Privacy Policy

1. Introduction

We, Zircoo Corporation, serve as the data controller responsible for managing Your information when You engage with our website, services, and products (collectively referred to as ‘Services’).

We value the trust You place in us by sharing Your personal information and are committed to maintaining that trust. To uphold this commitment, we aim to ensure that You have a clear understanding of the information we gather, the purposes for which we collect it, how it’s utilized, and the choices available to You regarding Your information when You interact with and utilize our Services.

This policy is crafted to outline our privacy practices in straightforward language, minimizing the use of complex legal and technical terminology.

The intent of this Privacy Policy is to provide You with clarity on the types of information we collect, the reasons behind its collection, and the options You have to update, manage, export, and delete Your information.

1.1. Privacy principles

All data is:

Fairly and lawfully processed;
Processed for a lawful specified purpose;
Adequate, relevant, and not excessive;
Not kept for longer than necessary;
Accurate;
Processed in accordance with the individual’s (data subject’s) rights;
Secure;
Not transferred to other countries without adequate protection.

1.2. Terms of Use

By accessing, using, or engaging with the resources provided in any capacity, or by utilizing, registering for, downloading, or installing the applications, websites, and services, you affirm that you have reviewed this agreement and comprehend the rights, responsibilities, terms, and conditions outlined herein. Our websites, applications, and services are exclusively accessible to individuals who are at least 18 years of age.

1.3. Table of Contents:

Purpose and Methods of Personal Information Collection and Usage
Legal Grounds for Processing
Security Measures for Your Information
Cookie Usage
Policy Amendments
Your Rights Concerning the Personal Data You Provide
Data Retention
Contact Information

1.4. EEA Representative

If you reside in a country within the European Economic Area (EEA), the services, applications, and websites are offered by Zircoo, which, as per relevant data protection laws, assumes the role of data controller/processor. Despite Zircoo’s location outside the EEA, we have appointed an internal representative to address any concerns you may have regarding the processing of your personal data. Should you have inquiries about our privacy policy or the handling of your personal data, please don’t hesitate to reach out to us.

1.5. Californian Consumers

This section pertains specifically to California consumers and outlines how we collect, utilize, and disclose Personal Data of such residents in our capacity as a business, along with the rights afforded to them. Under the California Consumer Privacy Act (“CCPA”), businesses are obligated to disclose whether they engage in the sale of Personal Data. As a business, we do not sell Personal Data. However, we may share Personal Data with third parties who serve as authorized service providers or business partners, provided they adhere to the contractual restrictions governing the retention, utilization, and disclosure of such Personal Data.

If you encounter difficulties accessing this Privacy Policy due to a disability or any physical or mental impairment, please reach out to us, and we will arrange to provide you with the necessary information in an alternative format that meets your accessibility needs.

For the purpose of this section, ‘Personal Data’ carries the same meaning as ‘Personal Information’ as defined in the California Consumer Privacy Act (“CCPA”).

We gather the following statutory categories of Personal Data:

Identifiers, such as your name, business email address, phone number, as well as your video image or photo and voice during virtual meetings with You. This information is collected directly from You or from third-party sources.
Internet or network information, including browsing and search history, collected directly from Your device.
Geolocation data, such as your IP address, obtained from Your device.
Other personal information, acquired when You interact with us online, over the phone, or via mail, such as when seeking assistance through our help desks or other support channels, participating in customer surveys, or utilizing our Services.

The business and commercial purposes for which we collect this information are detailed in the section labeled “Why Do We Collect Your Personal Data?” of this Privacy Policy. The categories of third parties with whom we share this information for business purposes are outlined in Section 8 of this Privacy Policy.

Your California Rights:

You possess certain rights concerning the Personal Data we collect or maintain about You. It’s important to note that these rights are not absolute, and there may be instances where we are unable to fulfill Your request in accordance with the law.

The right of access entitles You to request disclosure of the Personal Data we have collected, used, and shared about You in the preceding 12 months.

The right of deletion allows You to request the deletion of Personal Information collected or maintained by us, with certain exceptions.

The right to non-discrimination ensures that You will not face any discriminatory treatment for exercising Your privacy rights.

How to Exercise Your California Rights:

You can exercise Your rights independently or designate an authorized agent to act on Your behalf. For the protection of Your Personal Data, we will verify Your identity using a method appropriate for the type of request. Additionally, we may require written permission from You for Your authorized agent to make requests on Your behalf and may also need to verify the identity of Your authorized agent to safeguard Your Personal Data. Please refer to our contact details provided below.

2. What Data About You do We Collect and How Do We Collect It?

We gather various types of information from You, including:

Information that could reasonably identify or contact You, like Your name, email address, and phone number.
Data collected during virtual meetings, such as Your video image or photo and voice data, which could reasonably identify You.
Information about You that does not individually identify You, such as Internet Protocol (IP) addresses.
Non-personally identifiable data, such as the date and time of Your login, duration of time spent in the Services, features utilized, and advertisements clicked on.

3. Why and how we collect and use your personal information

We gather your personal data as an individual for various purposes, including but not limited to the following:

Accessing and Utilizing Services: When you navigate through our websites or utilize our online services and applications, we capture information essential for granting you access, ensuring the functionality of these systems, and adhering to security and legal standards associated with their operation. This includes details such as your IP address, browser, and application settings. Additionally, we track your activities during your visit to tailor your website and application experiences, such as saving your preferences and settings, and gather statistics to enhance and expand our websites, applications, and services. We solely utilize this type of personal data to support the functioning of the applications and services provided to you. Zircoo gathers information with the aim of enhancing Services and ensuring the proper functioning of applications in alignment with user expectations. When we mention using your personal information for marketing, improvement, or development of our applications or services, for safety and security reasons, or to meet regulatory requirements outside of your explicit agreement or request, we do so based on our legitimate interests or with your consent.

Responding to Your Information, Order, or Support Requests: When you reach out to us (online or offline) regarding a request for information, placing an order for a product or service, seeking support, or engaging in a forum, we collect necessary information to fulfill your request, provide access to the product or service, offer support, and maintain communication with you. This may include your name, contact details, request specifics, agreement details, and transactional information related to the fulfillment, delivery, and invoicing of your order, as well as feedback obtained through client satisfaction surveys. We retain such information for administrative purposes, safeguarding our rights, and managing our relationship with you. When we mention using your personal information in connection with a request, order, transaction, or agreement (or preparing for the same), or to deliver services requested by you (such as a website), we do so because it is necessary for fulfilling an agreement with you.

4. Legal basis of processing

If your personal information falls under the protection of EU data protection law, the legal basis for Zircoo’s collection and use of the described personal information will vary depending on the nature of the personal information and the specific circumstances surrounding its collection by Zircoo.

Typically, Zircoo will collect personal information from you under the following circumstances:

(a) When it’s necessary to fulfill a contract with you,

(b) When the processing is in pursuit of Zircoo’s legitimate interests and doesn’t override your rights,

Additionally, there may be situations where Zircoo is legally obligated to collect personal information from you, or where the information is necessary to protect your vital interests or those of another individual.

5. How do we protect your information?

The security of Your Personal Data is a top priority for us. We adhere to widely accepted standards to safeguard the Personal Data entrusted to us, both during transmission and upon receipt. Your Data is processed using computers and/or other IT-enabled tools. We implement technical and organizational measures to ensure that Your information is handled securely, protecting it against unauthorized or unlawful processing, as well as accidental loss, destruction, or damage.

Furthermore, we provide guidance and training to our personnel to ensure that Your data is processed securely in accordance with our internal data protection policies. Our systems undergo regular monitoring to detect and address potential vulnerabilities and attacks. Additionally, we routinely review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures. In the event of any suspected or detected breach of security, we reserve the right to suspend Your use of all or part of the services without prior notice. If You believe that Your account or information is compromised, please notify us immediately.

All Zircoo members, employees, and third-party service providers engaged to provide support services are obligated to adhere to our privacy standards and permit us to conduct audits for compliance.

6. Cookies

We and our service providers utilize cookies and other technologies to gather and store certain types of information whenever You engage with our Services via Your computer or mobile device. A cookie, for instance, is a small file comprising a string of characters sent to Your computer upon visiting a website. On subsequent visits, the cookie enables the site to recognize Your browser, potentially storing unique identifiers, user preferences, and other data. You have the option to configure Your browser to reject all cookies or alert You when a cookie is being sent. Nonetheless, some website features or services may not operate optimally without cookies. Additionally, some third parties may employ web beacons, which are small files utilized for tracking purposes.

Our websites employ four categories of cookies and web beacons: essential, performance, functionality, and advertising cookies.

Essential cookies and tracking technologies are vital for the operation of the Services, facilitating Your navigation and use of the Services’ features. Due to their necessity for Service operation, opting out of these cookies is not possible.
Performance cookies and tracking technologies gather data on how You utilize the Services, aiding in the enhancement of user experience.
Functionality cookies and tracking technologies help us recall Your login status and actions performed while logged into the Services.
Advertising cookies and tracking technologies, employed by third-party service providers, deliver ads to You on other third-party websites and gauge the effectiveness of our advertising endeavors. These cookies are also utilized to analyze visits to the Services and ad conversions originating from third-party websites.

7. Changes to the policy

Zircoo retains the right to modify or amend this Privacy Policy at its discretion periodically. Any changes will be made available for review here or elsewhere on Zircoo websites, services, and applications. Your ongoing use of Zircoo websites, services, and applications signifies your acceptance of such changes. This version was last updated on March 25, 2022, and prior versions are accessible upon request by contacting Zircoo.

8. Your rights regarding the personal data you provide to us

All users whose Personal Data we hold are entitled to:

Inquire about the information we hold about them and the reasons behind it:
You have the right to request details about the personal data we process. This includes seeking clarification on the purposes of collection and processing, the duration of processing, and any third parties with access to the information. You also have the right to receive your personal data in a structured, commonly used, and machine-readable format. Furthermore, you can request the transmission of this data to another controller if the processing is based on your consent or contract and is carried out by automated means.
Learn how to access the information: You have the right to know how to access and update your personal data.
Keep the information up to date: You can request corrections or removal of inaccurate personal data and completion of incomplete data concerning you.
Object to or request cessation of processing: You have the right to object to the processing of your personal data, particularly if it causes substantial, unwarranted damage or distress. In certain cases prescribed by applicable laws, you can object to the processing of your personal data.
Ensure no decisions are based solely on automated processes: You have the right to be informed about any decisions significantly affecting you that are solely based on automated processes.
Be informed of compliance efforts: You have the right to know how we are complying with our obligations under relevant data protection laws.

You may request the erasure of your Personal Data without undue delay if:
The personal information is no longer necessary for the purposes for which it was collected or processed.
– You withdraw your consent, and there’s no other legal ground for processing.
– You object to the processing, and there are no overriding legitimate grounds for processing, or you object to processing for direct marketing purposes.
– The personal information has been unlawfully processed.
– Erasure is necessary to comply with a legal obligation.

You can also request the transfer of Your Data to another Data controller, provided that the processing is based on consent or contract and is carried out by automated means.

If you encounter difficulty accessing certain information and personal data held by Zircoo, please contact us via our contact form. We will respond to requests regarding access or deletion of your personal data within 30 days.

For inquiries regarding your rights, please contact us using the provided contact details.

9. Retention

Unless otherwise specified in this Privacy Policy, the personal data you provide us will only be retained for as long as necessary to fulfill our obligations. Zircoo retains personal data for the duration required to provide services or for other essential purposes such as complying with legal obligations, resolving disputes, and enforcing agreements. Since these requirements can vary for different data types across various products, the actual retention periods may differ significantly. The criteria used to determine retention periods include:

The duration of data processing necessary to provide the services. This encompasses activities such as maintaining and enhancing service performance, ensuring system security, and keeping appropriate business and financial records. This serves as the general guideline establishing the baseline for most data retention periods.
Extended retention periods based on the data subject’s consent. If consent is provided, we will retain data accordingly.
Legal, contractual, or similar obligations requiring data retention. This may include mandatory data retention laws applicable in the jurisdiction, governmental directives mandating data preservation for investigations, or data retention necessary for litigation purposes.

10. Do we provide/disclose Your Data to the third parties?

We reserve the right to disclose aggregated information about our users and non-identifying information without restriction.

We may disclose personal information collected or provided by You in the following circumstances:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties engaged to support our business, who are obligated by contractual agreements to maintain the confidentiality of personal information and use it solely for the purposes disclosed.
For any other purpose explicitly stated by us at the time of information collection.
With Your explicit consent.

Additionally, we may disclose Your personal information:

To comply with any court order, law, or legal process, including responding to government or regulatory requests.
If we believe disclosure is necessary to protect the rights, property, or safety of us, our clients, customers, or others.

11. Which Technologies We Use To Collect Your Data?

The following providers gather data through our Services. You might have the option to opt out of the tracking of Your usage data. While our providers may change, we’ll make an effort to keep this list updated.

12. Contact details

If there are any questions regarding this privacy policy, you may contact us using the information below.

ZIRCOO CORPORATION

One World Trade Center,
85th Floor
New York, NY, 10007
Phone Number +1 (212) 220-8573