LAST UPDATED: 09/27/2019
the website operated by us at www.zira.us (the “Website”);
Software applications made available by us for use on or through computers and mobile devices (the “Apps”);
Our online marketplace for Zira Group products and services (our “Marketplace”);
Offline business interactions you have with us.
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:
Postal address (including billing and shipping addresses)
Job title and company information
IP address (we may also derive your approximate location from your IP address)
Your photos and location via our Apps, which we collect consistent with your choices
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
Through the Services.
We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, attend one of our events, contact customer service, or make a purchase.
From Other Sources.
We receive your Personal Information from other sources, for example:
publicly available databases;
joint marketing partners, when they share the information with us.
If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.
Use of Personal Information
We and our service providers use Personal Information for the following purposes:
Providing the functionality of the Services and fulfilling your requests.
To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
To complete your transactions, verify your information, and provide you with related customer service.
To send administrative information to you, such as changes to our terms, conditions, and policies.
To allow you to send messages to another person through the Services if you choose to do so.
Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
To send you marketing related emails, with information about our services, new products and other news about our company.
To facilitate social sharing functionality that you choose to use.
Analyzing Personal Information for business reporting and providing personalized services.
To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
Allowing you to participate in contests or other promotions.
We may offer you the opportunity to participate in a contest or other promotion.
Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.
Aggregating and/or anonymizing Personal Information.
We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
Accomplishing our business purposes.
For data analysis, for example, to improve the efficiency of our Services;
For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
For developing new products and services;
For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
Disclosure of Personal Information
We disclose Personal Information:
To our third party service providers, to facilitate services they provide to us.
These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
By using the Services, you may elect to disclose Personal Information.
On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
To comply with applicable law and regulations.
This may include laws outside your country of residence.
To cooperate with public and government authorities.
To respond to a request or to provide information we believe is necessary or appropriate.
These can include authorities outside your country of residence.
To cooperate with law enforcement.
For example, when we respond to law enforcement requests and orders or provide information we believe is important.
For other legal reasons.
To enforce our terms and conditions; and
To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
In connection with a sale or business transaction.
We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
Browser and device information
App usage data
Information collected through cookies, pixel tags and other technologies
Demographic information and other information provided by you that does not reveal your specific identity
Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
Your browser or device.
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
Your use of the App.
When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Pixel tags and other similar technologies.
Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by using the unsubscribe mechanism included in each such email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
If you would like to request to access, correct, update, or delete your Personal Information, you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
THIRD PARTY SERVICES
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Marketplace.
THIRD PARTY ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
THIRD PARTY PAYMENT SERVICE
400 Concar Drive
San Mateo, California USA
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.