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Privacy Policy

The privacy of customers' personal data is important to Zero-Code. This Policy describes the rules according to which Zero-Code processes the personal data of any person using Zero-Code's website, mobile apps and any services offered by Zero-Code.

1. General Definitions


Service provider who needs to process customer’s personal data for the provision of service. Depending of the service the service providers are the following:

  • ZeroCodeLabs OÜ (registry code 16498054, address Pärnu mnt. 139c - 14, Kesklinna linnaosa, Tallinn, 11317, Estonia) who provides The Ultimate NFT Launchpad

  • Affiliate of the forenamed service provider whose company information is provided in the respective service agreement

Customer: Natural person who is using Zero-Code’s website, app or any services provided by Zero-Code

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data

Policy: This privacy policy

Personal Data: Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

Personal Data processed by Zero-Code is described under Section 3

Processing: Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction


Controller: A person who alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

Depending of the service the Controller of the Customer’s Personal Data is:

  • ZeroCodeLabs OÜ or its affiliate if Customer requested Web3 Builder Services

  • ZeroCodeLabs OÜ or its affiliate if Customer requested Smart-Contract Builder

  • ZeroCodeLabs OÜ or its affiliate if Customer requested HoldMyToken 

  • ZeroCodeLabs OÜ or its affiliate if Customer requested Custom Consultancy Services. 


Processor: A person who Processes Personal Data on behalf of the Controller

In the course of provision of Service, Zero-Code may act as Processor by Processing Personal Data on behalf of its Customer or Customer’s legal entity. However, this Policy shall not regulate the Zero-Code’s actions as Processor


Service: Any services provided by Zero-Code via website and Zero-Code mobile apps

Web3 Builder: Enables customers to launch their campaign landing page with our drag & drop website builder. It enables the customer to integrate Web3 tools such as mint button, to enable the sale of NFTs on their landing page, and a gating button to manage their community using Zero-Code’s HoldMyToken app. 

Smart Contract Builder: Enables Customers to build their smart-contracts and deploy them on the Ethereum & Polygon blockchain. It further allows the customer to create a mint button that can be integrated into Zero-Code Web3 Builder, or their choice of site using our API plug-ins. 

Hold My Token: Enables customers to create a token-gated chat group for their NFT holders. It also enables creators to build utilities and offer them to their web3 community via our application. 


2. Policy Applicability
This Policy applies to Personal Data Processing where Zero-Code acts as a Controller. Any personal data Processing conducted on behalf of the Customer or his legal entity is subject to an additional data processing agreement signed between Zero-Code and the legal person controlled by the Customer.

3. Personal Data being collected
Zero-Code Processes the following Personal Data about the Customer:

3.1 Personal Details – full name (surname and given name), gender, personal identification code, date of birth, nationality, contact postal address, e-mail address, mobile phone number;

3.2 Identification Data – data retrieved from the copy of a passport, such as document number, issue date, expiry date and issuing entity, photo, URL of a Portfolio or LinkedIn profile;

3.3 Verification Data – data which Zero-Code collects for the purpose of conducting Customer due diligence under applicable anti-money laundering laws if deemed applicable. 

3.4 Background Data – data Zero-Code collects and Processes for the purpose of conducting Customer adverse media checks via open sources;

3.5 Profile Data – Customer’s Google profile data, such as name, e-mail address, language preference and profile picture;


3.6 Payment Data – data concerning payments for Zero-Code’s Service and state fees, such as account number (IBAN), account holder name, bank name, transaction details, If the Customer chooses to pay for the Service by credit card or by PayPal, his/her payment details are not stored by Zero-Code and therefore cannot be accessed by Zero-Code.

3.7 Device Data – information regarding the device on which the Customer is using the Zero-Code’s website/app, including the device’s model, name or any other identifier and the IP address;

3.8 Preference Data – Customer’s preferences in the Zero-Code’s website/app;

3.9 Customer Support Data – communication between Zero-Code and the Customer (inquiries submitted via the website, email, social media or chat);

3.10 Usage Data – data about Customer’s interaction in Zero-Code’s website/app.


4. Sources of Personal Data collection
Majority of Customer’s Personal Data Processed by Zero-Code is collected directly from the Customer. However, Zero-Code may collect Customer’s Personal Data also from third party sources, some of these databases are publicly available and some of them are not.


5.Purposes for collecting and Processing Customer's Personal Data
Personal Data collected by Zero-Code is Processed for the purposes established in the law or as described herein, including but limited for the following purposes:

5.1 Contractual Purpose – Zero-Code needs to Process Customer’s Personal Data in order to enter into service agreement with the Customer and to provide Service to Customer;

5.2 Compliance Purpose – Zero-Code needs to Process Customer’s Personal Data in order to perform obligations under applicable laws, such as to comply with anti-money laundering requirements, and combat fraud, ensure the fulfilment of international financial sanctions, comply with the lawful inquiries and orders of public authorities with whom Zero-Code is obligated to cooperate;

5.3 Analytical Purpose – Zero-Code needs to Process Customer’s Personal Data in order to manage, analyse and improve the Service, website and app;

5.4 Marketing Purpose – Zero-Code needs to Process Customer’s Personal Data in order to send relevant promotional information to the Customer about Zero-Code services and the related offerings by third parties we work with, if the Customer has granted an explicit consent to use his/her Personal Data for this purpose;

5.5 Personalization Purpose – Zero-Code needs to Process Customer’s Personal Data in order to personalize the Service and the content provided to the Customer;

5.6 Communication Purpose – to contact the Customer for administrative purposes such as customer service, address technical or legal issues related to the Service provided, or share updates and notifications about the Service;

Zero-Code shall not use Customer's Personal Data for any other purpose incompatible with the purposes outlined above or required, permitted or authorized by law.

Customer is not subject to statutory obligation which obligates Customer to provide Personal Data described herein to Zero-Code. The collection of certain Personal Data referred herein may be required under the law and/or inevitably necessary for the provision of service to the Customers (such as data necessary for the verification of the Customer). Failure to provide data may result in adverse consequences, such as Zero-Code's inability to comply with our obligations under law. The Customer is welcome to ask for clarifications regarding the obligation to submit any specific Personal Data and also about possible consequences arising from the failure to provide the Personal Data.

6. Automated decision making
Zero-Code is using automated decision making in the pre-contractual Processing in order to establish sufficiently whether the Customer is eligible to use Zero-Code’s services.

Automated decision making refers to a decision which is taken solely on the basis of automated Processing of Customer’s Personal Data. This means Processing using, for example, software code or an algorithm, which does not require human intervention.

During the onboarding process, the Customer is being asked for the field of activity of the service provided in course of using Zero-Code’s services. The automated decision making is necessary for entering into agreement with Zero-Code.

The automated decision making is used in order to accept or reject the Customer’s application to enter into a service agreement with Zero-Code.

In case the field of activity which the Customer wishes to act on is not supported by Zero-Code’s services, then the Customer’s application will be rejected. Upon rejection, Zero-Code will inform the Customer by e-mail about the reasoning for rejection.

The Customer is entitled to request human intervention or object to the decision by contacting Zero-Code.


7. Legal grounds for Processing
Zero-Code is relying on the following legal grounds when Processing Customer’s Personal Data:

7.1 Processing is necessary for the performance or entry into a contract between Customer and Zero-Code (GDPR article 6 (1) (b)), Zero-Code is Processing Personal Data for Contractual Purpose under contract entered into between Zero-Code and Customer;

7.2 Processing is necessary for compliance with a legal obligation to which Zero-Code is subject (GDPR article 6 (1) (c)). Zero-Code is Processing Personal Data for Compliance Purpose under legal obligations to which Zero-Code is subject to;

7.3 Processing is necessary for the purposes of the legitimate interests pursued by Zero-Code (GDPR article 6 (1) (f)). Zero-Code is Processing Personal Data for Analytical or Personalization Purpose under legitimate interest;


7.4 Customer has granted consent to the Processing of his Personal Data (GDPR article 6 (1) (a)). Zero-Code is Processing Personal Data for Marketing Purpose under Customer’s consent.

8. Transfer of the Personal Data
Zero-Code may transfer Customer's Personal Data to third parties, such as:

8.1 Legal and regulatory authorities (e.g. commercial register) whom Zero-Code is obligated to disclose Customer’s Personal Data under the law;

8.2 Server hosts who host Zero-Code’s servers;

8.3 Identification service providers who help Zero-Code verify Customer’s identity and acquire Verification Data;

8.4 Communication service providers who facilitate e-mails, calls, SMS messages and other communication between Zero-Code and the Customer;


8.5 Customer support and customer management service providers;


8.6 Marketing service provider;


8.7 Zero-Code’s affiliate. i.e. any company that directly or indirectly controls Zero-Code; any company that is directly or indirectly controlled by Zero-Code; or any company that is controlled, directly or indirectly, by the ultimate parent company of Zero-Code. Control shall mean owning more than fifty percent of the voting rights in a company or otherwise having the power to govern the financial and the operating policies or to appoint the management of a company;

8.8 Other parties involved with the provision of Zero-Code’s Service (accountants, auditors, lawyers, IT systems suppliers and support, or any other outsourcing providers).


8.9 Zero-Code has taken steps to ensure that these data recipients protect the confidentiality and security of Personal Data, and to ensure that Personal Data is Processed only for the provision of Service and in compliance with applicable law.

Such third parties may be located in countries outside of the European Economic Area ("EEA") whose privacy regulations may differ and which are not subject to adequacy decisions of the European Commission. In those countries the security of the Personal Data (inc. protection against misuse, unauthorized access, disclosure, alteration or destruction) may not be ensured as it is secured in the European Union, due to the lack of adequate data protection level.

When transferring collected Personal Data outside of the EEA, Zero-Code shall ensure the application of the appropriate safeguards. If the Customer wishes to receive a copy, please contact us as instructed below.


9. Security
Zero-Code will take appropriate legal, organisational, and technical measures to protect Personal Data consistent with applicable privacy and data security laws. Security measures shall be applied in order to protect Personal Data from involuntary or unauthorized Processing, disclosure or destruction.
Upon transferring Personal Data to third parties, Zero-Code will apply the following safeguards:


9.1 Zero-Code enters into a data processing agreement with the relevant third party;


9.2 Zero-Code makes sure that such third party undertakes to implement appropriate technical and organizational measures ensuring the Processing of Customer’s Personal Data in accordance with this Policy and applicable law;


9.3 Zero-Code makes sure that (a) the third party is established in a jurisdiction which the European Commission has recognized as ensuring an adequate level of personal data protection, or (b) the Processing of Customer’s Personal Data is subject to other appropriate safeguards stipulated in the GDPR.

10. Integrity and retention of the Personal Data
Zero-Code will retain Personal Data for the period required or permitted by applicable law, but no longer than it is reasonably necessary in order to achieve the purposes for which the Personal Data was collected.
Zero-Code takes reasonable steps to ensure that the Personal Data we Process is reliable for its intended use, accurate, and complete as necessary to carry out the purposes described herein.


11. Customer's rights in regarding to the collection of Personal Data
Customer has the following rights in relation to the Processing of his Personal Data:

11.1 Request information - Zero-Code has provided all information which the Customer has the right to receive in this Policy. The valid version of the Policy is available on Zero-Code's website at any time.


11.2 Right to access - Customer has the right to ask Zero-Code to provide a copy of Customer’s Personal Data which Zero-Code Process.


11.3 Right to Rectification - Customer has the right to ask Zero-Code to rectify Personal Data in case the data is incorrect or incomplete.


11.4 Right to Erasure - Customer has the right to ask Zero-Code to erase Personal Data, unless Zero-Code is obliged to continue Processing Customer’s Personal Data under law or under a contract between the Customer and Zero-Code, or in case Zero-Code has other lawful grounds for the continued Processing of Personal Data.


11.5 Right to Restriction - Customer has the right to ask Zero-Code to restrict the Processing of his Personal Data in case the data is incorrect or incomplete or in case his Personal Data is Processed unlawfully.


11.6 Right to Data Portability - Customer has the right to ask Zero-Code to provide the Customer or, in case it is technically feasible, a third party, his Personal Data, which the Customer has provided to Zero-Code and which is Processed in accordance with Customer’s consent or a contract between the Customer and Zero-Code.


11.7 Right to Object - Customer has the right to object to Processing his Personal Data in case there is a reason to believe that Zero-Code has no lawful grounds for Processing the Personal Data.


11.8 Right to withdraw Consent for the Processing of Personal Data - Customer is entitled to withdraw the consent granted for the Processing of Personal Data et any time. Withdrawal does not affect the lawfulness of the Processing conducted before the withdrawal.


11.9 Right to File Complaints - Customer has the right to file complaints regarding Processing of his Personal Data.


In order to exercise any rights referred herein the Customer is required to submit a written application to Zero-Code (Zero-Code’s contact details can be found under Section 16). Zero-Code has the right to decline this application by justifying the reasons for the refusal.
According to the article 12(3) of GDPR, Zero-Code is obligated to respond to the application within 1 month. However, Zero-Code will make its best efforts to respond to Customer’s request within 1 week.

12. Cookies and tracking technologies
Zero-Code is using automatically collected information and other information collected within its website through cookies and similar technologies.

Cookies are small text files that a website or its service provider transfers to the Customer's computer hard drive through his website browser (if Customer allows) that enables the website's or service provider's systems to recognize Customer's browser and capture and remember certain information. For example, cookies may help a website remember certain preferences the Customer has selected on the website, such as language preferences.

  • Within the website Zero-Code is using the following types of cookies:

    • first-party cookies, which are stored to the Customer’s device by Zero-Code. These cookies allow website owners to collect analytics data, remember language settings, and perform other useful functions that provide a good user experience;

    • third-party cookies, which are stored to the Customer’s device by other service providers on Zero-Code’s website. Zero-Code may use third-party analytics tools (such as Google Analytics), to help us measure traffic and usage trends for the Zero-Code’s Service. Web analytic service providers analyse the usage of the Zero-Code website and services so that Zero-Code could improve and amend our website/app and function thereof.

  • Cookies are being used to serve the following purposes:

    • to store authentication information and protect Personal Data from third parties;

    • to personalize our Service, help remember Customer's choices within the website, understand and save Customer's preferences for future visits;

    • to provide customized advertisements, content and information;

    • to track Customer's entries, submissions, and status in any promotional or other activities on the Service;

    • to monitor and analyse the effectiveness of the Service;

    • to compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future.

  • The Customer can delete or block cookies through his browser settings at any time. However, some cookies might be necessary for the functionality of the Zero-Code Services and usage of the website. Therefore, the Customer understands that when blocking or deleting the cookies some features within the website might not function correctly. For more general information about cookies please see


13. Google Analytics and ads
Zero-Code have implemented the following Google Analytics features:

  • Remarketing;

  • Google Display Network Impression Reporting;

  • Demographics and Interests Reporting.

Zero-Code along with third-party vendors, such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies or other third-party identifiers together to compile data regarding Customer interactions with ad impressions, and other ad service functions as they relate to our website.
Customers can set preferences for how Google advertises to them using the Google Ad Settings page. Alternatively, the Customer can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

Zero-Code is using Google Analytics to measure and evaluate access to and traffic on the public area of our website and create user navigation reports for our website administrators.

Zero-Code takes measures to protect the technical information collected by the use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the website and identify visitor preferences.


14. Commercial Communication
If a Customer receives commercial emails from us, he may unsubscribe at any time by following the instructions contained within the email or by sending an email to

The Customer is able to view and modify settings relating to the nature and frequency of promotional communications that they receive from us by accessing the "Settings" section in the restricted area of the website.

The Customer has to be aware that if he opts-out of receiving commercial emails from us or otherwise modifies the nature or frequency of promotional communications he receives from us, it may take up to five (5) business days for us to Process the request. Additionally, even after he/she opts-out from receiving commercial messages from us, he/she will continue to receive administrative messages from us regarding the Service.

15. Right to amend this Policy
Zero-Code is entitled to unilaterally amend this Policy from time to time. Upon amending the Policy, Zero-Code will notify the Customer about the terms by e-mail. In case the new terms refer to Processing of Customer’s Personal Data for any new purpose, which requires Customer’s consent, then Zero-Code will not Process Personal Data for such new purpose, before it has received respective consent.


16. Contact Information
Should the Customers have any questions regarding this Policy or Processing of Personal Data, they are welcome to contact Zero-Code with requests, inquiries or any complaints via email:


17. Confirmation
By accepting this Policy, the Customer confirms that he has familiarized himself with this Policy, understood it and agrees to its terms.

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