ZENTUNEZ PRIVACY POLICY
Last updated: August 31, 2023
1. Introduction
This privacy policy (“Privacy Policy” or “Policy”) explains how Zentunez LLC, a Georgia limited liability company and its subsidiaries and affiliates, which are set forth below (collectively, “Company”, “We” and “Us”) process information on our mobile applications and websites, or in connection with subscriptions for Company products and services that are linked to or contain the URL for this Privacy Policy (all of the foregoing, collectively, “Services”) and that Company may collect offline or from third parties. Certain third-party sites or apps where we collect information are considered “Services” when linked to this Privacy Policy, but this Policy does not otherwise apply to other information collected through the third party website(s). This Privacy Policy is incorporated into and subject to the Services’ Terms of Use. By using the Services, you acknowledge you have read and understand this Privacy Policy. If you do not agree to the Terms of Use and this Privacy Policy, you must discontinue using the Services.
For the purposes of data protection laws, Company is the data controller. Company’s address is
260 Howard St
Suite 6
Atlanta GA 30317
2. The Information We Collect
We obtain information from or about you when you use our Services. The information we collect and the purposes for which we use depends on the specific Services you use and how you interact with Company. For example, we collect the information you provide when you enter a contest, complete a survey, participate in a beta test, register for a part of our Services, make a purchase, request a refund, participate in our social networking features, subscribe to our publications, or send us an email or feedback. If you post material to any forums or our social networking features or other community boards offered on our Services, such materials will be collected and some information, including your posted pseudonym, may be publicly available for others to view.
We, or our service providers on our behalf, may collect the following information about you or your use of the Services:
Information You Provide to Us:
· Registration or Contact Information such as e-mail address, name, phone number, and address.
· Customer service information such as questions and other messages you address to us directly through online forms, by email, over the phone, or by post; and summaries or voice recordings of your interactions with customer care.
· Demographic, statistical and interest information such as interests, lifestyle information, hobbies, health and wellness information, your age, date of birth, gender, income and other personal finance information, sexual orientation, and race or ethnicity (to the extent permitted by and in accordance with applicable law). You may provide this information in connection with registering for the Services or events, participating in surveys on the Services, or other opportunities to provide profile or interest information.
· Financial and transactional information such as order information, billing information, and credit or debit card number or payment account information (processed by our payment processors), verification number, and expiration date, to process payments and information about your transactions and purchases with us.
· User-generated content such as comments on articles, photos, videos, audio, any information you submit in public forums or message boards, reviews and feedback or testimonials you provide about our Services.
· Research or survey information (including contact information and user generated content) collected if you participate in a survey. Surveys are voluntary and may request information any of the demographic, statistical and interest information above. In some circumstances, our surveys may embedded on our Services and your responses are associated with your other information including device identifiers or cookies and contact information (to the extent we have such information).
· Sweepstakes information (including contact information and user generated content collected if you participate in a sweepstakes or contest, including information needed for you to participate and information required to fulfill your prize). For prizes over a certain value, we may collect social security number for tax purposes.
· Contact Information about others, (including personal identifiers) such as name and mailing address to send a gift or use our send-to-a-friend functionality. If you use send-to-a-friend on our Services, your email address may be included in the communication sent to your friend.
· Social media information (which may include contact information, photos, location, user generated content, demographic information) if you link your account or access the Services through a third-party connection or log-in, we may have access to any information you provide to that social network depending on your privacy settings such as your name, email address, friend list, photo, gender, location, and current city; and information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, Snapchat, WordPress, and Twitter)
· Other information You choose to provide directly to Company in connection with your use of the Services.
Information We Collect Automatically:
· Device information and identifiers such as IP address; time zones, browser type and language; operating system; ISP provider; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers.
· Internet network and device activity data such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, products, goods or services viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services, the web sites you visit after this web site; if you share our content to social media platforms; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information. See “Cookies and Other Tracking Technologies” below for more information about how we collect and use this information.
· Geolocation information such as country, city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation; time zones; and precise geolocation information from GPS-based functionality on your mobile devices, with your permission in accordance with your mobile device settings.
Information from Third Parties:
· We may also collect the information outlined above (except “Other Information You Choose to Provide”), such as contact information, demographic and interest information listed above, social media information, as well as product ownership, purchase history, political views, religion, union or guild membership, and professional information (such as your title and employer) from other sources such as public and commercial data sources, affiliates, entities providing conferences and other events, marketers, social media networks, third party advertising partners in accordance with your privacy preferences on such services, and partners such as those providing surveys or operating sweepstakes for or with us. We use this information to update, validate or supplement the information that you provide or we collect automatically, to target our communications so that we can inform you of products, services and offers that may be of interest, and for internal research, analytics and improvement of our Services. If other users of the Services provide information about you, such as your name and mailing address, including to send a gift or to use our send-to-a-friend functionality, we collect that information from such users.
· Please note: certain information such as precise location, health data, union membership, race or ethnicity information is considered “sensitive” under certain laws. For certain jurisdictions, we do not process data that is considered sensitive. For others, if we process information that is deemed sensitive under applicable law, we do so as permitted by and in accordance with applicable legal requirements.
3. How We Use the Information We Collect
Depending on the Services you use and how you use them, We, or Our service providers, may use your information to:
Provide the Services you request, including to maintain and service your account, by:
· Processing and fulfilling your transactions.
· Maintaining and servicing your account.
· Sending communications that you have requested.
· Administering your entries into sweepstakes, contests, promotions, or surveys.
· Providing community features and post your content .
Communicate with You & Provide Customer Service to Provide the Services, including through:
· Transactional or service communications, such as to notify you when you have won one of our contests or sweepstakes or other promotions, when we make changes to subscriber agreements, to send you an email newsletter, process refund requests, or to contact you about your account.
· Responses to your requests for information.
· Customer service and technical support.
Personalize your experience to Provide the Services, by:
· Customizing certain features of the Services.
· Delivering relevant content and to provide you with an enhanced experience based on your activities and interests.
· Sending you personalized newsletters, surveys, and information about products, services and promotions offered by us, our partners, and other organizations with which we work .
· Customizing the advertising on the Services based on your activities and interests.
· Creating and updating inferences about you and audience segments that can be used for targeted advertising and marketing on the Services, third party services and platforms, and mobile apps.
· Conducting cross-device tracking by using information such as IP addresses and unique mobile device identifiers to identify the same unique users across multiple browsers or devices (such as smartphones or tablets), in order to save your preferences across devices and analyze usage of the Service.
Use inferences about your preferences and interests for any and all of the above purposes
Republish Information You Provide on the Services, by:
· Pursuant to our Terms of Use, using and editing information submitted by you in response to opportunities provided on the Services, which you provide to us through emails, blogs, forums, in response to polls, or through any other user generated submission, for editorial purposes, including your name, likeness, photograph, and biographical information you provide, with or without attribution, including publication via the Services, and in trade media, and advertising.
Improve the Services and develop new services, by:
· Engaging in analysis, research, and reports to better understand how you use the Services, so we can improve them and develop new services.
Our Marketing and Third-Party Marketing and Advertising Purposes, by:
· Sending you newsletters, promotional emails, surveys and information about products, services and promotions offered by us, our partners, and other organizations with which we work.
· Customizing content and advertising that we or our third-party partners deliver on the Services (e.g., targeted third-party advertising).
· Creating and updating inferences about you and audience segments that can be used for targeted advertising and marketing on the Services, third party services and platforms, and mobile apps.
· We may combine the information we collect about you, including from third parties, and conduct cross-device tracking for the marketing and advertising purposes above.
Bug detection and error reporting, including to understand and resolve technical issues, app crashes and other issues being reported.
Audit consumer interactions on the Services including to measure the placement, frequency, efficacy and compliance of advertising and ad impressions.
Security, Fraud, and Legal Compliance, including by detecting, protecting against, and prosecuting security incidents, fraud, and illegal activity including to:
· Monitor, prevent, and detect fraud, such as through verifying your identity.
· Combat spam or other malware or security risks.
· Monitor, enforce, and improve the security of our Services.
· Comply with any applicable procedures, laws, and regulations, subpoenas, governmental requests or legal process, or in connection with a legal investigation, if in our good faith opinion such is required or permitted by law.
· Establish, exercise, or defend our legal rights (e.g., to enforce compliance with our Terms of Use, Privacy Policies, or other contracts or legal rights).
· Protect or defend our Services, users, or others.
Aggregate and/or De-Identified Information.
· We may aggregate or anonymize information and/or de-identify any information collected through the Services so that such information can no longer reasonably be linked to you or your device (such information, “Aggregate/De-Identified Information”). We may use and disclose this Aggregate/De-Identified Information for any purpose permitted under the law.
4. How We Share the Information Collected
Company may disclose information collected from and about you on the Services to other companies or individuals as set forth below:
Service Providers. We may provide access to information to vendors that perform services on our behalf, including subscription and order fulfillment, event and travel coordination, managing our email lists and sending email messages on our behalf, processing payments, providing customer support, providing analytics, and performing other administrative services, in order to carry out such services.
Our Affiliates. We may disclose information we collect within the Company family of companies to deliver products and services to you, ensure a consistent level of service across our Services, internal management and administrative purposes on our behalf and enhance our products, services, and your customer experience.
Information You Disclose Publicly. You may submit photographs, user profiles, written material, music, video, photos, comments and other content, which may include information relating to your and/or other individual users (collectively, “UGC”) on the Services. We do not control who will have access to the UGC you choose to make public or how they will use it and take no responsibility for ensuring such UGC remains private or is secure. We are also not responsible for the accuracy, use or misuse of any UGC that you disclose or receive through the Services. Please see our Terms of Use for further information about the terms that govern the UGC you post.
Other Individuals, Services, and Partners at Your Request. We will disclose your information to other individuals and services at your request.
Third Party Contests and Promotions Providers. If you enter a contest or sweepstakes sponsored by a third party, the information you provide via the contest or sweepstakes may be disclosed to that third party for their use subject to their own policies.
Third Party Partners to Provide Co-Branded Products and Services. From time to time, we may partner with a retailer or other third party to offer products, services, subscriptions, events and summits, and other applications on a co-branded or cross-promotional basis (“Co-Branded Areas”). The information you provide in connection with Co-Branded Areas may be collected directly by, or disclosed by Company to, the third party, as well as with any participating sponsors or advertisers of such Co-Branded Areas. These third parties will use your information in accordance with their own privacy policy.
For Marketing Purposes. We may disclose your information to third parties whose offerings may interest you such as other marketers, magazine publishers, retailers, participatory databases, event sponsors and non-profit organizations. This includes licensing information about your interests and activities, and marketing segments created with such data, which we may disclose to third parties for their marketing purposes.
Third-Party Online Advertisers, Ad Networks and Advertising Partners. As discussed in the “Online Analytics and Advertising” Section below, the Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use. These technologies will collect certain information from your use of the Services to assist in delivering such ads and marketing messages and enhancing our information. These third parties may include advertising networks, data exchanges, ad servers, certain analytics providers and others. Except for the choices provided by Company herein, this Privacy Policy does not govern the use of cookies or other tracking by such third parties. In addition, we sometimes provide certain information (such as email addresses) to service providers, who may “match” this information in hashed form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.
For Legal Purposes. By using the Services, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of Company, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Social Networks. As noted above, if you use your login credentials from a social media networking service on a Publication, we may receive information from such service in accordance with its terms and privacy policy and your settings. If you elect to share your information with these social networking sites, we will disclose information to them in accordance with your election. The terms and conditions of these social networking sites will apply to the information we disclose to them.
Sales or Transfer of Business or Assets. In connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise, including via bankruptcy) of all or a portion of the business conducted by the Publication to which this policy applies, in which case the company will possess the information collected by us and will assume the rights and obligations regarding your information as described in this Privacy Policy (the “Acquisition Use”).
5. Legal Grounds for Using (Processing) Your Information
If you are a visitor from the European Economic Area, our legal basis for collecting and using the information described above will depend on the information concerned and the context in which we collect it. We collect information from you:
· Where we need it to perform our contract with you (i.e. our Terms of Service) in order to provide the Services you request;
· Where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights) to secure our Services, prevent misuse, prevent fraud, and resolve technical issues; respond to your requests for information and provide you with more effective and efficient customer service; contact you regarding the Services, as well as surveys, promotions, special events, and other subjects that we think may be of interest to you (in accordance with applicable legal requirements); better understand your interests and improve our Services; personalize the Services; conduct internal business operations in support of our Services, such as auditing, sales and marketing, analytics, and research and development; and establish, exercise, or defend our legal rights;
· Where we have obtained your consent to send you marketing and other commercial communications and use non-strictly necessary cookies where local law requires such consent for such marketing and cookies (please note these requirements vary by jurisdiction and not all jurisdictions require consent for such uses) or use your information as set forth in a release or in connection with a consent; or
· To comply with our legal obligations.
· We may also collect and use personal information in connection with your consent in other circumstances, which will be presented to you at the time of collection. You can revoke your consent at any time, though you might not be able to use a service or feature that requires collection or use of that personal information.
6. Your Rights & Your Choices
A. Marketing Choices
Email. If you want to stop receiving promotional e-mails from us (which we send pursuant to applicable law), click on the “unsubscribe” link in any promotional email from us. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. We may still send you transactional communications such as receipts or updates to this Privacy Policy or our Terms of Service.
SMS Text Communications. You may opt-out of SMS messages from us (which we send pursuant to applicable law) by following the instructions provided in the message or by texting back STOP to the number we send the text from for that particular SMS message. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.
B. Cookies
You may have the ability to accept or decline (or opt out of) certain cookies for analytics & targeted advertising on our Services depending on your jurisdiction. Some analytics providers we partner with may provide specific opt-out mechanisms. For example, to prevent Google Analytics from using your information for analytics, please see the Google Analytics Opt-out Browser Add-on. You may choose whether to receive some forms of targeted advertising from many ad networks, audience segment providers, ad serving vendors, and other service providers by visiting websites operated by the Network Advertising Initiative and Digital Advertising Alliance or if you are a user in the European Economic Area, Your Online Choices. Many mobile devices allow you to opt-out of targeted advertising for mobile apps using the settings within the mobile app or your mobile device. Please note that if you exercise your opt out choices, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.
C. Privacy Rights
Laws in certain jurisdictions grant consumers the right to exercise certain controls and choices regarding our collection, use, and disclosure of your information.
If you are a California or Virginia resident, or a resident of the EEA, UK, Canada, or Switzerland, you may request:
· Access to and/or a copy of certain personal information we hold about you.
· Correction of inaccurate personal information we hold about you.
· Deletion of certain personal information we have about you.
· Information about the financial incentives that we offer to you, if any.
· Restriction of or objection to certain processing of your information,
· Withdrawal of your consent to our use of your information for certain processing purposes, where the processing purpose was based on your consent.
Residents of California and Virginia also have sale/targeted advertising opt out rights described below.
California residents can also:
· Request information about the categories of personal information we collect, disclose or sell or share about you; the categories of sources of such information; the business or commercial purpose for collecting or selling or sharing your personal information; and the categories of third parties to whom we disclose personal information. Such information is also set forth in this Privacy Policy.
· Limit processing of sensitive personal information as described in the California Privacy Notice below by clicking on the Your Privacy Choices link in the site footer and following the directions.
Residents of certain other countries may be able request one or more of the above under applicable law.
Applicable law may further provide you with the right to not be discriminated against for exercising your rights.
Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information for legal compliance or in order to provide the Services to you. Your rights and our responses will vary based on your state or country of residency. You may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.
Verification: We will take reasonable steps to verify your identity before responding to a request, which may include, depending on your request and relationship with you verifying your name, email address, address, and/or having you respond to an email from us.
California residents are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, we may require proof of your written authorization before processing the request. We may also follow up with you to verify your identity before processing the authorized agent’s request.
D. Sale/Targeted Advertising Opt Out Rights (California, Nevada, & Virginia Residents)
If you are a California or Virginia resident, you also have the right to opt out of our sale of personal information or processing or sharing of your information for online targeted advertising purposes.
California and Virginia residents may opt out of the “sale” of their personal information or processing or sharing of your information for online targeted advertising purposes. We sell or share certain of your information to third parties that may directly provide you with offers and promotions and opportunities that may be of interest to you.
We also allow third parties to receive certain information, such as cookies, IP address, and/or browsing behavior and information about your potential interests or characteristics, to deliver targeted advertising to you on the Services or other services. This activity may also be considered a sale under applicable law. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.
Depending on what Services you use, we may sell the following personal information or share or process it for targeted advertising:
Contact information; device information and identifier; connection and usage data; demographic and statistical information, including age, date of birth, gender, income and other personal finance information, religion, union or guild membership, and race or ethnicity; interest information including, health and wellness information, lifestyle information, hobbies, product ownership, purchase history or intentions; user-generated content; geolocation; and social media information.
If you would like to opt out of Company’s sale, sharing or use of your information for such purposes, you may do so. Even if you opt out, you will still see advertising, it just may be less relevant to you, or it may be personalized for you based only on the data that Company has collected about you. You must opt out on each device and each browser and for each brand where you want your choice to apply. Your preference may be lost if you clear, or your browser is set to clear, cookies. If you have enabled a legally recognized browser-based opt out preference signal (such as Global Privacy Control) on your browser, we recognize such preference in accordance and to the extent required by applicable law. You will need to turn this on for each browser you use.
E. Subscriber Preferences
Subscribers to our Services may change their subscription-related mail and email preferences at any time via the Services.
Despite your indicated preferences, we may send you service related communications, including notices about your subscription, and we may continue disclosing your information to third parties as set forth under the Service Provider Use, the Legal Use and the Acquisition Use sections above.
7. Retention of Your Information
We keep your information for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
8. Cookies and Other Tracking Technologies
We use and allow certain other companies to use certain tracking technologies, including cookies, web beacons, and other similar technologies (collectively, “Cookies”) on the Services. To see an explanation what these technologies are and why we use them, as well as your rights to control our use of them please see our cookie notice (“Cookie Notice”). We endeavor to adhere to the Digital Advertising Alliance’s (DAA) self-regulatory principles governing interest-based advertising.
9. Links to Third Party Sites
When you are on the Services, you may be directed to other websites that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. If you access a third-party website from the Services, you do so at your own risk, and you understand that this Privacy Policy does not apply to your use of such websites.
10. Security
We implement appropriate administrative, technical and security safeguards to help prevent unauthorized access, use, or disclosure of the information we collect. However, no systems can be completely secure. Therefore, while Company uses reasonable efforts to protect your information, Company cannot guarantee its absolute security, and your use of the Services indicates your agreement to assume this risk.
11. Special Note For Parents
The Services are for a general audience and are not designed or intended for use by children, especially those under age thirteen (13) or sixteen (16) in the EU.
12. Transfer Information to the United States
The Services are operated in the United States of America (USA) and are intended for users located in the USA. If you are located outside of the USA, please note that the information you provide to us will be processed in the USA, where laws regarding processing of personal data may be less stringent than the laws in your country. Where applicable law requires certain mechanisms or safeguards prior to the transfer of data from another entity in another jurisdiction to the United States, we will implement such safeguards.
13. Changes to This Privacy Policy
We reserve the right to change this Privacy Policy at any time without prior notice. Any changes will be effective immediately upon the posting of the revised Privacy Policy.
14. Disputes; No Rights of Third Parties
If you choose to access the Services, subscribe to our Publications or use any of our Services, any dispute over privacy is subject to our Terms of Use, including limitations on damages, resolution of disputes by binding arbitration, and application of the laws of the United States, and the State of Georgia. This Privacy Policy does not create rights enforceable by third parties.
15. Contact Us: Data Privacy Officer
If you have any questions or concerns about any aspect of this Privacy Policy, please contact our Data Privacy Officer at the address set forth below.
Data Privacy Officer
Zentunez, LLC
260 Howard St
Suite 6
Atlanta GA 30317