HOW WE CAN HELP YOU
WHAT INFORMATION IS COLLECTED BY US
In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. We will only collect the information that is necessary for its specified, concrete, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our services or respond to your queries. Depending on the service you choose, we may collect the following types of information:
INFORMATION YOU PROVIDE TO US
We may collect any personal information you provide to us, which is necessary for the service you choose. For example, you may provide your Zuvi Account information when you log in; you may provide us your email address if you wish to receive news or updates from us.
INFORMATION THAT WE COLLECT IN YOUR USE OF SERVICES
We may collect log information related to your use, such as cookies, IP addresses. Log information is information related to your use of certain features of the websites. For example, cookies and IP addresses, network request information, standard system logs, crash information, log information generated by using the services (such as access time, activity time, etc.). We use such information in aggregated form to improve your experience while using our apps and websites.
We collect information such as information about your activities on our websites. We use such information in aggregated form to provide you with more useful information and to understand which parts of our websites, products and services you are most interested in. In its aggregated form, data is not personal information and cannot be used to identify you. However, if we combine non-personal information with personal information, such information will be treated as personal information.
NON-PERSONALLY IDENTIFIABLE INFORMATION
We may also collect other types of information which are not directly or indirectly linked to an individual and which may not be defined as personal information according to applicable local laws. Such information may include statistical data generated when you use a specific service (e.g. user clicks, browsing behaviors, page access events). The purpose for such collecting is to improve the services we provide to you. The type and amount of information collected depends on how you use our services.
In its aggregated form, such data is not personal information as it cannot be used to identify you. However, if we combine non-personal information with personal information, such information will be treated as personal information.
HOW WE USE THE PERSONAL INFORMATION THAT WE COLLECT
The purpose of collecting personal information is to provide you with services, and to ensure that we comply with applicable laws, regulations and other regulatory requirements. This involves:
Providing, processing, maintaining, improving and developing our services to you.
Handling your questions or requests about our services, such as sending notifications.
Conducting relevant promotional activities, such as providing marketing and promotional materials and updates. If you no longer wish to receive certain types of promotional materials, you may opt-out by the method provided in the message (such as the unsubscribe link at the bottom of the message) unless otherwise specified under applicable laws. Please also see “Your rights” below.
Internal purposes such as data analysis, research, and development of statistical information related to the use of our services for improvement.
Storing and maintaining information related to you for our business operations (such as business statistics) or for fulfilling our legal obligations.
Other purposes with your consent.
We may combine this information with other information (including information across different services or devices such as computers, mobile phones and other connected devices) to provide and improve our services and content. For example, we may use your Account details in all services you use that require a Zuvi Account.
COOKIES AND OTHER TECHNOLOGIES
Technologies such as cookies, tags, and scripts are used by Zuvi and our third party service providers and business partners (for more information see “How we share, transfer, and publicly disclose your personal information” below). These technologies are used in analyzing trends, administering the site, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. These technologies help us better understand users’ behavior, tell us which parts of our websites people have visited, as well as facilitate and measure the effectiveness of web searches. We treat information collected by cookies and other technologies as non personal information, except where Internet Protocol (IP) addresses or similar identifiers are considered personal information by local laws.
Log files: As true of most websites, we gather certain information and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we gather about you.
Local storage – HTML5/Flash: We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences .
HOW WE SHARE, TRANSFER, AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION
We do not sell any personal information to third parties.
We may sometimes share your personal information with third parties (as described below) in order to provide or improve our services, including offering services based on your requirements.
With your explicit consent or at your request, we will share your personal information within the scope of your consent/request with specific third parties designated by you.
SHARING WITH THIRD PARTY SERVICE PROVIDERS AND BUSINESS PARTNERS
To provide performance measurement, analysis, and other business services, we may also share information (non-personal information) with third parties in aggregated form. We use the information we have to help our business partners evaluate the effectiveness and coverage of their services, and understand the types of people who use their services and how people interact with their websites, apps, and services. We may also share general usage trends of our services with them, such as the number of customers in a particular group of people who purchase certain products or engage in certain transactions.
In accordance with legal requirements, legal procedures, litigation and/or requests from public agencies and government agencies, Zuvi may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.
In order to enforce our terms or protect our business, rights, assets or services, or to protect users, or if the disclosure is reasonably necessary for the following purposes (detecting, preventing and resolving fraud, unauthorized use of the service, violations of our terms or policies, or other harmful or illegal activities), we may also disclose information about you. (There may be occasions when Zuvi may collect, use or disclose your personal information without your consent if it is and only to the extent it is permitted under applicable data protection laws). This may include providing your personal information to public or government agencies; communicating with third-party partners about the reliability of your account to prevent fraud, violations, and other harmful behaviors.
In addition, we may share your personal information with:
our accountants, auditors, lawyers, or similar advisers when we ask them to provide us with professional advice; and
investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to an entity in the Zuvi Group; and
any other third parties, if authorized by you to do so in relation to a specific disclosure.
Zuvi will not transfer your information to any subject except in the following cases:
Where we have obtained your explicit consent;
If Zuvi is involved in the merger, acquisition, or sale of all or part of its assets, we will notify you of any changes in the ownership, use, and any choice of your personal information you possibly possess by email and/or by posting a prominent notice on our websites.
Zuvi will only publicly disclose your personal information under the following circumstances:
Where we have obtained your explicit consent;
Public disclosure based on law or reasonable grounds: including laws and regulations, legal procedures, litigation, or at the request of the competent government departments.
HOW WE STORE AND PROTECT YOUR PERSONAL INFORMATION
ZUVI'S SECURITY SAFEGUARDS
We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place all legally required physical, electronic and managerial procedures to safeguard and secure the information we collect from you. We will ensure that we safeguard your personal information in accordance with applicable law.
We conduct due diligence on business partners and third party service providers to make sure that they are able to protect your personal information. We also check that appropriate security standards are maintained by these third parties by putting in place appropriate contractual restrictions, and where necessary, carrying out audits and assessments. In addition, our employees and those of our business partners and third party service providers who access your personal information are subject to enforceable contractual obligations of confidentiality.
We conduct security and privacy protection training courses and tests to enhance our employees' awareness of the importance of protecting personal information. We will take all practicable and legally required steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information when transferred from you or to you via the Internet.
We handle personal data breaches as required by applicable data protection law which includes, where required, notifying the breach to the relevant data protection supervisory authority and data subjects.
WHAT YOU CAN DO
You can set a unique password for Zuvi by not disclosing your sign-in password or account information to anybody (unless such person is duly authorized by you) to avoid password leaks to other websites which may harm your account security at Zuvi. Whenever possible, please do not disclose the verification code you received to anyone (including those who claim to be Zuvi customer service). Whenever you sign in as an Account user on Zuvi websites, particularly on somebody else's computer or on public Internet terminals, you should always sign out at the end of your session.
Zuvi cannot be held responsible for lapses in security caused by third party accessing your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must notify us immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security. Your assistance will help us protect the privacy of your personal information.
Zuvi recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways Zuvi makes available to you to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings, such as sign in or out of your Account.
If you have previously agreed to us using your personal information for the aforementioned purposes, you may change your mind at any time by writing or emailing us at email@example.com.
YOUR RIGHTS TO YOUR PERSONAL INFORMATION
Depending on applicable laws and regulations, you have the right to access, rectification, and erasure of any other personal information that we hold about you (hereinafter referred to as the request).
For additional information, please write to us or contact us at firstname.lastname@example.org.
(1) Through Zuvi's particular request submission channels listed below, and your request should be in writing (unless the local law explicitly recognizes the oral request), for the protection of your information security;
(2) Provide sufficient information to enable Zuvi to verify your identity and ensure that you are the subject of the requested information or a personal legally authorized to act on the subject’s behalf.
Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.
Based on the requirements of applicable laws, a copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests for relevant information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.
If any information we are holding on you is incorrect or incomplete, you are entitled to have your personal information corrected or completed.
• Based on the requirements of applicable laws, you have the right to request the deletion or removal of your personal information where there is no compelling reason for us to keep using it. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures. If the right is upheld, we may not be able to immediately remove the information from the backup system due to applicable law and/or technology limitations. If this is the case, we will securely store your personal information and isolate it from any further processing until the backup can be cleared or be made anonymous.
You have the right to object to certain types of processing, and under certain circumstances where the legal basis for processing is our legitimate interests..
Particularly under the laws of some jurisdictions:
You have the right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.
You have the right not to be subject to a decision based solely on automated processing, which produces legal effects concerning you or similarly significantly affects you.
You have the right to apply for your personal information in a structured, commonly used format and transmit the information to another data controller.
We have the right to refuse to process requests that are frivolous requests that damage others' right of privacy, extremely unrealistic requests, requests that require disproportionate technical work, and requests not required under local law, information that have been made public, information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected.
WITHDRAWAL OF CONSENT
You may withdraw your consent previously provided to us for a particular purpose by submitting a request, including collecting, using, and/or disclosing your personal information in our possession or control.
Depending on the extent of your withdrawal of consent, please note that you may not be able to continue receiving the full benefit of Zuvi’s products and services. The withdrawal of your consent or authorization will not affect the validity of our processing carried out on the basis of the consent up until the point of withdrawal.
HOW YOUR PERSONAL INFORMATION IS TRANSFERRED GLOBALLY
If we need to transfer personal information outside of your jurisdiction, whether to our affiliates or third-party service providers, we will comply with related applicable laws. We ensure that all such transfers meet the requirements of applicable local data protection laws by implementing uniform safeguards. You can find out about the safeguards that we have in place by contacting us at email@example.com
If Zuvi shares personal data originating by you in the EEA to a Zuvi Group entity or a third party service provider outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR.
PROTECTION OF MINORS
We consider it the responsibility of the parent or guardian to supervise the child's use of our services. However, we do not offer services directly to a child or use personal data of children for the purposes of marketing.
If you are a parent or guardian and you believe that the minor has provided Zuvi with personal information, please contact us at firstname.lastname@example.org to ensure that the personal information is removed immediately and that the minor is unsubscribed from any of the applicable Zuvi services.
DO I HAVE TO AGREE TO ANY THIRD PARTY TERMS AND CONDITIONS?