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Privacy Policy

Last Revised on­­­­­ December 19, 2019

This Privacy Policy applies to information that we collect through our public website, at https://myzenkey.com, (the "website" or "site"), from you as an individual user ("you") of the site.

This Privacy Policy does not apply to information collected through our ZenKey Service Provider Portal, which is subject to a separate privacy policy.

This Privacy Policy does not apply to information collected through the ZenKey app. Rather, the privacy policy of your wireless carrier governs the collection, use, and sharing practices of the ZenKey app.1 This Privacy Policy also does not apply to information collected by third parties, third-party websites, or third-party applications, including any that may be linked to or accessible from or on the site.

  1. Definitions
  • Cookies : Cookies are small pieces of data that are written to a computer by a web server to facilitate access and authentication.
  • Personal Data : Personal Data means data about an individual or a device that directly identifies or can be used to identify a person. (Personal Data may include, for example, your name, address, email, phone number, mobile phone number, mobile device identifier, wireless network profile data, location, and other information that you provide to us.)
  • Suppliers : Suppliers are third-party entities and individuals that we work with to provide the site to you.
  • Usage Data : Usage Data is data collected automatically (for example, the duration of a page visit).
  1. Types of Data Collected

a. Personal Data When registering to receive more information from us on the "Contact Us" page of our website, we may ask you to provide us with certain Personal Data, which may include, for example: Email Address, Name, Address, State, Province, ZIP/Postal code, City, Country, Phone Number, Company Name, and Job Title. We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

b. Usage Data We may also collect Usage Data about how the site is accessed and used, which may include information such as your computer's Internet Protocol address, e.g. IP address, browser type, browser version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

c. Tracking and Cookies Data We use Cookies and similar tracking technologies to track the activity on our site. Cookies may include a unique identifier. Cookies are sent to your browser from a website and are stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our site. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our site.

Examples of Cookies we use: session cookies (to operate our site), preference cookies (to remember your preferences and various settings), and analytics cookies (to measure your use of our site, compile a record of this usage information, and help us improve and develop the way our site works). For more details related to your choices related to analytics cookies, please see the section[s] below labeled "Analytics".

  1. Use of Data We use the collected data for various purposes, including to:

a. provide and maintain our site;

b. notify you about changes to our site;

c. allow you to participate in interactive features of our site when you choose to do so;

d. provide customer support;

e. gather analysis so that we can improve our site;

f. monitor the usage of our site;

g. detect, prevent and address technical issues;

h. provide you with news, special offers and general information about other goods, services and events which we offer that are like those that you have already purchased or enquired about unless you have opted not to receive such information; and

i. for any other purpose with your consent.

  1. Disclosure of Data We may disclose aggregate statistical information about visitors to the site, which does not identify individual users, without restrictions. Personal Data about you, that you provide or that we collect as described in this Privacy Policy, may be disclosed to third parties as follows:

a. Suppliers. Your Personal Data may be shared with Suppliers who use the Personal Data on our behalf.

b. Business Transaction. Your Personal Data may be shared with your wireless carrier and third parties in order to complete a transaction that you requested.

c. Corporate Restructuring. If we are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy, if we are able to do so with the Personal Data we maintain about you.

d. As Required by Law. Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid orders or requests by public authorities, e.g. a court or a government agency, or to cooperate with law enforcement investigations.

e. To Enforce Rights. We may disclose your Personal Data to enforce our contractual rights, take precautions against liability, investigate suspected or actual illegal activities, or to investigate and defend ourselves against third-party claims or allegations.

f. Safety. Your Personal Data may be shared if we believe that disclosure is necessary or appropriate to protect the rights, property, or personal safety of ourselves, our customers, or others.

g. With Your Consent. We may otherwise share your Personal Data with your consent, such as to provide requested information, products or services, or otherwise to fulfill a contractual obligation to you.

It is our policy not to disclose Personal Data about you to third parties for those third parties' direct marketing purposes unless you first affirmatively agree to that disclosure.

Whenever we disclose Personal Data to a third party, we seek to minimize the disclosure to only that information that is necessary for the purpose of the disclosure.

  1. Security of Data The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. We use a variety of physical, electronic, and procedural safeguards to protect Personal Data from unauthorized access, use, or disclosure while it is under our control. While we strive to use commercially reasonable means to protect your Personal Data, we cannot guarantee its absolute security.

  2. Retention of Data We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

  1. Transfer of Data Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Data.

By using the site or submitting Personal Data via the site, you hereby consent to such transfer of your Personal Data to countries where applicable laws may not provide the same level of protection of Personal Data as the laws of the country or jurisdiction where you are located.

  1. Analytics We may use third-party Service Providers to help us monitor and analyze the use of our site.

a. Google Analytics Our site uses Google Analytics cookies or other code to help us understand how users use the site. The information collected by Google through this code will normally be stored on a Google server in the US. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data it collects to track and monitor the use of our site, and Google may also share this data with other Google services. Google may use the data it collects to contextualize and personalize the ads of its own advertising network.

You can opt-out of making your activity on the site available to Google Analytics by installing the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout). The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about your visits and activity. Our site does not respond to "do-not-track" or similar browser settings.

  1. Accessing and Requesting Changes to Your Information If you wish to access, correct, update, or delete personal information about you, please contact us as provided in this Privacy Policy. In responding to your request, we may request information from you and use information previously collected to verify your identity, or to take other actions that we believe are appropriate. Please understand that we may not be able to alter or delete your personal information if we are required under applicable law to maintain that information.

  2. Children's Privacy Our site is not intended for children under the age of 13. We do not knowingly collect Personal Data from anyone under the age of 13. If we acquire knowledge that the site has collected or received Personal Data from an identifiable person under the age of 13, we will delete that information.

If you believe that we may have collected any Personal Data from an identifiable person under 13, please contact us as provided in this Privacy Policy.

  1. Changes to this Privacy Policy We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the date the Privacy Policy was last revised. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

  2. Contact Us If you have any questions about this Privacy Policy, please contact us by using the contact information we provided on our Contact Us page.

  3. Information for California Residents Under the California Consumer Privacy Act of 2018 (CCPA), California residents are entitled to additional information about how we collect and use personal information. California residents may also have additional rights regarding their personal information. (Under California law, "personal information" includes any information that identifies, relates to, describes, or can reasonably be linked, directly or indirectly, with a particular California resident or household. But personal information does not include (i) publicly available information, (ii) deidentified or aggregate information, or (iii) information not covered by the CCPA, such as health and medical information, information collected for certain financial products or services, credit reports, certain information about motor vehicle ownership, and other information that may be regulated under other laws.)

a. As a California resident, how is my personal information used?

Under the CCPA, we are obligated to provide California residents with additional information about our information practices – the categories of personal information we have collected in the past 12 months, where that personal information comes from, why we collect it, and whether we disclose or sell that personal information.

The following chart provides this information about our information practices over the past 12 months.

Category of Personal Information Collected Source of the personal information Why the personal information was collected Disclosures of the personal information
Identifiers, such as email address, name, phone number From you, when you register on the site or communicate with us - To provide our services to you
- To communicate with you and provide you with information
- To provide customer support
- To our suppliers
- To your wireless carrier and other businesses or third parties at your request
Internet and network activity information, such as your interaction with our site Automatically collected from your computer or device and through the site - To provide, maintain, and improve our site
- To provide customer support
- To monitor and understand the use of the site and our services
- To detect, prevent, and address technical issues
- To our suppliers
Geolocation data Automatically collected from your computer or device and through the site - To provide, maintain, and improve our site
- To provide customer support
- To monitor and understand the use of the site and our services
- To detect, prevent, and address technical issues
- To our suppliers
Professional or employment information, such as your company name and job title From you, when you register on the site or communicate with us - To communicate with you and provide you with information - To our suppliers
- To your wireless carrier and other businesses or third parties at your request

We may also disclose personal information to third parties in the event of a corporate restructuring, as required by law, to enforce our rights, for safety reasons, or otherwise with your consent. See Section 4, above, for additional information.

We do not sell your personal information.

b. What are my rights as a California resident?

Under California law, California residents have specific rights regarding personal information. There are exceptions, but California residents may generally exercise the following rights:

Right to access personal information. As a California resident, you have the right to request that we inform you about the personal information we have collected, used, disclosed and sold about you in the past 12 months, and for us to provide the specific pieces of personal information that we have collected about you.

Right to request deletion of personal information. As a California resident, you have the right to request that we delete any of your personal information that we collected from you. Once we receive and confirm your request, we will delete your personal information from our records, unless an exception applies.

Right to opt-out of the sale of personal information. As a California resident, you have the right to opt-out of the sale of your personal information by a business that sells your personal information.

Right of non-discrimination. As a California resident, you have the right not to be discriminated against because you exercised your privacy rights provided under the CCPA.

c. As a California resident, how can I exercise these rights?

To submit requests to exercise your rights described above, please use one of the following methods:

We are only obligated to respond to – and we will only respond to – verifiable consumer requests. If we receive a request for information about you, we need to know that it is actually coming from you, or somebody legally authorized to act for you.

We may implement authentication procedures that are appropriate to the nature of the personal information requested. We may use any information that we have already collected about you in order to verify your request. Also, if we collect any personal information to verify your request, we will only use that information to verify your request.

Please remember that we are only obligated to respond to a request for access twice within a 12-month period.

1 https://www.verizon.com/about/privacy/full-privacy-policy