For the purpose of data protection laws applicable from time to time to you in the location that you provide your information (“Applicable Law”), PZarla will be a ‘data controller’ (or such equivalent or replacement terminology as appropriate) for the information you provide through the Services. There may be other controllers as well (e.g., advertisers), and we encourage you to consult their privacy policies to learn more about their privacy practices.
1. INFORMATION WE COLLECT
We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as from your browser or device.
A. Information You Provide Directly to Us We may collect information from you during your use of or access to the Services, such as when you:
Register for an account; Fill in forms; Search for a product, Make a purchase or place an order; Enter a sweepstakes or contest or register for a promotion; Complete a survey or provide us with feedback; Subscribe to a service or request certain features (e.g., newsletters, updates, and other products); Use certain features that require your information to function (e.g., vendor price quotes or using our mobile apps to scan and search for products, find coupons, and promotions); Communicate with us by phone, e-mail or otherwise; Chat with any of our support agents on our chat forum; Report a problem with our website; or Post user-generated content, including comments, to or on any of our Services, including on discussion boards, community forums, blogs, or other social media functions on our website.
You do not have a statutory or contractual obligation to provide us with your information; however, if you do not provide us with your information, we may not be able to provide you with the Services you have requested or you may be limited in your use of our Services (e.g., if you do not provide us with your email address, we will not be able to send you newsletters).
B. Information that is Passively or Automatically Collected
- Device/Usage Information We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze information such as (a) IP addresses, geolocation information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content (such as advertisements) viewed and the order of those pages, statistical information about the use of the Services (such as barcodes scanned through certain of our mobile apps), the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Location Information We and our service providers may automatically collect location information, including general information (e.g., IP address, zip code) from your computer or mobile device. If you access the Services through a mobile device, we may also ask you to share your specific geo-location information with us. The Services use this location information to provide customized location-based services, content, promotional offers and other information that may be of interest to you. For example, if you use our ShopSavvy mobile application, with your permission, we collect geolocation information from your device that will allow us to present location-based alerts such as nearby retailers or coupons, or organize products searched or scans based on the closest applicable retailer. We may also use location information to improve the functionality of the Services and our other products services. We and our service providers may also collect other information based on your location and your device’s proximity to “beacons” and other similar indoor proximity systems, including, for example, the strength of the signal between the “beacon” and your device and the duration that your device is near the “beacon.” If you do not wish to have this location information collected and used by us and our service providers, you may disable the location features on your device. Please note that if you disable such features, you will not be able to access or receive some or all of the services, content, features and/or products made available via the Services. Also see the “Tailored Advertising” section below for more choices regarding the delivery of interest-based content and advertising.
Cookies and Other Electronic Technologies We and our service providers may also collect data about your use of the Services through the use of Internet server logs, cookies and/or tracking pixels. A web server log is a file where website activity is stored to distinguish you from other users of our website. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather additional information through other methods. We also gather information and identify users through the fingerprinting methods described in Section 2(a) above.
We and our service providers use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Except for essential cookies, all cookies will expire after 13 months.
Please also see below the section entitled ‘Tailored Online and Mobile Advertising’ which contains further information on how cookies are used for advertising purposes by Zarla and by associated third parties.
When you “like” or “follow” us on Facebook, Instagram, Pinterest, Twitter or other social media sites, we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us. We may also collect your information if you sign up for one of our promotions or submit information to us through social media sites.
D. Information from Affiliates and Non-Affiliate Third Parties. In addition, our Services may include cookies and tracking mechanisms from social media platforms (e.g., Facebook) through which the social media platform may collect information about you, such as mobile advertising identifier, cookie data, and IP address, as well as non-personal information (e.g. screen size), for purposes that include targeting advertisements. Please see the “Tailored Online and Mobile Advertising” section below for more information.
We may also obtain information about you if you use any other websites that we operate or may operate from time to time or other services we provide. We may share information amongst members of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also obtain information, such as demographic information, from our affiliates or from third parties, such as marketers, partners, researchers, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies and others.
2. HOW WE USE YOUR INFORMATION
We may use your information for the following purposes:
For the purposes for which you provided it; To carry out our obligations arising from any contracts entered into between you and us including the provision to you with information, products and services that you request from us, online content and dealing with your requests and enquiries; To process a transaction you initiate or to provide the features, services and products available through the Services; To send you information about your relationship or transactions with us, account alerts, or other communications, such as newsletters to which you have subscribed; With your consent, to send you SMS messages; To notify you about new features, changes and/or offerings of the Services, including, but not limited to, updates, discounts, events, shows news about our Services, products, and/or special offers; To contact you with information, surveys, or advertising that we believe may be of interest to you both regarding our products and Services and those of third parties; To administer sweepstakes and contests; To process and respond to your inquiries or to request your feedback; For internal research and reporting; To analyze and improve the content and features of the Services or develop new Services; To ensure that content from our website is presented in the most effective manner for you and on the device or browser from which you are accessing our Services; To personalize the content and advertising that you see on the Services or on other websites, including across difference devices and browsers (see “Personalized Content and Advertising” section below); To measure or understand the effectiveness of advertising we serve to you and others; To allow you to participate in interactive features of our service, when you choose to do so; To enforce the legal terms that govern your use of the Services; To keep our website safe and secure; To use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries and to determine the jurisdiction in which you are accessing the Services; and To administer and troubleshoot the Services.
Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy.
We may aggregate and/or de-identify information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.
If you ever provide to us any information that classifies as ‘sensitive personal information’ (for example racial or ethnical origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences), we will only use this information to provide the Service you require in accordance with this Policy and we will ask for your explicit consent to such processing.
3. WHEN WE DISCLOSE YOUR INFORMATION
Zarla may disclose and/or share your information between members of the Zarla corporate group, and to or with any non-affiliated third parties under the following circumstances:
Consent. We may disclose your information to any third parties based on your consent to do so. Service Providers. We may provide access to or share your information with select third parties who perform services on our behalf and for any other legitimate business purpose. These third parties provide a variety of services to us, including without limitation billing, sales, marketing, advertising, market research, customer support, fulfillment, data storage, analysis and processing, and legal services. Business Partners. We may provide your information to individuals and companies with whom we have business relationships to provide you with special coupons, discounts, or promotions, or to offer products and services to you for purchase. We encourage these partners to adopt and post privacy policies. However, the use of your Information by such parties is governed by the privacy policies of such parties and is not subject to our control. Protection of Zarla and Others. By using the Services, you acknowledge, consent and agree that we may access, preserve and disclose your information, including, but not limited to, any user content, if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce our Terms of Service, this 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; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Zarla, 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. Business Transfers. As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If a portion or all of Zarla’s assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. Public Forums. Our Services offer publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Please also remember that if you choose to provide information on public features of the Services, individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about what you choose to disclose publicly and make sure it’s information you want to share with the public.
4. LEGAL BASIS FOR PROCESSING PERSONAL DATA
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds for processing your personal data are as follows:
To Honor Our Contractual Commitments to You. Much of our processing of personal data is to meet our contractual obligations to our customers, or to take steps at customers’ request in anticipation of entering into a contract with them. Legitimate Interests. In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals: Customer service Marketing Protecting our customers, personnel and property Analyzing and improving our business Managing legal issues We may also process personal data for the same legitimate interests of our customers and business partners.
Legal Compliance. We need to use and disclose personal data in certain ways to comply with our legal obligations. Consent. Where required by law, and in some other cases, we handle personal data on the basis of consent. Where we handle your personal data on the basis of consent, you have the right to withdraw your consent.
5. PERSONALIZED CONTENT AND ADVERTISING
If you receive email from us, we may use certain tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
B. Tailored Online and Mobile Advertising We may personalize the content and advertising that you see when using the Services through the use of third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you provide such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored.
When using a mobile application you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems to opt-out of tailored in-app advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. We also may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. You can opt-out from third-party interest-based advertising on some Android devices and Google apps by visiting Google Settings, Ads and then click on ‘Disable ads based on interests.’ You can also opt out of some interest-based advertising on your mobile device by downloading the TrustArc Privacy App available at: https://www.trustarc.com/consumer-resources/privacy-app/.
Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out. n that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
C. Notice Concerning Do Not Track Signals Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform online services that they do not want certain information about their webpage visits collected over time and across websites or services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
6. YOUR RIGHTS AND CHOICES
You may review and update certain information through your relevant account settings on the Services. For additional assistance with reviewing or modifying information provided to us, contact us as described below.
If you have provided contact information through the Services and decide that you do not want Zarla to use that information for marketing purposes in accordance with this Policy, you can opt out of future use at any time by: (a) going to the link provided at the bottom of any email you receive and opting out of receiving future information; or (b) contacting us as described below. Please note that you may not be able to opt out of emails about your transactions and relationship with us, such as emails regarding your account, requests or inquiries, and purchases of products and/or services.
Individuals in the European Economic Area (“EEA”) and many other jurisdictions have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. You may also have rights to object to our handling of your personal data, restrict our processing of your personal data, and to withdraw any consent you have provided. To exercise these rights, please contact us as described below with the nature of your request. Our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will typically take the form of your e-mail address and any password submitted upon registration. While we strongly encourage you to first raise any questions or concerns about your personal data with us, you also have a right to contact the relevant supervisory authority.
Many of the rights described here are subject to significant limitations and exceptions under applicable law (e.g., objections to the processing of personal data, and withdrawals of consent, typically will not have retroactive effect).
We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using Secure Sockets Layer (SSL) technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or our service, 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, and although we will do our best to protect your information, we cannot and do not guarantee that the measures we take will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, as no Internet and/or other electronic transmissions can be completely secure and any transmission is at your own risk.
It is important for you to protect against unauthorized access to your password and to your computer so we advise that you sign off when you have finished using a shared computer and strongly recommend that you do not use the browser’s password memory function as that would permit other people using your device to access your information. It is important for you to protect against unauthorised access to your password and to your computer so we advise that you sign off when you have finished using a shared computer strongly recommend and that you do not use the browser’s password memory function as that would permit other people using your device to access your information. We recommend that you change your password periodically. You are responsible for maintaining the security of your account username and password. You may not provide these account credentials to any third party. If you believe that your account username and/or password have been stolen or been made known to others, you must contact us immediately as described below and change your password immediately. We are not responsible if someone else accesses your account through information that they have obtained from you. To the fullest extent permitted by law, we disclaim all liability and responsibility for any damages you may suffer due to any loss, unauthorised access, misuse or alterations of any information you submit to the Service.
8. DATA RETENTION
We will keep your information only for as long as is reasonably necessary for the purpose that it has been processed, taking into account any legal requirements under Applicable Law. For the avoidance of doubt, we will retain your information to continue offering the Services to you. If you terminate your account, any association between your account and information we store will no longer be accessible through your account. However, if you have engaged in any public sharing prior to termination, that information will remain on our services and accessible to the public. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Information may persist in copies made for backup and business continuity purposes for additional time.
9. INTERNATIONAL USERS
To the extent that Zarla’s affiliates in the EU make such transfers, they will rely on the EU-U.S. Privacy Shield or Standard Contractual Clauses. Individuals whose personal data is transferred pursuant to the Standard Contractual Clauses may request a copy of the Clauses by contacting us as described below.
10. THIRD PARTY LINKS AND SERVICES
The Services may also include widgets and social media features such as the Facebook “Like” button, which are interactive mini-programs that provide specific services from another company (e.g., displaying the news, opinions, music, etc.). Information such as your email address may be collected through these features. These features may collect your IP address and set cookies to enable them to function properly. We are not responsible for nor do we endorse the privacy practices or the content of such third-party services. Any information you provide via those services is subject to their applicable privacy policies and is not covered by this Policy.
11. YOUR CALIFORNIA PRIVACY RIGHTS
California Law permits visitors who are California residents to request a list of the third parties to which we have disclosed “personal information” (as that term is defined under applicable California law) for such third parties’ direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing at: Privacy, Zarla, 2093 Philadelphia Pike #2555 Claymont DE 19703 United States.
12. INFORMATION FROM CHILDREN
The Services are not directed to children under the age of 13 and such children are not permitted to use the Services. If we discover we have received any “personal information” (as defined under the Children’s Online Privacy Protection Act) from a child under the age of 13 in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under the age of 13, please contact us as described below.
13. CHANGES TO THIS POLICY
We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Policy will mean you accept those changes.
14. QUESTIONS ABOUT THIS POLICY
If you have any questions about our Policy, to exercise any of your rights, or for any other privacy-related inquiries, you can contact us at firstname.lastname@example.org