Privacy Policy

This Privacy Policy (“Policy”) governs processing by ZRX LTD OÜ (“onFOMO, “we”, “us”) of information, including personal data, relating to the data subjects (“you”, “User") of the ("Site"), and other services provided by us, including but not limited to wallet and prepaid card services (collectively hereinafter “Service”). This privacy policy applies to the Site, App, all products and Services offered by us.

ZRX LTD OÜ is a company registered in Estonia with registration number 14488459.

Gathering Personal Information

We may process personal information of Users in a variety of ways, including, but not limited to, when users visit our Site, or use any of our Services; register on the Service; fill out a form; provide information for passing of anti-money laundering procedures. We also may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms for purposes of verifying your identity. We obtain such information with a purpose and a legal basis to comply with our legal obligations, such as anti-money laundering laws. From time to time, we may process additional data about client to make sure our Service is not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contract with you and others, as well as on the basis of our legitimate interest to prevent fraud, money laundering and other illicit activities.

Categories of data involved in data processing include:

  • Name;
  • Date of birth;
  • Business/Company name;
  • Contact information such as email addresses and telephone numbers;
  • Demographic information such as city, post code and countries;
  • Financial information such as payment method information;
  • Cryptocurrency wallet addresses used;
  • IP address;
  • Web browser type and version;
  • Operating system;
  • A list of URLs starting with a referring site, Your activity on Our Site;
  • Any documents containing personal data required to comply with financial regulation such as Anti Money Laundering (AML) and Know Your Customer (KYC). These can be, but are not limited to National Identity Card, Passport, Proof of Address, Proof of Funds & related documents.

How long we retain information

We retain the information we collect for as long as needed to provide the Services (including aspects of risk management) and to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements (unless we are instructed otherwise).

We may rectify, replenish, or remove incomplete or inaccurate information at any time and at our own discretion.

How we share collected information

We sometimes need to share personal information we process with third parties. Where necessary or required we may share information with authorities, other companies within the same group of companies as us for internal administrative purposes, companies which the group cooperates with and to other third parties, such as third party service providers used in connection with our Services (e.g. various analytical services and financial institutions that we have partnered with to jointly create and offer a product). The legal basis for this data processing is performance of contract between you and us, as well as our legitimate interest and our legal obligation.

We may share collected information with:

  • credit reference agencies;
  • KYC providers;
  • debt collection and tracing agencies and other companies in the same group;
  • suppliers and services providers (analytical, financial);
  • government bodies and other recipients in order to comply with applicable law;
  • courts and tribunals.

How do We Store Your Data?

We only keep Your personal data for as long as We need to in order to use it as described above and/or for as long as We have Your permission to keep it.

Data security is very important to Us, and to protect Your data We have taken suitable measures to safeguard and secure data collected through Our Site.

Steps We take to secure and protect Your data include:

  • Implemented & maintain a rigorous internal data protection policy;
  • Server-sided security measures & firewalls

How Can You Control Your Data?

In addition to Your rights under the GDPR, when You submit personal data via Our Site, You may be given options to restrict Our use of Your data. In particular, We aim to give You strong controls on Our use of Your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which You may do by unsubscribing using the links provided in Our emails and at the point of providing Your details and by managing Your Account).

How we transfer collected information internationally?

We intend to transfer the collected information we obtain from you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.

The collected information may be transferred to a destination outside the European Economic Area ("EEA"). All data transfers outside the EEA are made under agreements and include all necessary standard data protection clauses adopted by a supervisory authority copy of which may be obtained by request made to the [email protected].

Despite data transfer, we save all our obligations and liability for any breaching of your personal data rights by action of our data-processors.

Rights of users

As a data subject, You have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

  • The right to be informed about Our collection and use of personal data;
  • The right of access to the personal data We hold about You;
  • The right to rectification if any personal data We hold about You is inaccurate or incomplete;
  • The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about You;
  • The right to restrict (i.e. prevent) the processing of Your personal data;
  • The right to data portability (obtaining a copy of Your personal data to re-use with another service or organisation);
  • The right to object to Us using Your personal data for particular purposes;
  • Rights with respect to automated decision making and profiling.

If You have any cause for complaint about Our use of Your personal data, please contact Us using the details provided in section 10 and We will do Our best to solve the problem for You.

Changes to this privacy policy

Onfomo has the discretion to update this privacy policy at any time. When we do, we revise the updated date at the top of the page. We may also may post a notification on the main page of our Site and notify you by other means. We encourage Users to frequently check the page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

What if I do not want to accept this Privacy policy?

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed as your acceptance of those changes.

If you have already registered an account, you can find out how to terminate or cancel your account.


If you have a concern about the way we handle your personal information, you have a right to lodge a complaint. For further information, please contact our Data Protection Officer [email protected], or, alternatively, you can fill out a contact form.