INFORMATION WE COLLECT
Information We Collect Directly From You. We collect information directly from you when you request information from us, when you register with us, and for those who have registered, when you log into your account. The information that we collect may include your name, contact information and billing / payment information any other information you provide to us. If you register for an account, we will collect your email address and a password. We generally don’t sell this information, but we transfer it to trusted agents and service providers as described below.
Information We Collect Automatically on our Site. Our Site is directed to business partners, Clients and prospective Clients, which are generally businesses. We automatically collect certain information about your use of our Site through cookies, web beacons, and other technologies (including the Analytics Services), including (but not limited to): your IP address and location information, website URL, referring URL, pages viewed (including page address, name and title, data and time of access, and length of time spent on each page), activities on each page (including links clicked and search terms entered), operating system, browser type, precise location information such as lat/long, User Agent header information, web page performance information, campaign information, java version, flash version, resolution and screen information, and language information. We may share this information with third parties to targets ads on other websites and disclose it to trusted agents and service providers as described below.
Information We Collect From Social Networking Sites. If you choose to “Like” us, subscribe to our twitter feed, or connect with us on LinkedIn, we may receive information from those third party sites. For example, when you “Like” us through Facebook, we receive your Facebook user ID and the pages you were visiting when you chose to “Like” us; we may also collect any profile information that you share with everyone. To review and manage the privacy settings for your social networking accounts, you should refer to the privacy settings for the social network.
USERS OF OUR CLIENTS’ WEBSITES
Zaius’ clients (“Clients”) may use our Analytics Services, which includes certain code, software, cookies and other tracking mechanisms, and services to obtain information regarding the activities that users engage in while visiting their websites (“Client Analytics Data”). When a user visits a website that uses our Analytics Service, code contained on the website contacts our servers and enables Zaius to collect Client Analytics Data. Some Clients may also use their own code to obtain analytics data about users of their Digital Properties, and then send such information to our servers. Client data is stored on Zaius’ web servers and databases for use in performing analysis and producing reports for Clients, and for other purposes explained in this Policy.
Our Analytics Services are used to collect and analyze behavioral, usage and activity information about the use of our Clients’ Digital Properties. The Analytics Services will collect certain non-personally identifiable analytics data, including (but not limited to) IP address and location information, website URL, referring URL, pages viewed (including page address, name and title, data and time of access, and length of time spent on each page), activities on each page (including links clicked and search terms entered), operating system, browser type, User Agent header information, web page performance information, campaign information, java version, flash version, resolution and screen information, and language information.
HOW WE USE THE INFORMATION WE COLLECT
We use the information that we collect for the following purposes:
HOW WE DISCLOSE THE INFORMATION WE COLLECT
We do not share the information we collect or receive with third parties for their own marketing purposes. We may transfer or otherwise disclose the information that we collect as follows:
In cases of onward transfer to third parties of data of EU, UK, and Swiss individuals received pursuant to the EU-US Privacy Shield or Swiss-EU Privacy Shield, Zaius is potentially liable.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, have the browser notify you when you receive a new cookie, or disable cookies altogether. Disabling cookies may affect the functionality of the websites and online services you use.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We, and our third party service providers, also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
THIRD PARTY ANALYTICS AND TRACKING
USER GENERATED CONTENT
We invite registered users to post content on our Site, including your comments, pictures, and any other information that you would like to be available on our Site. If you post content to our Site, all of the information that you post will be available to our registered customers. If you post your own content on our Site or services, your posting may become public and we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.
Our Site and services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
If you’d like us to provide access to, update, correct, or delete any personally identifiable information that you have provided on the Site or that we may have in connection with the Analytics Services, please send your request to firstname.lastname@example.org, and the company will process your request within a reasonable period of time after receipt. EU and California data subjects have additional rights listed below.
We store personally identifiable information such as email address or billing details received from our Clients so long as they continue to have a business relationship with Zaius. You may ask us to delete that information by following the instructions above. As an agent (i.e., data processor) of our Clients, store information collected via our Analytics Services for a reasonable time as directed by our Clients.
DATA INTEGRITY, PURPOSE LIMITATION
We process information in a way that is compatible with and relevant for the purpose for which it was collected as described above. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
We have implemented reasonable security precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
We may send periodic promotional emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails related to your account or any services you have requested or received from us.
Our Site is not designed for users under 18 and our Analytics Services may only be used by Clients over 18 years of age. Further, our Analytics Services may not be used to collect personal information from children under 13 years of age or on Digital Properties that are directed to children under 13 years of age; if we discover that we have collected personal information from children under 13, we will take steps to securely delete such information.
If you have questions about the privacy aspects of our Site or Analytics Services or would like to make a complaint, please contact us at email@example.com.
CALIFORNIA DATA SUBJECTS
Starting January 1, 2020, the California Consumer Privacy Act (CCPA) provides additional privacy protections for California data subjects and users, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information). Please visit our California Privacy Rights page for more information on how to exercise those rights or you may call our toll-free CCPA California consumer hotline at 1-877-636-1232.
We do not discriminate against you if you exercise any of the above rights. Moreover, we may not be able to honor a right if doing so would violate applicable law. We transfer pseudonymous personal information to third parties pursuant to operating our Site and as such are considered to have sold data over the past twelve months pursuant to California law.
EU DATA SUBJECTSs
In addition to the above referenced privacy practices, EU Data subjects are granted additional privacy rights under the General Data Privacy Regulation (“GDPR”). For example, an EU (or Swiss) individual who seeks access, or who seeks to correct, amend, port over and/or delete inaccurate data, or who wishes to limit the use and disclosure of their personal data should email our compliance team at firstname.lastname@example.org. Those rights also include the right to complain to EU Supervisory Authorities.
With respect to EU data subjects, personal data includes Pseudonymous Data such as an IP address, a mobile advertising ID or a cookie ID as well as PII. EU Data subject wishing to object to Zaius’ processing of data using the opt-out methods described above should note that the presence of a Zaius opt-out cookie tells our systems that you object to our processing of data.
Zaius operates the Platform and provides the Services as a “data processor” under the GDPR. That means that Zaius processes data via the Platform and Services as directed by each of our Clients pursuant to our contracts with Clients. While Zaius does enable Clients to create profiles of Internet Users, none of those profiles contain sensitive information, nor do the profiles present a “high risk” to the fundamental human rights of EU data subjects.
We process certain EU personal data provided by Clients and Data Partners under contractual necessity. For example, we require the billing details of our Clients located in the EU to process payment for the Services and we need email addresses from Clients to enable them to login to our systems. We collect contact details from EU data subjects via our Website with consent and ask for consent to place cookies onto EU desktops. Our sales and marketing team may obtain additional additional contact details for current and prospective Clients via our legitimate interest.
Zaius’ data protection officer and EU representative is Dr. Christoph Bauer, CEO at ePrivacy GmbH:
Große Bleichen 21, 20354 Hamburg
RECOURSE, PRIVACY COMPLAINTS BY EU, UK, AND SWISS RESIDENTS
Zaius has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
CHANGES TO THIS POLICY
This Policy is current as of the Effective Date set forth below. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personally identifiable information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.
EFFECTIVE DATE: Dec 15, 2019.