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ZayZoon Privacy Policy – Effective January 1, 2020

Thanks for choosing ZayZoon!

At ZayZoon, we want to give you the best possible experience to ensure that you enjoy our service. To do this we need certain information that may be personally identifiable to you so we can deliver an exceptional and personalized service specifically for you. Your privacy and the security of your personal data is, and will always be, enormously important to us. We want to transparently explain how and why we gather, store, share and use your personal data – as well as outline the controls and choices you have around when and how you choose to share your personal data.

This Privacy Policy (“Policy”) will explain exactly what we mean in further detail below.  This Policy describes the information ZayZoon, the company that offers services under the ZayZoon brand, collects about you, how we use and share that information, and the privacy choices we offer. This policy applies to information we collect when you register for ZayZoon, access or use our website, mobile applications, products, and services (collectively, the “Service”), or when you otherwise interact with us. As used in this Privacy Policy, the term “Site” includes: all websites and all devices or applications operated by ZayZoon that collect personal information from you and that link to this Privacy Policy; pages within each such website, device, or application, any equivalent, mirror, replacement, substitute, or backup website, device, or application; and pages that are associated with each such website, device, or application.

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

Our commitment to protecting your information is described in the sections outlined below:

  1. Collection of information
  2. What we use your personal data for
  3. Sharing of information
  4. Keeping your personal data safe
  5. Data retention and deletion
  6. Transfer to other countries
  7. Email communications
  8. Changes to your personal information
  9. Changes to this Policy
  10. Additional California privacy disclosures
  11. How to Contact Us

 

  1. Collection of Information

ZayZoon may collect the following categories of personal information about you, including but not limited to the following:

i. User Data.  This is the personal data that is provided by you or collected by us to enable you to sign up for and use the ZayZoon Service. Depending on the type of Service you sign up for, this may include your username, email address, phone number, birth date, gender, street address, and country.

Some of the personal data we will ask you to provide is required in order to create your account, such as an email address and password.  In order to verify who you are, you may also be asked to provide identification information to confirm your identity, including your first and last name, zip code and phone number and the last four digits of your Social Security Number.

If you use a third-party service to create an account, we will receive personal data via that third party service but only when you have consented to that third party service sharing your personal data with us.

In order to provide you with access to On-Demand Wages, we may also need your employment and wage history, and time and attendance data from your employer or payroll provider.  We also need a place to send you your On-Demand Wages, and so we will need to collect information on your bank account, debit card, payroll card, etc.

ii. Usage Data. This is the personal data that is collected about you when you’re accessing and/or using the Service, including:

  • Information about what Service plans you use
  • Information about your interactions with the Service such as your requests, repayments, customer service queries (including the date and time of any requests you make) and your interactions with the Service, content and other ZayZoon users. This also may include details of your use of third party applications in connection with the Service.

 iii. Third Party Data. This is information that we may receive about you either directly from you or from third party sites and Internet services (collectively, “Third-Party Sites”).  This may include certain passwords, usernames, account numbers, and other account information that you provide to us.

In order to display information to you or to fulfill your requests for certain products and services through a Service, we may collect, on your behalf, your account and other personal information from Third-Party Sites that you register under your account via the Service. We may also collect information about you from mailing list providers, publicly available sources, and other third parties.

For certain Services, ZayZoon uses Plaid Technologies, Inc. (“Plaid”) to gather your data from financial institutions.  You will be notified which Services use Plaid prior to any information being gathered.  By using our service, you grant ZayZoon and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid privacy policy

iv. Technical Data. This means information about your use of the Service and particular technical identifiers.  We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files that are stored on your hard drive or in device memory by a website. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We may also collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, count visits, understand usage, and determine whether an email has been opened and acted upon. It may be possible to disable some cookies through your device or browser setting. Please note, however, that certain features of our Site may not be available if cookies are disabled.

We may collect your computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our web design and functionality.

v. Device ID. When you use the mobile versions of our Site, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (the “Device ID”). Device IDs allow app developers, and others to uniquely identify your device for purposes of storing application preferences and other data.

vi. Contests, Surveys and Sweepstakes Data. When you complete any forms, respond to a survey or questionnaire, or participate in a contest, we collect the personal data you provide.

  1. What we use your personal data for

When you use or interact with the Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (as set out in Section 1 above).

Description of why ZayZoon processes your personal data (“Processing Purpose”) Legal Basis for the Processing Purpose Categories of Personal Data used by ZayZoon for the Processing Purpose
To provide and personalize the Service. – Performance of a Contract

– Legitimate Interest

– Consent

– User Data

– Usage Data

– Third-Party Data

– Technical Data

– Device ID

To understand, diagnose, troubleshoot, and fix issues with the Service. – Performance of a Contract

– Legitimate Interest

 

– User Data

– Usage Data

– Third-Party Data

– Technical Data

– Device ID

To evaluate and develop new features, technologies, and improvements to the Service. – Performance of a Contract

– Legitimate Interest

 

– User Data

– Usage Data

– Third-Party Data

– Technical Data

– Device ID

For marketing and promotion purposes. – Consent

– Legitimate Interest

 

– User Data

– Usage Data

– Contest, Surveys and Sweepstakes Data

To comply with legal obligations and law enforcement requests. – Compliance with legal obligations

– Legitimate Interest

 

– User Data

– Usage Data

– Third-Party Data

– Technical Data

– Device ID

– Contest, Surveys and Sweepstakes Data

To establish, exercise, or defend legal claims. – Legitimate Interest

 

– User Data

– Usage Data

– Third-Party Data

– Technical Data

– Device ID

– Contest, Surveys and Sweepstakes Data

To conduct business planning, reporting, and forecasting. – Legitimate Interest

 

– User Data

– Usage Data

– Third-Party Data

– Technical Data

– Device ID

– Contest, Surveys and Sweepstakes Data

To detect fraud, including fraudulent payments and fraudulent use of the Service. – Performance of a Contract

– Legitimate Interest

– Compliance with legal obligations

– User Data

– Usage Data

– Third-Party Data

– Technical Data

– Device ID

To conduct research, contests, surveys, and sweepstakes. – Performance of a Contract

– Legitimate Interest

– Consent

– User Data

– Usage Data

– Technical Data

– Device ID

– Contest, Surveys and Sweepstakes Data

You authorize the sharing, exchange and use of transaction data described above and herein by and among ZayZoon and ZayZoon’s third-party service providers.

  1. Sharing of information

We may share personal information about you as follows:

Categories of Recipients Reason for Sharing
Payroll Providers and Employers We partner with payroll providers and employers to get information required to provide you with the Service.

 

We may share your username or other User Data as necessary to enable your account. We may also share personal data with that third party about your use of the Service, such as whether and to what extent you have used the offer, activated an account, or actively used the Service. We also may share your personal data in a pseudonymised format with our industry partners to help them understand how the Service is performing and to use the Service.

Service providers We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we’ve hired to customer service support communication, operate the technical infrastructure that we need to provide the Service, assist in protecting and securing our systems and services, and help market ZayZoon’s own products and services as well as partner products, services, events, and co-branded promotions in which ZayZoon is involved.
Payment processors We will share your personal data with our payment processors as necessary to enable them to process your requests for advances, repayments, and for anti-fraud purposes.
Academic researchers We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format.
Other ZayZoon group companies We will share your personal data with other ZayZoon group companies to carry out our daily business operations and to enable us to maintain and provide the Service to you.  As of the date of this Privacy Policy, the only other ZayZoon group company is ZayZoon Inc., a Canadian corporation based in Alberta, Canada.
Law enforcement and data protection authorities We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
Purchasers of our business We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, ZayZoon will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy.
  1. Keeping Your Personal Data Safe

We take reasonable measures, including firewall barriers, SSL encryption techniques, and authentication procedures, to help protect personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. No system, however, is perfectly secure and, therefore, we recommend that, when you register for our Site and use our services, you take reasonable steps to secure your personal information, including using use a unique password that you do not use on other Sites.

  1. Data retention and deletion

We keep your personal data only as long as necessary to provide you with the Service and for legitimate and essential business purposes, such as maintaining the performance of the Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Service. For example, we keep your advance and repayment history and account information.

If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:

  • If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
  • Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or
  • Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

California residents should also refer to Section 10 of this Privacy Policy to view additional rights regarding these matters.

  1. Transfer to other countries

ZayZoon shares your personal data globally with ZayZoon group companies in order to carry out the activities specified in this Policy. ZayZoon may also subcontract processing to, or share your personal data with, third parties located in countries other than your country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country.

Personal data collected within the United States may, for example, be transferred to and processed by third parties located in a country such as Canada. In such instances ZayZoon shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place.

  1. Email communications

We may provide our registered customers with summaries of their Account Information and email alerts. We may also allow users to subscribe to email newsletters and from time to time may transmit emails promoting ZayZoon or third-party goods or services.

Subscribers have the ability to opt-out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts.

  1. Changes to your personal information

If you wish to access personal information that you have submitted to us or to request the correction of any inaccurate information you have submitted to us, you may correct certain information via your user account. Alternatively, you can send an email that includes your contact information to support@zayzoon.com to request any corrections to your personal information.

You may also email us if you wish to deactivate your account, but even after you deactivate your account, we may retain archived copies of information about you for a period of time that is consistent with applicable law.

  1. Changes to this Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we’ll may provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Service or by sending you an email and/or a device notification. We may notify you in advance.  Please, therefore, make sure you read any such notice carefully.

You may review updates to our Terms of Service and Privacy Policy at any time via links at the bottom of www.zayzoon.com. You agree to accept electronic communications and/or postings of revised versions of this Privacy Policy on www.zayzoon.com or through the ZayZoon Service and agree that such electronic communications or postings constitute notice to you of the revised version of this Privacy Policy. Changes take effect immediately upon posting.

  1. Additional California Privacy Disclosures

If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws. Beginning January 1, 2020, the CCPA gives you certain rights with respect to the processing of your personal data (known as “personal information”, as described in under the CCPA).

This section provides additional privacy disclosures and informs you of your additional rights as a California resident, and should be read in conjunction with our Privacy Policy.  This section does not apply to you if you are not a resident of California.

Personal Information Collected and Processed

Section 1 of our Privacy Policy sets forth the categories of personal information that ZayZoon collects and processes about you, a description of each category, and the sources from which we obtain each category.

Requests to Exercise Your Rights

RIGHT TO KNOW REQUEST – Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

  1. Categories of and specific pieces of personal information we have collected about you.
  2. Categories of sources from which we collect personal information.
  • Purposes for collecting, using, or selling personal information.
  1. Categories of third parties with which we share personal information.
  2. Categories of personal information disclosed about you for a business purpose.
  3. If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

To make a verifiable request for information about the personal information we have collected about you, please make a request by emailing us at support@zayzoon.com and telling us “I want to download a copy of my data”.

RIGHT TO DELETE REQUEST – You also have a right to request that we delete personal information, subject to certain exceptions. You may exercise your right to delete by emailing us at support@zayzoon.com and telling us “I want to permanently delete my data”.

HOUSEHOLD REQUESTS – We currently do not collect household data. If all the members of a household makes a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

REQUESTS, GENERALLY – Please note, if you do not have a ZayZoon account we will not have enough information about you to verify your Right to Know and Right to Delete requests, as we do not keep sufficient information necessary to reidentify and link you to a prior visit to the Service where data may have been collected. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.

REQUESTS MADE THROUGH AGENTS – You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, ZayZoon has disclosed certain data from the following categories of personal information to the categories of recipients listed in Section 2 of our Privacy Policy for one or more business purposes:

  1. User Data
  2. Usage Data
  3. Third-Party Dat
  4. Technical Data
  5. Device ID
  6. Contest, Surveys and Sweepstakes Data

We never sell your information in the conventional use of the word “sell”.  Our use of your personal information is solely to provide you the Service in accordance with the Terms of Service and this Privacy Policy.

However, under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. It does not necessarily mean money was exchanged for the transfer of personal information. We have taken substantial steps to identify whether any of our data sharing arrangements would constitute a “sale” under the CCPA. Due to the complexities and ambiguities in the CCPA, we will continue to evaluate some of our third-party relationships as we wait for final implementing regulations and guidance. For example, it is currently unclear whether the use of certain types of payment processing partners would be considered a sale under CCPA. We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction.

11.  How to Contact Us

If you have questions or concerns regarding this statement, or if you have any questions or suggestions, please contact support@zayzoon.com, or by writing to us at the following address:

ZayZoon US Inc.

109 E. 17th St. Suite #5427

Cheyenne, WY 82001