Zonat, SA Policy
Last modified: November 6th, 2020
This Policy explains what kind of Personal Data we collect from you as well as the purpose of our collecting and using the data, how long it is retained, with whom we share it, and your rights concerning the data.
This Policy applies if you are an individual actual or prospective customer, regardless of your nationality or residence. It does not apply to companies/organizations (although it may apply as to specific individuals within such companies/organizations). Nor does it cover how you or other users may use or share data that they collect using our Services.
Please read this Policy carefully. By accessing or using Services, you are agreeing to this Policy so if you do not agree to be bound by its terms you should not use our Services. By accepting the Policy you are also certifying that you are of the legal age of majority in the jurisdiction where you reside. If you have not yet reached the age of majority you may not use our Services.
This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
This policy applies to Personal Data that we collect:
On our website(s).
In e-mail, text and other electronic messages exchanged between us and/or through our website(s).
When you interact with advertising and applications of third-party websites and services appearing on our website(s). However, it does not cover any aspect of your interaction with a third party site (even if accessed via our website) or any data collection or use by such third parties.
What is Personal Data?
Not all data is “Personal Data”. For the purposes of this Policy the term “Personal Data” means information that, acting alone or together with other data elements that we have, is sufficient to identify you as a specific natural person. Examples of Personal Data elements may include: a name, an identification number, location data, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity as a particular natural person.
Information We Collect About You and How We Collect and Use It
Although more details are provided below, we generally use information that we collect about you (or that you provide to us), including any Personal Data:
To present our website(s) and its contents to you.
To allow you to participate in interactive features on our website(s).
To provide you with information or Services that you request from us.
To provide you with notices about your account, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our website(s) or any Services we offer or provide though it.
To fulfill any other purpose for which you provide it.
In any other way we may describe when you provide the information to us.
For any other purpose consistent with your consent.
We may collect and process the following categories of information, some or all of which may include Personal Data:
Account Data. We may obtain and process data regarding any registration or subscription process regarding any of our Services. Account Data may include information you provide during a registration process, including in connection with any co-branded offer or third party goods/services provided through our website(s). This information may include your user name, company name, and other identifying information such as your physical or shipping address, email address, user name, IP address, billing address, credit card or other payment data, geographic location and industry, and any preferences you may have established using our Services. It may also include age-verification data that we may be required to obtain to establish that you are of the legal age of majority. Account Data may be obtained and processed for the purposes of operating our website(s), providing our Services in the manner in which you have requested, ensuring the security of our Services, preventing or investigating attacks and/or fraud, maintaining back-ups of our databases and communicating with you. Our legal basis for this processing is your consent and provision of this data to us, our entry into and performance of any agreement you may have with us, the delivery of Services you may have ordered, our legal obligations as required to comply with applicable law regarding age verification, maintenance of proper accounts, attend to security issues and prevent or investigate attacks and/or fraud, protection against money laundering, our need regarding the maintenance of banking and payment processing relationships, and the proper operations of our business.
User Content Data. We may also collect and process information that you post for publication on our website(s) or through the use of our Services as user contributions – for example, and if available, by submitting a blog posting or a support Ticket. User content data can include content you upload and any metadata associated with the upload, ratings and/or reviews and/or comments you may post to any forum, or information you include or exchange with any other user on our website(s). User Content Data may also be shared with third party websites that publish all or parts of User Content Data available on our website(s). Examples of such instances include affiliates (with whom we may share your review and ratings as a part of our marketplace functionality) and Google (which may reproduce all or a portion of your User content data in its publicly available search results). The legal basis for our collection and processing of such data is your consent (by submitting the User Content Data). Our legitimate interest in processing this data is namely to perform the Service(s) as and in the manner you have requested, attend to security issues and prevent or investigate attacks and/or fraud, address actual or asserted violations of legal rights, and to properly administer our Services.
You should generally consider your User Content Data you share with this Website to be public in nature and you should not share any information that you would not want to become known to the general public. User contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of our website(s) with whom you may choose to share your user contributions. Therefore, we cannot and do not guarantee that your user contributions, and any User Content Data contained therein will not be viewed by unauthorized persons. Discretion is a key part of your responsibilities. Moreover, if you delete your User Contributions from our website(s), copies of your user contributions, and any User Content Data contained therein, may remain viewable in cached and archived pages, or might have been copied or stored by other website users.
Customer Contact Data. We may collect and process information contained in any inquiry you submit to us regarding Services. Such data may include your name and other identifying information such as your physical or shipping address, email address and/or IP address, the communication content, and metadata associated with the communication. Our legal basis and legitimate interest for obtaining and processing such data is to communicate with you, respond to your inquiries, and offer, market and sell relevant Services as requested, attend to security issues and prevent or investigate attacks and/or fraud, maintain our record keeping, and properly administer our business.
Sales Data. If you engage in transactions with our website(s), we may obtain and process information you supply relating to such transactions, including the purchase and shipping of Services, that you request from us or through our website(s). Such data may include your user name, name and other identifying information such as your physical or shipping address, email address and/or IP address, your payment details, sales tax exemptions, and other information directly related to the specific transaction. The legal basis for obtaining and processing such data is to enter into and perform any contract we may have with you for the purpose of supplying Services and issuing and maintaining invoices and other proper records of those transactions, our legal obligations as required to comply with applicable law regarding age verification, maintenance of proper accounts, attend to security issues and prevent or investigate attacks and/or fraud, protection against money laundering, our need regarding the maintenance of banking relationships, and the proper operations of our business.
Solicitation Data. We may also obtain and process data that you may voluntarily provide to us for the purpose of subscribing to our email notifications and/or newsletters. Subscription to our mailing list requires a double opt-in process, pre-checked with a "General" category opt-out. You may subscribe using the forms available on our website(s). Subscribers receive periodic email notices that include special offers, information about sales, promotions, new releases, and other relevant information. To unsubscribe from any list, click on the link at the top or bottom of the email and type your email address in the field marked "unsubscribe." Or go to your client area and change your account settings. Our legal basis for obtaining this data is your consent when you opt into such programs. We may legitimately process this data to send you the relevant notifications and/or newsletters as you have requested, attend to security issues and prevent or investigate attacks and/or fraud, and the proper operations of our website(s) and business.
Also, in connection with the formation and duration of our relationships with resellers, we may obtain and process information in each of the categories described in this Policy. We may obtain some such data directly from the resellers. Our legal basis and legitimate interest in obtaining and processing such data is our entry into and performance of any agreement we may have with the reseller, the delivery of Services they may have ordered (or that you may have ordered through such reseller), our legal obligations as required to comply with applicable law regarding age verification, maintenance of proper accounts, protection against money laundering, our need regarding the maintenance of banking relationships, attend to security issues and prevent or investigate attacks and/or fraud, and the proper operations of our website(s) and business.
Social Media Data. We may receive, use and retain information from third party social networking sites with your consent (as you provided to the social media site), including information that social networking sites provide to us if you use your credentials at such social networking sites to log into some of our Services (such as your name and email address to pre-populate our sign-up form).
Usage Data - Cookies And Other Automatic Data Collection Technologies. As you navigate through and interact with our website(s) and Services, we may use automatic data collection technologies to collect Usage Data and other information about you, your equipment, browsing actions, and patterns. Such data is collected automatically as you enter and navigate through our sites by our platform using various tools and software applications, including cookies and other tracking technologies.
Usage Data includes the following:
Details of your visits to our website(s), including traffic data, location data, logs and other communication data and the resources that you access and use on our website(s).
Information about your computer and Internet connection, including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
The information we collect automatically helps us to improve our website(s) and to deliver a better and more personalized Service, including by enabling us to:
Estimate our audience size and usage patterns and analyze site traffic.
Store information about your preferences, allowing us to customize our website(s) according to your individual interests including recognizing you when you return to our website(s).
Enhance and make our website(s) and Services more efficient and responsive.
Attend to security issues and prevent or investigate attacks and/or fraud, and the proper operations of our website(s) and business.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You can control flash cookies from your browser.
Flash Cookies. Certain features of our website(s) may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our website(s). You can control flash cookies from your browser.
Session Cookies. A session cookie lasts as long as you are online. We use these cookies to identify your shopping cart and its contents and to help us personalize your experience. These session cookies help us facilitate any promotions or surveys that we provide. These cookies do not contain any Personal Data and we do not store data collected by them.
Persistent Cookies. As part of the sign-in process, we may also use what are commonly called persistent cookies, which stay with you and are on your computer, after your session is over and you are offline. We use these cookies in connection with a sign-in feature that allows you to remain partially logged in so that the next time you sign in, you will only need to provide your password.
Cookies do not typically contain any Personal Data (e.g. information that personally identifies a user), but personal information that we store about you may be linked to the information stored in and obtained from cookies. We store this data (along with Social Media Data) in a variety of places within our infrastructure, including system log files, back end databases and analytics systems.
OTHER REASONS FOR DATA COLLECTION & PROCESSING.
We may obtain, process and retain any of your Personal Data, whether or not identified in this policy:
Where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests to protect and assert our legal rights, your legal rights, and the legal rights of third parties.
Where necessary and as legitimately required for us to secure and maintain adequate insurance policies, manage risks, ensure the security of our website(s) and services, attend to security and prevent or investigate attacks and/or fraud in order to legitimately protect our website(s) and business against risks.
To the extent reasonably is necessary to comply a legal obligation to which we are subject, or to protect the vital interests of you, us or any third party.
Important. Please bear in mind that the data we collect may fall within one or more of the categories set forth above. In such an instance, the legal basis and legitimate interest in our collection and/or processing of such data is inclusive and we will apply the legal basis and legitimate interest most favorable to our activities with regard to such data.
DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
We may disclose your Personal Data to third parties insofar as reasonably necessary for the relevant purposes and on the relevant legal basis set out in this Policy. This includes the following:
To any member of our group of companies (including our subsidiaries, our ultimate holding company and all its subsidiaries);
To our resellers or third party suppliers insofar as reasonably necessary for the purposes described regarding “Account data”, “Sales data” and “Affiliation data” in order to provide the Services you have requested;
To one or more of our third party advertisers or suppliers of Services identified on our website(s) for the purpose of enabling them to contact you so that you can receive the goods or Services you have purchased while using our website(s);
To contractors, service providers and other third parties to the extent reasonably necessary for the maintenance, security, and proper operation of our website(s) and our provision of Services;
To our insurers and/or professional advisers to the extent reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, prevention or investigation of security breaches and fraud, obtaining professional advice, or the establishment, exercise or defense of legal or equitable claims, whether in court proceedings or in an administrative or out-of-court procedure;
To a potential buyer or other successor (and/or their advisors) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our website(s) users is among the assets transferred;
To our payment services providers to the extent necessary for the purposes of processing or refunding payments or addressing complaints and queries relating to such payments or refunds;
To the extent reasonably necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of a third person;
To third party service providers to the extent reasonably necessary to fulfill, provide and ship Services you have purchased through our website(s);
Consistent with the purpose for which you agreed to provide it; and/or,
With your consent.
SHARING OF INFORMATION
Generally, we may transfer your Personal Data between different jurisdictions. However, in doing so we will comply with the European Data Protection Directive 95/46/EC (“GDPR”) and other applicable laws regulating the protection for the transfer of personal information between jurisdictions. This means that we may transfer your data to the United States, the EU, or other countries subject to conditions. If you are a European resident, we will endeavor to confirm that either the European Commission has determined that the receiving jurisdiction provides adequate protection of Personal Data or that other appropriate safeguards are in place, namely the use of relevant standard data protection clauses adopted or approved by the European Commission. Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.
Please note that if you access our services through a tool that hides your location, such as a VPN, or if you access our Services through a location other than where you reside, you may not receive our request for permission because we were not able to identify you as being located in a jurisdiction where your permission is required.
SHARING WITHIN THE CORPORATE FAMILY
We may share your Personal Data with other members of our corporate family so that they can contact you with services (or offers) that may be of interest to you and/or so that they can provide you with Services or assistance regarding Services provided by one or more members of our family. Any such use or processing will be pursuant to the terms of this Policy. If you are located in a jurisdiction where such sharing requires your permission, we will only do so with your consent.
SHARING WITH PARTNERS
When we share personal information with certain third-party affiliates, including marketing and advertising partners, that information may include your name, email address and other information so that our partner may assist you in using our products and services, contact you with offers, services or products that may be of interest to you, and/or provide you with their products or services.
SHARING WITH THIRD PARTY SERVICE PROVIDERS AND VENDORS
We rely on others to provide some of the support and services we provide to you. We form contracts with these vendors and service providers for this purpose (for example providing banking, payment processing/gateway, IT, and storage services including back-ups or to aid us in our security measures or marketing activities.
If you purchase a product or service from a third party through one of our websites, we will pass your personal information to such third party in order for them to fulfill your order.
From time to time our website(s) may portray advertisements or links to third party websites and sources. If you activate such link you will be interacting with such third party and we will retain a record of your having responded to the advertising or link. We may provide such third party with general non-Personal Data necessary to identify our website(s) as the source of any interaction you may have with such third party. However, each such third party will act as a data controller/processer in relation to data that they obtain or receive and when you interact with such third party you will be subject to their Policy, which will govern any of your Personal Data that you provide to them. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
If we are involved in a merger, acquisition, a sale of any part of our business, we may be required to disclose information to the counter-party.
Anyone that you (or if you are a company/organization, your company) authorizes to have access to your account or any Services, may be able to view Personal Data stored in connection the account or any subaccount to which they may have access.
If we are, or in good faith believe disclosure is reasonably necessary to comply with our legal obligations in any relevant jurisdiction, we may disclose information about you, including Personal Data, to courts of law, people acting under color of law, law enforcement authorities and other relevant third parties, such as internet service providers, attorneys or investigators, to conduct an investigation, respond to a third party or law enforcement subpoena or court order, bring legal action, prevent harm to others or pursue other relief when you or a third party are or, in our good faith belief, may be:
Disclosures can include transferring your information to the U.S. and other countries outside the European Economic Area. To the extent we are legally permitted to do so, it is our policy to notify you in the event that we are required to provide your personal information to third parties in connection with a subpoena. For transfers of Personal Data to third parties, such transfers will either (i) be under the European Commission’s model contracts for the transfer of Personal Data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU; or (ii) rely on the EU-US Privacy Shield Framework.
THIRD PARTY LINKS AND INFORMATION COLLECTION AND USE BY OUR USERS
Some of our Services provide links to other websites. We do not control the information policies or practices of these third party sites and you should carefully review their privacy policies to learn about how they collect, use and share your personal information.
From time to time we may permit you to log into your account and access our Services using single-sign-in services such as Facebook. These services will authenticate your identity to us and may allow you to control what information these services share with us, thus providing you with options regarding sharing certain personal information with us (e.g. your name and email address to pre-populate our sign up form). Using certain social media features, such as “like”, “share”, “widgets” or interactive mini-programs that may run on our website(s) may result in the applicable social networking sites collecting Personal Data and other data regarding you and your activities, including your IP address, which page you are visiting on our websites, and may set a cookie to enable it to function properly. You should carefully review the applicable privacy policies of such third party services to learn about how they collect, use and share your personal information.
The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk. Once we have received your information, we will take good faith measures to safeguard your personal information within our systems against loss, theft and unauthorized use, access or modification.
Through our provider, Google Analytics, data is collected about use of our website(s). We will not provide Google Analytics with your name, phone number, email address or credit card information. We assign a random number to your usage so that Google Analytics can identify a unique user of our website(s) although Google Analytics does not associate that number with your personally identifiable information. We recognize that you may prefer to limit or eliminate the data that Google Analytics collects about your use of our website(s). Google Analytics does provide an "Opt-out" option. You can review instructions and relevant information about Google Analytics at: http://www.google.com/intl/en/analytics/privacyoverview.html.
In some cases it is not possible for us to specify in advance the periods for which your Personal Data will be retained. In such cases, we undertake to determine a period of retention based upon the relevant applicable statute of limitations as concerns any claim you may have as against each other based upon your interaction with our website(s) and/or the order or delivery of any goods or services and to attend to security issues and prevent or investigate attacks and/or fraud, maintain our record keeping, and properly administer our website(s) and business.
In any event, we may retain your Personal Data where retention is necessary for legal or regulatory compliance purposes or in order to protect the vital interests of either of us or of a third party.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the information you provide to us. We have created mechanisms to provide you with the following control over your information:
Promotional Offers from the Company. If you do not wish receive solicitations promoting our own Services or those of our partners or third parties, you can opt-out by following the unsubscribe link in any email, by logging into our website(s) and adjusting your user preferences, or by sending us an e-mail stating your request to: firstname.lastname@example.org and including as the subject: unsubscribe me.
Accessing and Correcting Your Information
You can review and change some of your Personal Data and some other Non-Personal Data via your account. However, your right to change or delete information is subject to exceptions generally referenced in this Policy.
If your physical or email address changes, please advise us in writing or update your user account information so our records remain up to date and there is no delay to your receipt of Services. We are not responsible for incomplete services due to your failure to accurately maintain such information.
To exercise any of your rights in relation to your Personal Data, or to request access to, correct or delete any personal information that you have provided to us, please contact us by e-mail at email@example.com and/or by letter to Zonat, SA Customer Service 14, Rue Robert Stumper, L-2557 Luxembourg. User names cannot be modified once created. Certain Personal Data may not be deleted unless you also delete your accounts with us – which means terminating our Services. There are exceptions to our obligation to delete or modify your Personal Data. In general, we may not accommodate a request to delete or change information if the change would violate any law or regulation or if retention is necessary to exercise the right of freedom of expression and information, comply with a legal obligation, attend to security issues and prevent or investigate attacks and/or fraud, maintain our record keeping, and properly administer our website(s) and business, to protect the vital interests of you, us, or any third party, or for the establishment, exercise or defense of legal claims.
We reserve the right to require proof of identity and residence, and (subject to applicable legal restriction) to obtain reasonable compensation as a condition to providing access to, modifying or deleting your data.
If you delete User Content Data from our website(s), copies of your User Content Data may remain viewable in cached and archived pages, or might have been copied or stored by other website users or third parties over which we have no control (e.g. Google).
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our website(s) that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us at: firstname.lastname@example.org subject=California Privacy Rights Inquiry.
Special Rights For European Residents.
If you reside in the European Union you may have additional rights as set forth under the European Union’s General Data Protection Regulation 2016/679 (“GDPR”). The GDPR is a complex regulatory scheme and we have not provided an exhaustive summary in this Policy. We advise you to read the regulation and guidance provided by the relevant regulatory authorities for a full explanation of your rights.
Your principal rights under the GDPR are access, rectification, erasure, processing restriction or objection, portability, withdrawal of consent and the right to complaint to a regulatory authority. These rights are not absolute and exceptions apply. For example, we may not accommodate a request to delete or change information if we can demonstrate compelling legitimate grounds that override your interests or the change would violate any law or regulation or if retention is necessary to exercise the right of freedom of expression and information, comply with a legal obligation, attend to security issues and prevent or investigate attacks and/or fraud, maintain our record keeping, and properly administer our website(s) and business, to protect the vital interests of you, us, or any third party, or for the establishment, exercise or defense of legal claims.
If the legal basis for our processing your Personal Data is your consent, or the necessity to comply with your requests, or for the performance of a contract we have with you, and we are automatically processing your Personal Data, you have the right to receive from us a copy of such Personal Data in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time subject to applicable exceptions. Withdrawal will not affect the lawfulness of processing before the withdrawal.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.
We commit to resolve complaints about our collection or use of your Personal Data as required under the applicable Principles of the Privacy Shield. EU individuals with inquiries or complaints regarding our policies and their inter-relation with Privacy Shield principles should first contact our Data Protection Officer at email@example.com.
If you have a complaint concerning our use of relevant Personal Data, which remains unresolved by other means, you may have the right to binding arbitration. The pre-conditions for arbitration, and your rights in this regard are more fully described on the Privacy Shield website which as of the date of this Policy was located at: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any ordering/payment transactions will be encrypted using SSL technology using third party gateway/processors.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website(s), you are responsible for selecting one that is strong and keeping it confidential. We ask you not to share your password with anyone. We also urge you to be careful about disclosing any personal information in public areas of our website(s). The information you share in public areas may be viewed by any user of our website(s).
The transmission of information via the Internet (e.g. email) is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information while it is being transmitted to our website(s). Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our website(s).
Changes to Our Policy
We may modify this Policy at any time by publishing a new version on our website(s). It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on our website(s) home page and/or by email. The effective date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our website(s) and this Policy to check for any changes.
To ask questions or comment about this Policy and our privacy practices, contact us at:
Our website(s) is owned by Zonat, SA Customer Service 14, Rue Robert Stumper, L-2557 Luxembourg.
Our representative in the European Union for the purposes of our obligations under the European General Data Protection Regulation (GDPR) is Frederick Schiwek, Zonat, SA Customer Service 14, Rue Robert Stumper, L-2557 Luxembourg, e-mail: firstname.lastname@example.org Tel: +352 202 123 3970
If any provision of this Policy is held by a court or other tribunal of competent jurisdiction to be invalid, illegal or unenforceable for any reason, such provision shall be eliminated or limited to the minimum extent such that the remaining provisions of the Policy, as amended from time to time, will continue in full force and effect. Links to other websites and webpages appearing in this Policy are as of the effective date of this Policy and are subject to change without notice. Accordingly, we provide no assurance that such links remain accurate or correct following the effective date of this Policy.