ZONETAP PRIVACY POLICY

Effective Date: Nov 28th, 2018

Zonetap, Inc. (“Zonetap” or “we”) is committed to safeguarding your privacy online. Please read this Privacy Policy to understand the information that we collect and how we process the information we collect from use of zonetap.com (“Website”) and [our location based marketing business-to-business web applications and any other website, application or other online service in which this Privacy Policy is referenced and linked (collectively, the “Services”).

Your privacy matters to Zonetap – whether you are new to Zonetap or a long-time user. Please do take the time to read this Privacy Policy – and if you have any questions contact us at info@Zonetap.com

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.

WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to you when you use our Services [or communicate with us offline, such as by telephone for customer support]. This Privacy Policy describes the information that Zonetap collects (directly or indirectly) when you use the Services and why we collect it, what we do with the information we collect and how you can manage your information through the Services.

If a particular Service has its own privacy policy or links to a different privacy policy, then that privacy policy — not this Privacy Policy — applies. This Privacy Policy also does not apply to any website or service that does not display or link to this Privacy Policy.

Our agreements with our customers (your employer) (a “customer agreement”) may contain provisions about the collection, use, storage and disposal of information collected through the Services and offline. If a provision of a customer agreement conflicts or otherwise is inconsistent with a provision of this Privacy Policy, then the provision of the customer agreement will prevail but solely to the extent of the conflict or inconsistency. Please contact your employer if you have questions about a customer agreement.

In this Privacy Policy, to “process” Personal Data means to perform any operation on Personal Data, whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying.

If you have not done so already, please also review our [End User License Agreement][Terms of Service].

INFORMATION WE COLLECT

Personal Data is any information directly or indirectly relating to you as an individual, such as your name, email address and mobile device identifiers.

Usage Information is information that, by itself does not individually identify you, such as browser type, operating system, the webpages you viewed and how long you viewed them.

We may link together different types of Usage Information or link Usage Information to Personal Data. If linked information directly or indirectly identifies you as an individual person, then Zonetap treats the linked information as Personal Data.

HOW WE COLLECT INFORMATION

How we collect information depends on how the Services are used.

User Provided Information. We collect information provided directly to us through the Services, such as when you create or modify your account on the Website, request customer support or otherwise communicate with us [add?]. This information includes (a) your name and email address; [(b) user name, password and other registration information; (c) transaction-related information, such as when you [place an order/subscribe?]; (d) information you provide us when you contact us for help; and (e) other information you choose to provide and enter into the Services.
Automatically Collected Information.
The Website automatically collects information about how it is used, such as mobile device or computer type, IP address, system and application software and the pages and screens view and how long they are viewed [and traffic data, logs and other communication data, [metadata and other information associated with other files stored on your device]. When the Services are deployed by one of our business customers, the information collected is hardware model and operating system, mobile device ID and Location Information (described below) Some of this automatically collected information is Personal Data. Some of this information is collected through Data Collection technology as described below
Location Information. Zonetap collects information from Wi-Fi access points, GPS, wireless networks and/or cell towers that indicate the current or prior location of the mobile device on which the Services are accessed (“Location Information”). The Services can collect Location Information from mobile devices after [the device operator/owner consents to tracking through the permission system used by the mobile operating system]. [Confirm:
Some of the Services may use Google Maps to determine your location. When Google Maps is part of the Services
you choose to use, you are subject to Google’s Privacy Policy at http://www.google.com/policies/privacy.
Other mapping services also have privacy policies and user terms to which you agree when you download or use them.]
Information Collected from Third Party Sources. Zonetap also may receive information from other sources and combine that with information we collect through our Services.

COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

The Services may use cookies, pixel tabs (also known as web beacons, flash cookies and clear GIFs) and similar technology (“Data Collection Technology”).

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of
the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.

When we use Data Collection Technology, it helps compile statistics about use of the Services and help us analyze technical and navigational information about the Services and to detect and prevent fraud. [add?]

[Confirm: We also use Google Analytics, which is a Google service that collects aggregate information about use of the Services and reports website trends. Google Analytics does not directly identify individual users. You can learn about Google’s practices and opt out by visiting https://policies.google.com/technologies/partner-sites.]

Your Control of Cookies:

Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

Our Policy On Do Not Track Signals:

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not
Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain Personal Data about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Zonetap, do not respond to DNT signals.

HOW WE USE INFORMATION

We use information to operate the Services, including:

To administer your account and provide the Services to you

Create and manage your account Provide you with customer support and respond to your requests Communicate with you about the Services

To inform you about our resources

Communicate with you about products or services that we think may interest you Inform you about our social media posts and other resources
[Confirm: To develop, display and track content tailored to your

interests on the Services]

To improve the Services and develop new ones

Conduct research and analysis of users’ behavior to improve the Services Develop new features and services

To prevent, detect and fight fraud or other illegal or unauthorized activities
Address ongoing or alleged fraud on or though the Services and our related products and services Analyze data to better understand and design countermeasures against fraud Retain information related to fraudulent activities to prevent recurrence
To ensure legal compliance

Comply with legal requirements Assist law enforcement Enforce or exercise our rights
HOW WE SHARE INFORMATION

We share information as described in this Privacy Policy or as otherwise disclosed to you at the time information is collected from you.

With our service providers and partners
We use third-party operational providers to help us operate and improve the Services. These third parties assist us with [Confirm: data hosting and maintenance, analytics, customer care, marketing, payment processing, debt collection and security operations]. All of our service providers must adhere to confidentiality and data protection obligations that are consistent with this Privacy Policy.

For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law
Applicable law may require us and our service providers to disclose your information if: (i) reasonably necessary to comply with a legal process, such as a court order, subpoena or search warrant, government or regulatory investigation or request or similar requirements; or (ii) necessary for the prevention or detection of crime (subject to applicable law).

To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request
We may ask for your consent to share your information with third parties. When we do, we will make clear why we want to share the information.

We may collect and aggregate information about our users and share it with [Confirm: advertisers, promotional partners and affiliates] but this aggregated information does not include information that directly identifies any individual person.

HOW WE PROTECT AND RETAIN INFORMATION

We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your information to those employees who need to know that information to perform their job functions.

Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. Any transmission of your information is at your own risk. Please use appropriate security measures to protect your Personal Data.

You are responsible for maintaining the security of your account and the information in your account. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address on record on your account.

If you believe that your account or information is no longer secure, please notify us immediately at info@Zonetap.com.

We retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy or our contract with you unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include: The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Services); Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); Whether retention is advisable considering our legal position (such as for statutes of limitations, litigation or regulatory investigations).

YOUR CHOICES ABOUT YOUR PERSONAL DATA

If you would like to review, correct, delete or restrict our use of Personal Data about you that you previously provided to us or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (in each case, when these rights are provided to you by law), please contact us using the contact information below. In your request, please make clear the Personal Data to which your request relates and the actions you would like us to take. For your protection, we will verify your identity before fulfilling your request. Please note that we may not allow you to review or delete certain data for legal, security or other reasons. We will comply with your request as soon as reasonably practicable and in compliance with law.

IF YOU ARE LOCATED IN THE EUROPEAN UNION

You have the right to lodge a complaint with a data protection authority about how we process your Personal Data.

Zonetap is the “data controller” of your Personal Data.

Our legal bases for processing your Personal Data depends on the information concerned and the specific context in which we collect it. We collect Personal Data from you only when we have your consent, if we need the Personal Data to perform our contract with you or when the processing is in our legitimate interests and not overridden by your fundamental rights and freedoms, such as to provide our Services to you or respond to your inquiries and improve our Services. In some cases, we may also have a legal obligation to collect Personal Data from you.

CROSS BORDER DATA TRANSFERS

[Confirm: Sharing of information sometimes involves cross-border data transfers to or from the United States of America and other jurisdictions. For example, when the Services are used by individuals from the Economic Area (“EEA”), Personal Data [is/maybe] transferred to the United States. We use standard contractual clauses and other mechanisms approved by the European Commission to validate transfers of EEA residents’ Personal Data from the EEA to other countries. Standard contractual clauses are commitments between companies transferring Personal Data of EEA residents to protect the privacy and security of the transferred Personal Data.]

CHILDREN’S PRIVACY

Zonetap does not knowingly collect Personal Data from minors. If we learn that a minor has provided us with information, we delete the minor’s Personal Data from our records.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you can request a notice disclosing the categories of Personal Data about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. [Confirm: As of the Effective Date above, Zonetap does not disclose Personal Data about you with third parties for their direct marketing purposes.]

.LINKS TO OTHER WEBSITES AND SERVICES

The Services may include links to third-party websites and services that are not operated by us, such as websites of banks that issue prepaid cards. When you use third-party services, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any information that you provide to websites and services that are not operated by Zonetap.

CHANGES TO THIS PRIVACY POLICY

The “Effective Date” of this Privacy Policy is set forth at the top of this page. Zonetap may change this Privacy Policy from time to time to address new legal and business needs. We will take appropriate measures to inform you, consistent with the significance of the change. We will obtain your consent to material changes as and when required by applicable law.

QUESTIONS?

If you have any questions about this privacy statement, the practices of this site, or your dealings with this website, please contact us at info@zonetap.com.