PRIVACY POLICY June 7, 2019

ZOOLATECH, INC. — a boutique service provider, specializing in high-end software development — together with its affiliates and subsidiaries (collectively ZOOLATECH or WE) has prepared this Privacy Policy (the POLICY) to outline its online data protection practices, set forth your privacy rights, describe the types of data that we collect at ZOOLATECH.COM (the WEBSITE) and explain how we process it.
The POLICY may change from time to time; therefore, we recommend you to check this page occasionally to inform yourself of any changes. If you do not agree to the terms of the POLICY, please do not access or use the WEBSITE.

TABLE OF CONTENTS

  1. WHAT PERSONAL DATA DO WE COLLECT
  2. HOW WE USE YOUR PERSONAL DATA
  3. YOUR RIGHTS IN RELATION TO PERSONAL DATA
  4. HOW LONG DO WE KEEP YOUR PERSONAL DATA
  5. SHARING AND TRANSFERRING YOUR PERSONAL DATA
  6. HOW WE PROTECT YOUR PERSONAL DATA
  7. WHAT ARE COOKIES AND HOW DO WE USE THEM
  8. HOW TO CONTACT US

1. WHAT PERSONAL DATA DO WE COLLECT

PERSONAL DATA is any information that relates to you and that identifies you either directly or indirectly, by reference to other information that we have access to. We collect PERSONAL DATA directly from you; depending upon how you interact with us, we may collect, store and use the following categories of PERSONAL DATA:

2. HOW WE USE YOUR PERSONAL DATA

Depending on the relationships we have or wish to have with you, we may use your PERSONAL DATA for the following purposes:

YOUR RIGHTS IN RELATION TO PERSONAL DATA

You have the following rights over the way we process PERSONAL DATA relating to you, as set out below:

(A) THE RIGHT OF ACCESS. If you ask us, we will confirm whether we are processing your PERSONAL DATA and, if necessary, provide you with a copy of such data (along with other details). There are exceptions to this right; for example, where information is legally privileged or if providing you with the information would reveal PERSONAL DATA about another person.

(B) THE RIGHT TO DATA PORTABILITY. You have the right, in certain circumstances, to receive your PERSONAL DATA provided by you to us and the right to reuse it elsewhere or to send the data to another organization (or ask us to do so if technically feasible) where our lawful basis for processing the PERSONAL DATA is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

(C) THE RIGHT TO RECTIFICATION. You may require us to update or correct any inaccurate PERSONAL DATA, or to complete any incomplete PERSONAL DATA, concerning you. If you do, we will take reasonable steps to check the accuracy of, and correct the data. Please let us know if any of your information changes so that we can keep it accurate and up to date.

(D) THE RIGHT TO WITHDRAW CONSENT. If we rely on your consent (or explicit consent) as our legal basis for processing your PERSONAL DATA, you have the right to withdraw that consent at any time. Your withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

(E) THE RIGHT TO OBJECT. You can ask us to stop processing your PERSONAL DATA, and we will do so, if we are:

(F) THE RIGHT TO ERASURE. You can ask us to delete or remove your PERSONAL DATA in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your PERSONAL DATA with third parties, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your PERSONAL DATA with so that you can contact them directly.

(G) RIGHT TO RESTRICTION OF PROCESSING. You can ask us to ‘block’ or suppress the processing of your PERSONAL DATA in certain circumstances, such as where you contest the accuracy of that data or you object to us. If you are entitled to restriction and if we’ve shared your PERSONAL DATA with third parties, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your PERSONAL DATA with so that you can contact them directly.

(H) RIGHTS IN RELATION TO AUTOMATED DECISION-MAKING AND PROFILING. You have the right to be free from decisions based solely on automated processing of your PERSONAL DATA, including profiling, that affect you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent. That is why we request your consent before analyzing your PERSONAL DATA (on our own or via our providers) to build individual profiles. These profiles may be used to find out your interests and display targeted (online) advertisement. The aim is to provide you with offers that are relevant for you. The profiling is based on repeated interaction with the WEBSITE, emails, and content. As we will not collect your name and other important PERSONAL DATA, such as addresses or bank details in the course of such profiling, we expect that such profiling will have no further impact, other than providing you with a more pleasant user experience when surfing the Internet. No automated decisions will be made that would result in legal effects or similarly significantly affect an individual.

(I) THE RIGHT TO COMPLAIN. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your PERSONAL DATA, you can report it to the relevant supervisory authority.

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process your PERSONAL DATA or where such data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations. You can exercise the above rights, where applicable, by contacting us at privacy@zoolatech.com. To ensure that your PERSONAL DATA is disclosed only to you, we will require you to provide satisfactory proof of your identity.

4. HOW LONG DO WE KEEP YOUR PERSONAL DATA

We do not keep your PERSONAL DATA for any longer than is necessary to fulfill the purpose for which we collected it (for example, we will keep your PERSONAL DATA obtained in connection with your subscription to our emails until you unsubscribe, PERSONAL DATA obtained in connection with your service inquiries – until the matter of inquiry is resolved). We may therefore retain your PERSONAL DATA for a reasonable period after your last interaction with us.

5. SHARING AND TRANSFERRING PERSONAL DATA

Since Zoolatech is headquartered in U.S. and has no branches offices in EU countries, your PERSONAL DATA will be mostly processed outside of the EEA.

Still, we do our best to protect your data by sticking to appropriate internal policies and using state-of-the-art security means that follow EU requirements for the safe and lawful processing of PERSONAL DATA.

We do not share PERSONAL DATA with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or as described herein. We may share PERSONAL DATA with our subsidiaries and affiliated companies where necessary in connection with the purposes described in this POLICY – for example, we may share PERSONAL DATA with our affiliates that may be involved in the provision of services requested by the user of the WEBSITE. We also may transfer your PERSONAL DATA to our third party service providers, such as our IT systems providers, our website hosting providers, data analysis, data backup, security and cloud storage services, consultants and other providers.

We work with such providers so they can process your PERSONAL DATA on our behalf. We will only transfer PERSONAL DATA to them when they meet our strict standards on the processing of data and security and flow those same standards down to their sub-processors. We only share PERSONAL DATA that allows them to provide their services and will not transfer the PERSONAL DATA you provide to any third parties for their own direct marketing use.

6. HOW WE PROTECT YOUR PERSONAL DATA

We have security measures in place to protect your PERSONAL DATA, which involve preventing, detecting, investigating and resolving security threats. We have implemented technical and organizational measures to safeguard and secure your PERSONAL DATA. All our personnel and third parties that we engage to process your PERSONAL DATA are obliged to respect your data’s confidentiality.

We restrict access to your PERSONAL DATA, and only employees who need to access it to perform specific jobs are granted with such access. We are working with service providers and third-party players to ensure that physical security of computer hardware and software solutions are at the highest level.

Although we use industry-standard precautions to safeguard your PERSONAL DATA, we cannot guarantee that our precautions will prevent every unauthorized attempt to access, use or disclose personal data. We endeavor to protect personal data, but 100% complete security does not presently exist anywhere online or offline.

7. WHAT ARE COOKIES AND HOW DO WE USE THEM

Cookies are tiny text files containing a small amount of user and website information and stored in your web browser on your device. These files help us enhance WEBSITE navigation and improve its functionality, analyze WEBSITE usage, and assist in our marketing and advertising efforts. They are not harmful and do not contain any information such as your home address, date of birth or credit card details.

Cookies can remain on your computer or mobile device for different periods of time. Some of them are session cookies and are automatically erased when you close your browser, while others are persistent cookies and remain on your hard drive until you manually erase them or they expire.

We use cookies for a number of reasons, like improving your browsing experience and measuring effectiveness of the WEBSITE. The cookies we use fall into one of the following categories:

All information collected by our cookies is aggregated and therefore anonymous.

In some special cases we also use cookies provided by trusted third parties. Such cookies may be placed on your device by someone providing a service for us in order to provide us with better insights into the use of the WEBSITE or user demographics or to provide relevant advertising to you.

Most internet browsers are initially setup to automatically accept cookies. You can refuse cookies by adjusting the appropriate settings on your browser; though, in such case all or parts of the WEBSITE may not be functional or accessible to you.

8. HOW TO CONTACT US

If you have questions or complaints regarding this POLICY or the way your PERSONAL DATA is processed, or would like to exercise a legal right in relation to your PERSONAL DATA, please contact us by one of the following means:

Email:
privacy@zoolatech.com