years) | | Internal communications | 3 years | | Aggregate / analytics data | Indefinite, anonymised | We may retain data longer if required by law (e.g., to defend a legal claim). *** ### 7. Your rights Depending on your jurisdiction, you may have the right to: (a) **Access** the personal data we hold about you; (b) **Rectify** inaccurate data; (c) **Delete** your data ("right to be forgotten") — subject to retention obligations and ongoing-Program needs; (d) **Object to processing** (especially profiling and direct marketing); (e) **Restrict processing** in certain circumstances; (f) **Data portability** — receive your data in a structured, machine-readable format; (g) **Withdraw consent** at any time, where consent is the lawful basis (this may end your participation); (h) **Lodge a complaint** with a supervisory authority (e.g., UK ICO, Irish DPC, your local authority). To exercise any right, contact us at . We will respond within 30 days (or as required by applicable law). *** ### 8. Security We use reasonable technical and organisational measures to protect your data, including: * TLS encryption in transit * Row-level security (RLS) on the application database * Server-side service-role keys held only by authorised serverless functions * Cloudflare Turnstile bot protection, honeypot, and rate-limiting on the application form * Discord webhook contents limited to the operational minimum No system is perfectly secure. In the event of a personal-data breach, we will notify the relevant supervisory authority and (where required) affected Participants in line with applicable law. *** ### 9. Decisions based on automated processing We do not make decisions affecting Participants based solely on automated processing. Acceptance, removal, and Recognition decisions are made by ZeroTick personnel. *** ### 10. Children The Program is not intended for individuals under 18. We do not knowingly collect personal data from children. If you believe we have collected data from a child, contact us and we will delete it. *** ### 11. Changes to this Policy We may update this Policy from time to time. The current version is always available at `zerotick-trade.gitbook.io/documentation.v1.1/zerotick-ambassador-program-privacy-policy`. Material updates will be notified to active Participants by email at least 30 days before taking effect. *** ### 12. Contact ZeroTick, the operator of the Program. Email: *** **Effective Date: 28.04.2026**