Privacy Policy

1. Who We Are

ZEBEDEE, LLC is a limited liability company organized under U.S. law, registered with FinCEN as a Money Services Business (MSB Registration #31000327040201) and licensed as a Money Transmitter in Washington State (License #550-MT-149372). Our registered address is 50 Harrison St Ste 472, Hoboken, NJ 07030, USA.

2. Information We Collect

2.1 Identity and Verification Information (KYC)

As a regulated MSB, we are required by law to collect and verify identifying information from customers. This includes:

• Full legal name
• Date of birth
• Government-issued identification documents
• Residential address
• Tax identification number (where required)
• Photographs or biometric data used for identity verification

2.2 Contact and Account Information

• Email address and phone number
• Account credentials
• Communication preferences

2.3 Transaction and Financial Information

• Transaction history and amounts
• Wallet addresses
• Source of funds information (as required by AML regulations)
• Blockchain transaction data

2.4 Technical Information

• IP address and device information
• Browser type and version
• Log data and usage information
• Cookies and similar tracking technologies

3. How We Use Your Information

We use your personal information to:

• Provide, administer, and improve our services
• Verify your identity and comply with our Customer Identification Program (CIP)
• Comply with Anti-Money Laundering (AML) obligations, including transaction monitoring, suspicious activity reporting, and currency transaction reporting
• Screen against OFAC sanctions lists and other watchlists
• Communicate with you about your account and our services
• Maintain required records under applicable law (5-year minimum retention)
• Respond to regulatory inquiries and legal process
• Detect, prevent, and investigate fraud and illegal activity

4. Legal Basis for Processing

We process personal information based on: (a) legal obligations under the Bank Secrecy Act, FinCEN regulations, and applicable state law; (b) contractual necessity to provide our services; (c) legitimate business interests; and (d) your consent where required.

5. Disclosure of Your Information

We may disclose your information to:

• Regulatory authorities: FinCEN, the IRS, state regulators, and law enforcement, as required by law (including SAR and CTR filings)
• Service providers: Third-party vendors who assist with identity verification, compliance screening, and technology infrastructure, under confidentiality obligations
• Legal process: In response to valid court orders, subpoenas, or other legal process
• Business transfers: In connection with a merger, acquisition, or sale of assets

We do not sell your personal information to third parties for marketing purposes.

6. Data Retention

We retain customer records, transaction data, and identification documents for a minimum of five (5) years from the date of the last transaction or account closure, as required by the Bank Secrecy Act and FinCEN regulations. In some circumstances, we may be required to retain data for longer periods.

7. Data Security

We implement industry-standard technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no data transmission or storage system is 100% secure, and we cannot guarantee absolute security.

8. Your Rights

Subject to applicable law and our legal obligations (including mandatory KYC/AML recordkeeping), you may have the right to access, correct, or request deletion of your personal information. To submit a request, contact us at info@zebedeellc.it.com. Please note that certain information must be retained by law and cannot be deleted upon request.

9. Cookies

Our website uses cookies and similar technologies for functional purposes (e.g., session management) and analytics. You may configure your browser to refuse cookies, though this may affect website functionality.

10. Children's Privacy

Our services are not directed to persons under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected information from a minor, we will take steps to delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated effective date. Continued use of our services after changes constitutes your acceptance of the revised policy.

12. Contact Us

For questions or concerns about this Privacy Policy or our data practices: