Last Updated: March 10, 2023
Zooltech is a group of companies, including Zoola Tech Inc., its parents, subsidiaries, and affiliated entities (“Zoolatech,” “we,” “us,” “our”) that respect your privacy and we are committed to protecting it through our compliance with this Privacy Policy and all applicable laws and regulations. We have created this Privacy Policy to inform you of our policies regarding the collection, use, and disclosure of personal information (also referred to here as “personal data”) as well as the rights and choices you may have associated with that information. For any requests or inquiries in relation to this Privacy Policy, please see the Contact Us section below.
If you are interested in applying to a job position in Zoola Tech, in addition to reading this privacy policy regulating the processing of your personal data as a website visitor, please also read the Privacy Notice – Job seekers and applicants.
This Privacy Policy applies with respect to access to and use of Zoolatech’s internet properties including, without limitation, www.zoolatech.com, microsites, mobile websites, mobile applications, and any other digital services or properties operated or used by Zoolatech from time to time that links to this Privacy Policy (collectively referred to as the “Site(s)”). It is an integral part of the agreement between you and us concerning the use of the Site(s).
Zoolatech’s internet properties are owned and operated by Zoola Tech Inc. The websites that are owned and operated by Zoolatech may contain links to digital properties that are owned and operated by other companies. This Privacy Policy does not apply to websites and services that are owned and operated by unaffiliated third parties.
If you do not agree with this Privacy Policy, please discontinue the use of our Sites immediately.
This Privacy Policy applies also to our processing of personal data of our business contacts, (potential) customers, and (potential) suppliers, including people providing services to us through third parties such as outsourcing or recruitment entities.
This policy explains who we are, why and how we process personal data, and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to. It explains the rules applicable to the processing of personal data by the companies of Zoolatech group in business, commercial and marketing relations.
Variances to this policy may apply to regulate the processing of personal data in accordance with specific local laws, where they exist.
Personal data / personal information – all information related to you that we process. For example: first name, last name, e-mail address, telephone number, information about your professional experience, etc.
Processing – all activities performed in regard to your personal data. For example: collecting, retaining, updating, sending messages to you, deleting data.
GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).
UK GDPR – GDPR incorporated into law in the UK as amended by the Data Protection, Privacy and Electronic Communications (Amendments, etc.) (EU Exit) Regulations 2019.
CCPA – California Consumer Privacy Act of 2018, including as amended by the California Privacy Rights Act of 2020.
We are Zoolatech a boutique service provider, specializing in high-end software development — together with its affiliates and subsidiaries.
As a rule, each of the companies from the Zoolatech group independently decides about the purposes and methods of personal data processing, which means that each of them is a separate data controller – depending on which company you contact, conclude a contract with, run business relations with etc., this company, usually, will be the data controller of your personal data.
It may also happen that a particular company performs activities for another company from the Zoolatech group, e.g. related to marketing – in this case, the company that performs such activities does not become the data controller of your personal data, but processes it on the basis of a data processing agreement concluded with the data controller.
Except as otherwise described in this Privacy Policy, in most cases the entity responsible for processing personal data outside of the European Economic Area, Switzerland and the UK is Zoola Tech Inc.
We may process personal data relating to you if:
We do not knowingly solicit data online from or market to children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information without parental consent, we take steps to delete such information.
We may process personal data relating to you that we have either obtained from you, or from somewhere else. Therefore, your personal data can be processed:
The scope of personal data we process depends on the information that is vital for a given relationship – it primarily encompasses the content of documents, our communication, along with other information we have obtained from publicly available sources (e.g. LinkedIn). Personal data relating to you that we process may include:
Your submission of personal data is generally voluntary, but sometimes it may be necessary e.g. to conclude or execute a contract, to respond to your query or to communicate with you.
Information that we automatically obtain from you when you use our website, including:
We may use a variety of technologies to collect information about your device and use of our Sites. These technologies include first- and third-party cookies and web beacons. Most web browsers can be programmed to accept or reject the use of some or all of these technologies, although you must take additional steps to disable or control other technologies.
If you want to learn the correct way to modify your browser settings, please use the Help menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser.
For more information on how to opt-out of tracking technology from Google Analytics, click here.
From time to time Zoolatech may organize or take part in a promotional event, e.g. a conference, fairs, or lecture (“Event”), which you may attend as a guest, speaker, host, etc. (“Participant”). Events are usually recorded on videos or photographs (sometimes with a help of a third party acting on our behalf), therefore your image, including voice and utterances (“Image”) may be recorded and used, with neither geographical nor temporal restriction, nor with restriction as to the medium and number of copies, for the purpose of sharing information about the Event and for promotional purposes of Zoolatech.
To the extent permissible by law, participation in the Event is equivalent to each Participant granting free of charge consent to the use and multiple dissemination of their Image recorded during the Event. Such consent may be withdrawn at any time. Where, for the above activities of Zoolatech, the applicable law requires the explicit consent of the person whose Image has been recorded, Zoolatech will collect such proper consent from you.
Please note, that if you decide to participate in an Event, your personal data, including an Image, might get published for an indefinite period of time on the Internet, in a manner that may allow an unrestricted number of people to view it.
We process your personal data for the following purposes:
We may share your personal data, where legally allowed, for the following purposes:
(a) When We Work Together – We may share information between and among Zoolatech Inc., its parents, subsidiaries, and affiliated companies for purposes of management and analysis, decision-making, and other business purposes. For example, we may share your information with our parents, subsidiaries and affiliated companies to process orders and requests and to expand and promote our product and service offerings.
(b) When We Work with Service Providers – We may share your information with service providers that provide us with support services, such as website hosting, email, and postal delivery, product and service delivery, analytics services, or conducting academic research. We contractually prohibit these service providers from retaining, using, or disclosing your personal information for any purpose other than performing agreed upon services for us.
(c) When We Work on Business Transactions – If we become involved with a merger, corporate transaction or another situation involving the transfer of some or all of our business assets, we may share your information with business entities or people involved in the negotiation or transfer.
(d) When Sharing Helps Us Protect Safety and Lawful Interests – We may disclose your information if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms or supply terms and other agreements with you; or to protect the rights, property, or safety of Zoolatech, our customers, employees or others. This includes exchanging information with other companies and organizations (including law enforcement bodies) for the purposes of fraud protection and other risk reduction.
(e) When We Work with Marketing Service Providers – We may share your information with marketing service providers to assess, develop and provide you with promotions and special offers that may interest you, administer contests, sweepstakes and events or for other promotional purposes.
(f) When You Give Consent – We may share information about you with other companies if you give us permission or direct us to share the information.
(g) When the Information Does Not Identify You – We may share your information in a way that does not identify you, in particular by combining it with similar information about other people and sharing the aggregated information for statistical analysis and other business purposes. For example, we may share information about your use of our Sites.
Access to your data is restricted to those who need it for the purposes outlined above, and generally, they will only have access to that part of the data relating to you that is relevant to the particular purpose concerned.
We may share your data with duly authorized Zoolatech employees or professionals who assist us in running our business and who are subject to security and confidentiality obligations. Whenever personal data is disclosed to a third party in this way, it will only be to the extent necessary to perform their duties, to perform our contract with you, or for the purposes of our legitimate interests.
We may share your personal data with:
The basis on which we process your personal data is as follows (where legally applicable).
Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it (for example, some direct marketing activities), we will obtain and rely on your consent in relation to the processing concerned
Otherwise, we will process your personal data only where the processing is necessary:
Another applicable legal basis can be mentioned in the country-specific sections below.
We process personal data only for so long as is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived unless it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject, or for another legitimate and lawful purpose.
The above periods may be extended, if necessary, in the event of any claims and court proceedings – for the duration of these proceedings and their settlement.
Sometimes your data may be available in the mediums such as the Internet for an indefinite period.
Zoolatech operates internationally and, therefore, personal data may be processed in countries that may not have data protection regulations as stringent as those in your country including in the United States, India and Ukraine. We will transfer such information to third countries in accordance with the applicable privacy laws, in particular GDPR, particularly to each country in which Zoolatech conducts business, or has a service provider, for the purposes set out in this document.
Zoolatech applies all required safeguards, including standard data protection clauses adopted by the relevant authorities. We may also transfer your data to a country that ensures an adequate level of protection according to the European Commission’s decision.
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. All personal data processed by us is stored on secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website or systems, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee or warrant the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
You should be aware that other Internet sites that are linked from the Site(s) or from a Zoolatech email message may contain privacy provisions that differ from the provisions of this Privacy Policy. To ensure your privacy is protected, we recommend that you review the privacy statements of these other linked sites, applications or other digital properties.
To exercise your rights please contact us at [email protected] or by other means as convenient for you.
Zoolatech respects all applicable privacy laws and your rights under the applicable legislation – in particular you can request that we delete your data, or withdraw your consent for personal data processing. You can also opt-out of receiving marketing communication by using the “unsubscribe” link included in the emails we send you, or by contacting us as described below.
Please note that we are legally obliged to confirm your identity before we can process your request, so you may be asked to provide some further information.
We reserve the right to amend the Privacy Policy at any time, for any reason. The date of the last revision to the Privacy Policy will be indicated by the “Last updated” date at the beginning of this page. We encourage you to look for updates and changes to this Privacy Policy by checking this date when you access our Sites.
You can contact us at [email protected]
List of companies of the Zoolatech Group
| USA | ZOOLA TECH INC. |
| USA | ZOOLA TECH LLC |
| UKRAINE | ZOOLA TECH UKRAINE LLC |
| MEXICO | ZOOLATECH MEXICO, S. DE R.L. DE C.V. |
| POLAND | ZOOLA TECH POLAND SP. Z O.O |
| ROMANIA | ZOOLA TECH ROMANIA SRL |
This section applies only to Argentina residents. Zoolatech processes personal data in compliance with Argentina Personal Data Protection Law No. 25,326 (“PDPL”), Regulatory Decree No. 1558/2001 and the provisions and resolutions issued by the Argentine Agency of Access to Public Information (“AAAPI”).
In addition of the legal bases introduced in the main body of this Policy we may also process your data for compliance with a scientific or professional relationship with you, provided that these are necessary for its development or fulfillment.
You have the following rights:
The California Consumer Privacy Act, as amended by the California Privacy Rights Act (“California Privacy Laws”) requires us to disclose the following additional information related to our privacy practices. If you are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, this section applies to you in addition to the rest of this Privacy Policy.
In the preceding 12 months, depending how you interact with our Sites, we may have collected the following categories of Personal Information (as defined under Cal. Civ. Code §1798.140(v)(1)):
For more information about the Personal Information we collect and how we collect it, please refer to “Information We Collect” section above.
We collect your Personal Information for the business purposes described in the “How We Use Your Personal Data” above.
The categories of third-parties with whom we may share your Personal Information are listed in the “Who We Share Your Personal Data With” section above.
If you are a California resident, you have rights in relation to your Personal Information as identified below; however, your rights are subject to certain exceptions and are not absolute. We may deny your request: (a) when denial of the request is required or authorized by law; (b) when granting the request would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.
You may exercise your rights by contacting us at [email protected] or via another method identified in the “Contact Us” section above. In your request, please make clear which right you would like to exercise. Before fulfilling your request, we are required by law to have you to verify the Personal Information we already have on file to confirm your identity. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
If you use an authorized agent to submit requests on your behalf, we will require you to directly verify your identity with us, or have you directly confirm with us that the authorized agent has been authorized to act on your behalf.
Direct Marketing If you are a California resident, you can request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes. To request a notice, please submit your request at [email protected] or by postal mail as described in the Contact Us section.
This section applies to processing of personal data that is within the scope of the GDPR or UK GDPR – when it is carried out by a Zoolatech group company that has its seat or establishment within the European Economic Area (including the European Union), Switzerland or the UK or concerns data subjects who are in the EEA, Switzerland or the UK. In case of any doubts please contact us at [email protected].
Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it (for example, direct marketing activities), we will obtain and rely on your consent in relation to the processing concerned.
Otherwise, we will process your personal data only where the processing is necessary:
We process data regarding use of our website for the purpose of proper management of our website, to improve its performance, ensure its security, adapt its content to your preferences. In addition, we gather this data for internal purposes, including resolving issues, conducting data analyses, testing, research, statistics, and for survey purposes. The legal basis of our activities is your consent, except for cases when the use of such data is essential for the functioning of our website (electronic provision of a service to you within that scope); in such cases the legal basis will be our legitimate interest (Art. 6(1)(f) GDPR).
As a rule, personal data will be processed:
unless the law or an authority requires that we process such data for a longer period, or in case of potential claims, for such claim’s limitation period specified by law – whichever is longer.
Once the relevant storage periods have elapsed, your Personal Data will be destroyed, deleted, or irreversibly anonymized.
You have the following rights:
8.When despite your objection we find that there are compelling legitimate grounds for the processing which override your interests, rights and freedoms, or basis for the establishment, exercise or defense of legal claims, we will continue to process data covered by the objection to the extent necessary. If you disagree with such an assessment of the situation, you can exercise your right to file a complaint with the relevant public authority (more information below).
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. Complaints to the relevant public authority – in connection with our actions as the controller of your personal data, you are entitled to lodge a complaint to the relevant supervisory authority. You can find list of local authorities responsible for data protection across the EU and their contact details at: https://edpb.europa.eu/about-edpb/board/members_en. The relevant public authority in the UK is the Information Commissioner’s Office https://ico.org.uk/global/contact-us/. The relevant public authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC) https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/task.html. Of course we encourage you to first contact us at [email protected].
This section applies only to Mexican residents, Zoolatech processes personal data in compliance with the Federal Law for the Protection of Personal Data Held by Private Parties (“LFPDPPP”), its Regulation of the Federal Law for the Protection of Personal Data Held by Private Parties (“RLFPDPPP”) and its Guidelines for the Notice of Privacy, hereinafter “Mexican Data Protection Legislation”.
We inform you that the personal data we collect is established in the sections “Information we Collect”, “Information you Voluntary Provide to Us”, “Information we collect automatically”, “Information We Collect from Other Sources”, “Cookies and Similar Technologies” and “Your Image”.
We remind you that we do not collect sensitive personal data as established in the Mexican legislation for the protection of personal data.
In the section “How we use your Personal Data; the Purpose of the Treatment” the purposes established in said section will be considered as necessary under the Mexican data protection legislation with the exception of the following which will be considered voluntary:
For voluntary purposes, you may object through the mechanisms established in the section “ARCO Rights and other rights”.
Regarding the section “How We Share Your Personal Data” and “ Who We Share Your Personal Data With”, we inform you that the transfers marked in subsections “c) When We Work on Business When we work in commercial operations” your consent is necessary.
Also, for the purpose established in subsection “e) When We Work with Marketing Service Providers” your consent is necessary.
By accepting this Privacy Notice, you consent to data transfers that require your consent. However, you may oppose them at any time through the mechanisms established in the section “ARCO Rights and other Rights”.
As the owner of your personal data, you can exercise your rights of Access, Rectification, Cancellation and Opposition (the well-known “ARCO” rights), request the limitation of the use and disclosure of your personal data, oppose secondary purposes, oppose the transfers that require your consent, revoke the consent you have given us to process your personal data.
Your request must contain, at least, the following information: a) name, address or other means to communicate the answer; b) document that proves your identity or your personality as representative of the owner of the personal data; c) clear description of the personal data in respect of which you wish to exercise a right and which right you wish to exercise; d) elements or documents that facilitate the location of the data; e) In case of requesting the right of rectification, you must indicate the corresponding modifications to the personal data.
We will respond to your request within 20 business days of receiving your request. If appropriate, we will make it effective within the following 15 business days.
It will be understood that we have given you access to your personal data when we make it available to you, regardless of what means or format, as long as it is understandable. Before giving you access to your data, you have to prove your identity, this is for your own security.
This section applies only to processing of personal data collected within the territory of Ukraine, specifically by a Zoolatech group company (as a data controller) that has its seat or establishment in Ukraine.
Within described processing, you have all rights of the data subject set by Art. 8 of the Law of Ukraine “On Personal Data Protection”. Among other, you have the following rights:
8.Complaints to the relevant public authority – in connection with our actions as the controller of your personal data, you are entitled to lodge a complaint to the relevant supervisory authority or to the court. For Ukraine the supervisory authority is the Ukrainian Parliament Commissioner for Human Rights. You may find contacts of his office at https://www.ombudsman.gov.ua/. Of course we encourage you to first contact us at [email protected].
International Data Transfers. As mentioned, Zoolatech operates internationally and, therefore, personal data may be used in countries outside of the EU/EEA, which may not have data protection regulations as stringent as those in EEA. Providing to us your data you agree on their transfer outside Ukraine and the EEA. In any case, for such international transfers we ensure use of appropriate guarantees regarding non-interference to your personal and family life.