Amendments to this Policy will be posted on the Sites and will be effective when posted. Your continued use of the Sites following the posting of any amendment will constitute your acceptance of that amendment, except if your personally identifiable information will be used in a materially different manner. See the Notification of Changes section below for further information.If you have questions or concerns regarding this Policy, you should contact Zen Innovations AG by emailing firstname.lastname@example.org.
For the avoidance of doubt, Zen Innovations AG may refer to unregistered individuals within this Policy as a “visitor”, and registered individuals as a “subscriber” or “subscribing user” hereafter. Furthermore, we may refer to registered or unregistered individuals “you” or a “user” . Registration is not mandatory to access certain public areas of the Web Site. A pre-paid subscription or trial registration is required for access to certain areas of the Website and all areas of the Service Sites, and the products and services provided through those areas of the Sites. When you sign up for a subscription or register for a trial use of the Service Sites, you are given an account with GTT (your “Account”) and you will be assigned a username and password for purposes of accessing your Account, the Service Sites and the portions of the Website available to registered users.
ZEN is not responsible for any loss or misuse of your username and password. Always remember that in order to protect your privacy, you should not share your username and password with others.
PERSONALLY IDENTIFIABLE INFORMATION
We collect and share personally identifiable information regarding users of the Sites as described in this Policy. Except as noted in this Policy, personally identifiable information collected on the Sites is not shared with third parties without your consent. We may automatically collect personally identifiable information from you when you access the Sites. We may also collect personally identifiable information from you through a number of voluntary sources on the Sites, such as emails, postings, messages or other electronic submissions and communications sent by you to ZEN or the Sites.
The personally identifiable information we may collect from you will include, by way of example:
- Full name
- Company name
- Contact information (including, address, postal/zip – code, country, and phone number)
- Email address
- Other information volunteered by users, such as information provided during surveys and Sites’ registration
- IP address
- User-specific and aggregate information on the areas of the Sites accessed
- User name and password information for the Sites
ZEN may collect and publish statistics and usage information related to the Users consumption and feedback of content only in Anonymous Information cases. We may publish consumption data associated with a certain keyword or piece of content, but never in relationship to your Account. We may collect certain information from visitors to the Site and users of the Services, such as Internet addresses. This information is logged to help diagnose technical problems and prevent security breaches.
DISCLOSURE AS REQUIRED BY LAW
Though we make every reasonable effort to preserve user privacy, we may need to disclose personally identifiable information of certain users of the Sites when we have a reasonable and good-faith belief that the disclosure is necessary to comply with a current judicial proceeding, a court order, or legal process served on ZEN or the Sites. In this situation we will use reasonable efforts to provide notice of this disclosure to all affected users, to the extent reasonably possible under the circumstances.
WHERE WE STORE AND PROCESS PERSONAL DATA
We may store or process personal data collected by ZEN in any country that we operate.
ZEN primary data storage location is Switzerland, however, services such as our CRM are hosted on cloud-based 3rd party services. We will ensure that ‘adequate safeguards’ are in place when transferring data between regions, following the guidance of applicable laws.
Company entities of ZEN may also process personal data following Applicable Law.
ZEN retains personal data for as long as necessary to fulfil our contractual obligations and provide products that you have requested, or to comply with the legal requirements of the country where the data is located. These retention periods vary depending on the location, type of data, product type and the extent of our interaction with you.
We use the following criteria to determine the retention period.
- Has the customer provided personal data with the expectation that we will retain such data until they specifically ask for its erasure?
- In such cases, ZEN will follow the guidelines of applicable law and keep data for no longer than is necessary for the purpose for which it is being processed, or until you request for the erasure of your data. Has ZEN contractually agreed to a retention period?
- Organisations may ask that we retain data for at least a specified period. Your rights are not affected. Personal erasure requests will take priority in such circumstances.
- Is ZEN under a legal obligation to retain or delete the data?
- Examples of this include, but not limited to; mandatory data retention laws set by governing bodies or data retained for the purposes of litigation.
On occasion it is necessary to send out service related announcements. For instance, if the Sites or any of the services offered through the Sites are temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. These communications are not promotional in nature.
SPECIAL OFFERS AND UPDATES
We send all new registrants of the Sites a welcoming email to verify password and username. Subscribing users will occasionally receive information on products, services and special deals, and periodic newsletters in accordance with their subscription agreements. We may occasionally send existing and expired subscribers information on products, services and special deals, and periodic newsletters which are not part of their subscription.
NON-PERSONALLY IDENTIFIABLE INFORMATION
Where possible, our server automatically recognises each visitor’s Internet Protocol addresses. We also collect information about how visitors use the Sites (for example what pages are viewed and products and services are purchased). This information, which is collected and maintained in an anonymous and non-personally identifiable form, allows us to improve the content of the Sites and facilitate market research. Sometimes, we utilise the services of a third party to help us understand this information better, although the information that is disclosed to these entities remains at all times in anonymous and non-personally identifiable form. Other than improving the Sites and the experience of visitors to the Sites, we make no other use of this information.
TRANSFER OF INFORMATION
As we continue to develop our business, we may participate in corporate transactions such as mergers and acquisitions, and it is possible that another company may acquire ZEN or its business assets in the future. If ZEN elects, in its reasonable discretion, to transfer ownership or control of the Sites to a third party, whether or not in the context of an acquisition of ZEN or a merger of ZEN with a third party, you consent to the transfer of your personally identifiable information and non-personally identifiable information to that third party, provided that all use of your information by that third party remains subject to the terms of this Policy.
ACCESS, REVIEW, UPDATE
Users may review, delete/deactivate and update the personal information that was previously provided to us by contacting us. We may ask you to provide identification before progressing with your enquiry.
OTHER WEB SITES; LINKS
Third-party web sites may be accessible through the Sites. These third party web sites have their own privacy and data collection policies and practices. ZEN is not responsible for any actions or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing personally identifiable information through linked web sites.
CONSENT TO THE USE OF THIRD PARTY PROVIDERS
In addition to the specific third parties noted in this Policy, ZEN may also contract with other third parties to provide various services to ZEN relating to the Sites on an outsourced basis rather than performing the services itself. For example, ZEN may contract with an email provider to handle the distribution of email messages to subscribers of the Sites. Likewise, ZEN may contract with a web site hosting provider to host all or a portion of the Sites for ZEN. By visiting the Sites, all visitors consent to ZEN providing both personal and non-personal information received from those visitors to these third party providers for the purpose of enabling the third party provider to provide these outsourced services to ZEN. In addition, all visitors consent to the collection, maintenance, and processing of their personal and non-personal information by ZEN and these third party providers.
NOTIFICATION OF CHANGES
If we decide to change the Policy, we will either notify users by way of an email or post material changes on the Sites so our users are aware of what information we collect, how we use it, and if we disclose it. Unless we seek and receive your consent, we will use information in accordance with the Policy under which the information was last collected. Users may prevent their information from being used for purposes other than those for which it was originally collected by emailing us at email@example.com.
We will use at least industry standard measures on the Sites to protect the loss, misuse or alteration of the information under our control. We use a secure server hosting location, firewall protection, controlled access and secure data storage to protect your data. We do not store your passwords in plaintext, nor do we store your credit card information on our systems. The Sites fully support SSL and current encryption standards. We also limit access to your data to our employees whom we believe reasonably need to come into contact with that information. While no system is guaranteed to be completely secure, we work hard to ensure our security measures protect all information in a responsible manner.