Last updated: February 19, 2020

This Privacy Statement (“Statement”) describes the types of information the Zettar , Inc. (collectively, “Zettar”, “we,” “our,” or “us”) collect through our websites, including the website at www.zettar.com (our “Sites”), together with all related websites, networks, applications, and other services provided by us and on which a link to this Statement is displayed (collectively, with the Sites, our “Offerings”). This Statement describes the information that we gather from you in connection with our Offerings, how we use and disclose such information, the steps we take to protect such information, and how you can exercise your data protection rights.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided under the “Contacting Zettar” section.

Access this Privacy Statement

If you are unable to access this Statement due to a disability or any physical or mental impairment, please contact us by emailing us at info@zettar.com and we will endeavor to supply you with the information you need in an alternative format that you can access.

What We Collect and How We Use It

Information you provide voluntarily

When you use our Offerings, you voluntarily provide us with information about you. We use this information for the following business and commercial purposes:

• Account Registration. We collect information that is necessary for you to register an account with us, log in to your account, and use features of our Offerings. Collected usually includes your name, contact details, company, geographic area, preferences, job title, and password. This information also allows us to manage your account.
• Order and purchase. We collect information that is necessary to fulfill your order of our Offerings or the purchases you make through our Offerings, such as your name, contact details, job title, company, credit card or other billing information.
• Customer communications and support: We collect information that is necessary to respond to inquiries, support requests, or any other communications you submit through our Offerings, such as your name, contact details and the content of your communications. We also use that information to communicate with you via technical notices, updates, security alerts, and support and administrative messages.
• Promotions: We collect information that is necessary to process and deliver entries and rewards in connection with promotions that we may offer from time to time, such as your name, contact details, job title, and company.
• Operate and enhance our Offerings. We collect information that is necessary to operate, maintain, enhance, and provide all features of our Offerings, such as your feedback or any other information related to your utilization of our Offerings that you provide us with. We also use that information to develop new products, services, features, and functionality.
• Direct marketing. In accordance with your marketing preferences, we may send you information forcdirect marketing. We use your name, contact details, and account information to email you with marketing offers and resources, events, newsletters, white-papers and other company updates about Zettar and other third parties.
• Other purposes. We may use the personal information you voluntarily disclose to us for any other purposes disclosed to you and with your consent.

Information we collect automatically

When you use our Offerings, we may collect certain information automatically from your device, including information like your IP address, operating system, device type, unique device identification numbers, browser-type, geographic location (by use of GPS or other location features of your device) and other technical information. We also collect information about how you use our Offerings for purposes of facilitating your use of our Offerings, including securing, managing, measuring, improving, and/or supporting our Offerings, together with developing and marketing additional products and services. We may also collect information about how your device has interacted with our Offerings including our Sites, including the pages accessed and links clicked. Some of this information may be collected using cookies and similar tracking technology. We use these cookies or similar technologies to understand and analyze the usage trends and preferences of our users, enhance and develop new products, services, features, and functionality, administer our Offerings, track user’s movements around our Offerings, store preference information in our Offerings, serve targeted advertisements, and gather demographic information about our user community as a whole.

Information from Other Sources

From time to time, we may receive personal information about you from third party sources, but only after we have checked that these third parties either have your consent (where required by law) or are otherwise legally permitted or required to disclose your personal information to us. For instance, we may obtain information such as your contact details, job title, company and interest from third-parties, such as our partners and advertisers, and from other sources outside of our Offerings, including from certain offline sources such as trade shows or publicly available sources, to market our Offerings or services and products offered by third parties, in accordance with your marketing preferences.

Web Visits Related Data

Zettar, like most websites, gathers certain information automatically to analyze trends in the aggregate and administer our Offerings. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use our Offerings, we automatically receive the URL of the website from which you came and the website to which you go when you leave our Offering. This information is used to analyze overall trends, to help us improve our Offerings, to track and aggregate non-personal information, and to provide the Offerings.

Social Media Features

Zettar websites or other Offerings may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address and which page you are visiting on our website, and may set a cookie or other similar technologies to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on our Offering to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are either hosted by a third-party or hosted directly on our Offerings. Information collected in the context of the Social Media Features is subject to the relevant social media
platforms’ own data collection, use, and disclosure policies.

Your Rights and Choices

Depending on your location and applicable data protection laws, you may have the right to request access to, or correction, deletion or removal of, information about you, by using “Contacting us” form. To protect your privacy and security, we may take steps to verify your identity before granting access, deleting or making changes to information you have provided us, including by requesting your name and email address. While we will make reasonable efforts to accommodate your request, we also reserve the right to reject such access requests or to impose certain restrictions and requirements on such requests, if required or permitted by applicable law.

If you receive marketing communications from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out by writing to us at the address given at the end of this Statement. Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may continue receiving promotional communications from us during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our Offerings.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We do not discriminate against any individual based on the exercise of their data protection rights.

Information Sharing

Except as described in this Statement, we will not disclose information about you that we collect on or through our Offerings to third-parties without your consent, unless legally required or permitted to do so. We may disclose information to third-parties if you consent to us doing so and in the following circumstances:

Any information that you voluntarily choose to include in a publicly accessible area of the Sites or any of our Offerings will be available to anyone who has access to that content, including other users.

We work with third-party service providers to provide website, application development, hosting, maintenance, sales enablement and other services for us. These third-parties may have access to or process information about you as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain
the confidentiality of such information.

We may share your information with our partners in connection with, selling or distributing our Offerings, or engaging in joint marketing activities, in accordance with your marketing preferences.

We may disclose your information if required to do so by any competent law enforcement body, regulatory, government agency, court or other third-party where we believe disclosure is necessary to comply with applicable law or regulation, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to 1) take precautions against liability, 2) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, 3) investigate and defend ourselves against any third-party claims or allegations, 4) protect the security or integrity of our Offerings and any facilities or equipment used to make our Offerings available, or 5) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

Information about our users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third-parties as one of our business assets in which case the acquirer, successor or assignee will use your personal information in line with this Statement.

We may make certain aggregated, automatically-collected, or otherwise non-personal information available to third-parties for various purposes, including (a) compliance with various reporting obligations; (b) for business or marketing purposes; or (c) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through our Offerings.

Security

At Zettar, security is always a high priority. We use physical, managerial, and technical safeguards that are designed to improve the integrity and security of information that we collect, process and maintain. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Security is an evolving area and Zettar is constantly working to not only raise the level of security it deploys but also the security training of its employees.

Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Third-Party Services

Our Offerings may contain features or links to websites and services provided by third-parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our Offerings. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through our Offerings. We encourage you to learn about third-parties’ privacy and security policies before providing them with information.

Retention of Data

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Rights of California Residents

• Shine the Light Customer Rights
  Residents of California have the right to request a disclosure describing what types of personal information we have shared with third-parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year. You may request a copy of that disclosure by contacting us.
• California Consumer Rights Under The CCPA
  The following disclosures apply only to California residents covered under the California Consumer Privacy Act (“CCPA”).

Personal information collected for a business purpose and for a commercial purpose

The purposes for which we collect your personal information are described under the heading ” What We Collect and How We Use It” above. This section describes the business purposes and commercial purposes for which we collect personal information.

Personal information disclosed for a business purpose

This Privacy Notice describes the categories of personal information that we have, disclosed for a business purpose, and sold over the preceding twelve (12) months. Please refer to the sections headed ” What We Collect and How We Use It” and “Information Sharing” for more information.

Personal information sold

We do not and will not sell your personal information to any other business or third party. Zettar will always seek your affirmative direction/consent to intentionally disclose personal information to third parties in ways that might otherwise be construed to be a “sale” under the CCPA.

Right to know and right to delete

You have the right to request that we disclose the personal information we collect, use, disclose and sell. To exercise this right, please follow the instructions described to access your information in the “Your Rights and Choices” section above.

Minors’ Privacy

Protecting the privacy of young children is especially important to Zettar. Our Sites are general audience websites not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16 without obtaining parental consent. If you believe we have collected information belonging to an individual under the age of 16, please let us know by C ontacting us.

Changes and Updates

Please revisit this page periodically to stay aware of any changes to this Statement, which we may update from time to time. If we modify this Statement, we will make it available through our Offerings, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change and obtain your consent where legally required. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access one of our Offerings for the first time after such material changes are made.

Contacting Zettar

If you have any questions or comments about this Statement, your Information, our use, and disclosure
practices, or your consent choices, please contact us using the Contact us form or write to us at the following address with a postal mail.

Zettar Privacy
Zettar, Inc.
650 Castro Street, Suite 120-470
Mountain View, CA 94041
United States