Legal · Zion Capital

Privacy Policy

Last Updated: May 20, 2026·Effective: May 20, 2026

1. Overview

This Privacy Policy applies to all digital properties operated by Guzzi Management Co. Inc. ("Company," "we," "us," or "our"), a Wyoming corporation, including Zion Assets LLC (zionassets.com) and Zion Capital (zcap.zionassets.com). It describes how we collect, use, store, and protect your personal information when you access our platforms, use ZCAP token-gated features, or interact with any tools provided through the ZCAP ecosystem.

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree, please discontinue use of our Services immediately.

2. Information We Collect

2.1 Blockchain & Wallet Data

When you connect a Solana-compatible wallet to our platform, we may record your public wallet address. This is a public blockchain identifier — we do not collect private keys, seed phrases, or any signing credentials. All transactions you initiate are broadcast to the Solana blockchain and are publicly visible. We do not control or store your private keys at any time.

2.2 Automatically Collected Data

We may automatically collect: IP address and approximate geolocation, browser type and version, device identifiers, operating system, pages visited and clickstream data, session duration and interaction patterns, and referral URLs. This data is collected via cookies, server logs, and third-party analytics tools.

2.3 Voluntarily Provided Data

If you contact us, complete forms, or participate in community programs, we may collect: name and email address, Discord or social handles, correspondence content, and employment or business information for institutional inquiries.

2.4 ZCAP Ecosystem Data

For token-gated features (Capitol Signals, Alpha Signals, Sniper Bot, Trading Tools, and VIP membership tiers), we record: wallet address and ZCAP token balance at time of access, feature access logs and timestamps, trial status and expiration data stored in our database, and order and position data for trading tools (stored locally in your browser's localStorage and, when you opt to save orders, in our secure database).

3. How We Use Your Information

We use collected information to: provide, operate, and improve our Services; verify ZCAP token holdings to gate access to VIP features; detect and prevent fraud, abuse, or unauthorized access; comply with legal obligations and respond to lawful requests; communicate with you about platform updates, security notices, and service changes; conduct analytics to understand usage patterns and improve user experience; and enforce our Terms of Use.

We do not sell your personal information to third parties. We do not use your data for targeted advertising.

4. Blockchain Transparency Notice

ZCAP is a Solana-based SPL token. All on-chain activity — including token transfers, swaps executed through the ZCAP Sniper Bot, and smart contract interactions — is permanently recorded on the Solana blockchain and is publicly accessible. This information is immutable and cannot be deleted or modified by us or any party. You acknowledge and accept this inherent transparency when using blockchain-based features.

5. Trading Tools & Sniper Bot

The ZCAP Sniper Bot and associated trading tools are non-custodial. This means: we never hold, control, or have access to your funds or private keys; all trade executions are initiated and signed by your own wallet; position data and take-profit/stop-loss orders are stored in your browser (localStorage) and optionally in our encrypted database for server-side monitoring; we do not execute trades on your behalf without your explicit wallet signature, except for automated monitoring features you have voluntarily configured.

These tools are provided exclusively to users accessing from eligible jurisdictions. Users in the United States are not eligible to use the Sniper Bot, presale features, or certain trading signals. By accessing these features you represent that you are not located in, or a resident of, the United States or any other restricted jurisdiction.

6. Cookies & Tracking

We use essential cookies required for platform functionality (session management, wallet connection state), analytics cookies (to understand traffic and usage — you may opt out via your browser settings), and localStorage for storing your trading preferences, positions, and bot configuration on your device.

We do not use advertising cookies or sell cookie data to third parties. You may disable cookies in your browser settings, but some features may not function correctly without them.

7. Data Sharing

We may share your information with: service providers who assist in operating our platform (database hosting, analytics, security monitoring) under strict confidentiality obligations; law enforcement, regulators, or government authorities when required by applicable law or legal process; professional advisors (legal, accounting, compliance) bound by confidentiality; and successors in interest in the event of a merger, acquisition, or corporate restructuring.

We do not sell, rent, or trade your personal information. Any third-party service provider we engage is prohibited from using your data for their own purposes.

8. Data Retention

We retain personal data for as long as necessary to provide our Services and fulfill the purposes described in this Policy, or as required by law. Wallet-connected session data is retained for 90 days. Trading order records are retained for 12 months. Communication records are retained for 3 years for compliance purposes. You may request deletion of your personal data subject to legal retention obligations by contacting us at privacy@zionassets.com.

9. Security

We implement industry-standard security measures including encrypted database connections (TLS), secure API authentication, rate limiting and abuse prevention, and regular security reviews. However, no system is completely secure. You are responsible for maintaining the security of your wallet, private keys, and seed phrases. We will never ask for your private key or seed phrase under any circumstances.

10. Your Rights

Depending on your jurisdiction, you may have rights to: access the personal data we hold about you; request correction of inaccurate data; request deletion of your personal data (subject to legal obligations); object to or restrict processing; and data portability.

To exercise these rights, contact us at privacy@zionassets.com. We will respond within 30 days. Note that blockchain transaction data is immutable and cannot be deleted.

11. Minors

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from minors. If you believe a minor has provided personal information through our platform, contact us immediately at privacy@zionassets.com.

12. International Users

Our Services are operated from the United States. If you access them from outside the United States, your information may be transferred to and processed in the United States, which may have different data protection laws than your country. By using our Services, you consent to this transfer. Certain features — including but not limited to the Sniper Bot, presale participation, and trading signals — are not available to residents of the United States or other restricted jurisdictions.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top reflects the most recent revision. Continued use of our Services after changes constitutes acceptance of the updated Policy. We will make reasonable efforts to notify users of material changes via platform announcements.

14. Contact

For privacy-related inquiries, data requests, or concerns:

Guzzi Management Co. Inc. Operating as: Zion Assets LLC / Zion Capital Email: privacy@zionassets.com Website: https://zionassets.com