ZVAMY.ORG leverages technology responsibly to power prosperity around the world, and we believe that everyone has a right to privacy. At ZVAMY.ORG, we view privacy as a key part of the value that we deliver to our customers. ZVAMY.ORG’s Data Stewardship Principles were developed to describe ZVAMY.ORG’s values regarding the data our customers entrust to us.

Scope of this Privacy Statement and our role

As a financial services and technology company, we’re providing this Global Privacy Statement (which we’ll refer to as “Privacy Statement”) to explain how we, ZVAMY.ORG (collectively “ZVAMY.ORG”, “we” and “us”) collect, use, share or otherwise process information when you interact with us and our offerings, services and experiences, or when businesses provide us with your information. This Privacy Statement is global in nature, meaning that it is applicable to all ZVAMY.ORG websites and offerings, and it describes our privacy practices when we process:

b) Personal information for the purposes of providing the benefits of the ZVAMY.ORG platform, which is collectively, all of ZVAMY.ORG’s services, sites, experiences and software (including through our mobile applications and desktop applications); and/or

c) Personal information as necessary to manage, run, improve and develop our business and personalize your experience while interacting with the ZVAMY.ORG Platform.

ZVAMY.ORG determines the purposes and means of the processing of personal information, as described in this Privacy Statement, and therefore acts as ‘data controller’ (or equivalent/similar terms) for purposes recognized by certain data privacy laws. If you have any questions about the processing of your personal information, please contact us.

This Privacy Statement does not apply where ZVAMY.ORG processes personal information as a service provider (or equivalent role under data privacy laws, such as data processor) on behalf of a customer or entity who acts as the data controller. When we act as a service provider, the privacy statement of the relevant data controller and our agreements with such business or entity will govern our processing of such personal information.

In certain circumstances, there may be more than one data controller processing your information. For example, your employer or a financial partner may also act as a data controller. In these situations, we act as an independent data controller over our processing activities – meaning that we make determinations over how your personal information will be processed independently from the other data controllers. The other data controllers have their own obligations under applicable information privacy laws. ZVAMY.ORG is not responsible for the processing of other data controllers (including our customers) and you should contact them directly for questions on how they process your personal information and for exercising your privacy rights in relation to such processing.

The ZVAMY.ORG Platform

The ZVAMY.ORG Platform and your information

When we say “platform” we mean that when you choose to share data with us, or bring over information from third parties (like a bank or loan provider), we use that data together, not just within the individual offering(s) you’re using.

The personal information we use in this centralized way is all the information that ZVAMY.ORG knows about you, either because you are an end user of our services or a customer contact (like a subscriber to a customer’s email list) whose personal information has been included in the ZVAMY.ORG Platform. It includes information such as your credentials; your name and contact details; payment information; information about your activities, behavior, your interests and preferences (including purchase history with ZVAMY.ORG or if you’re a customer contact, our customers); insights about your finances, business or preferences or your contacts; the content you or others place about you in our Platform; and information we have collected about you from third-party sources.

Information we collect

Information we receive from you

The personal information that we receive about you depends on the context of your interactions with ZVAMY.ORG, how you configure your account and the choices that you make, including your privacy settings. Personal information that we receive from you may also depend upon what services, functionalities or experiences you use, your location and applicable law.

• Creating an account. We collect information when you (or your organization) create an account, interact with the ZVAMY.ORG Platform or activate a subscription. Personal information may include your name, address, phone number and email, country, profile photo, billing information (your payment information), usernames and credentials.
• When a business provides it. We collect information when a business you interact with provides us with information about you (for example, when you are a customer contact), including information such as your name, email address and telephone number.
• Identification information. We collect information to verify your identity, including your name, social security number, social insurance number, driver’s license numbers, government-issued identification details.
• Customer support, product research, training and feedback. We may collect personal information such as your name, email address, telephone number and any other personal information you choose to share when you reach out to us for support, give us feedback, participate in optional surveys, subscribe to marketing, attend our events, participate in product research or training or otherwise interact or communicate with us.
• Social and community content. We receive content you post on our social media pages and our community pages.
• Online behavioral data. We may automatically collect certain information about your use and interactions with our websites, customers’ websites or e-commerce stores, Platform, social media websites, and marketing campaigns that we or our customers organize, including device information (such as your IP address and unique device IDs), page view information and search results, links and if you are a customer contact, whether or not a campaign presented or sent to you using our offerings has been viewed, delivered, opened, clicked on, whether it has bounced or was treated as spam.
• Device information. We may collect information about your device such as Internet Protocol (“IP”) addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.
• Usage information. We may collect information about your usage of the Platform, such as the pages you viewed, the services and features you used or interacted with, your browser type and details about any links or communications with which you interacted.
• Location information. Certain features in the ZVAMY.ORG Platform may collect your precise location information, device motion information, or both, if you grant permission to do so in your device settings. For example, if you use our time-tracking service.
• Expert advice. The ZVAMY.ORG Platform provides many opportunities for you to connect with live experts. When you interact with these experts, we may receive information about the questions you ask, the details of your accounts and the guidance provided to you.
• Camera and contacts. Certain features may have access to your camera and contacts if you grant permission in your device settings.
• Information from cookies and other technologies. ZVAMY.ORG and our service providers may use commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively “cookies”) to collect information about you (“Cookie Information”) so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers’ experience. You have control over some of the information we collect from Cookies and how we use it.
• Information stored locally. Some of our web-enabled desktop services and offerings synchronize with the information on your computer. In doing so, we may collect information such as device information, product usage, and error reports. We may also store personal information locally on your device.

Biometric Information

Certain parts of the ZVAMY.ORG Platform make use of biometric personal information (“Biometric Information“). Biometric Information can be subject to additional laws and regulations.

We collect Biometric Information from you when you enroll in our biometric identity program available through certain of our services and automatically as part of our anti-fraud protection, authentication and customer support activities. These identifiers may include facial recognition information, voiceprints and key-stroke information, as well as mathematical representations of your biometric identifier, such as the template maintained for comparison. We use Biometric Information to identify and authenticate you, and for security and similar purposes. We share Biometric Information with third-party service providers who assist with our information technology, security and fraud programs, our professional advisors, and as required by law or regulation. ZVAMY.ORG does not sell your Biometric Information.

When we collect Biometric Information, you will receive a specific notice and consent request at the time of that collection. You are not required to consent to the collection of Biometric Information in order to use our services, although some functionality may not be available if you decline and you may withdraw your consent at any time.

ZVAMY.ORG will retain Biometric Information until the purposes for which it was collected have been satisfied or three years from your or your organizational account manager’s last interaction with ZVAMY.ORG, whichever comes first.

Information provided by others

Our Platform is designed to help you connect with other people and organizations. As a result of those connections, others may be able to input information about you, including business customers using the ZVAMY.ORG Platform. For example, one of ZVAMY.ORG’s customers may share information about you with us in order to use and benefit from the ZVAMY.ORG Platform, such as information relevant to your or other customer contacts’ interactions with a business that is using ZVAMY.ORG. You may also be able to input or process information about others, for example, if you are an account administrator of one of our products or use ZVAMY.ORG to manage customer lists. If you input information about others into our platform, you must only do so if you have first provided sufficient notice and received the appropriate rights and permissions to do so, including having an appropriate legal basis for doing so, such as getting advanced written consent, if required by applicable law.

We may also get information about you from others where permitted by applicable law. We protect and process information obtained from those parties as described in this Privacy Statement, consistent with any additional restrictions imposed by the source of the information. Our sources may vary over time and depend upon how you use the ZVAMY.ORG Platform. For example, we receive information from:

• Your service providers. If you choose to sync a non-ZVAMY.ORG account/service with your account, we will receive information from that account/service according to your settings with that account/service. For example, if you connect a point of sale application to your account, we may receive details of your business’s sales records.
• Supplemental information and identity verification providers. Service providers who help us verify your identity, the specifics of your business and/or supplement the information you have provided and ensure the accuracy of your information. For example, we use third-party service providers to validate your mailing address, phone number or provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider or email provider.
• Customer Support providers. Service providers who provide us with information about you or your interaction with the ZVAMY.ORG Platform for troubleshooting purposes. For example, we may obtain support information or technical issues you have raised with these third parties.
• Other users.We may also collect such information through features like member referral programs.
• Risk management, cybersecurity & anti-fraud providers. We may receive information from service providers who help us assess risks associated with our offerings, including to help combat fraud, illegal activity and to help protect your personal information.
• Content providers. We may receive information from software providers that make user-generated content from their service available to others, such as local business reviews or public social media posts.
• Communication providers & social networks. We or our third party service providers may collect information from email providers, communication providers and social networks, including to monitor public discussion about our brands. Where we are legally required, we ask for your permission to collect this information.
• Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events.
• Publicly-available and third-party sources. We collect information from publicly available and other third-party sources, such as open government databases.
• Government agencies. We receive information from government agencies.
• Required information. Some services and experiences in the ZVAMY.ORG Platform require you to provide information for it to function. If you do not wish to provide the required information, you may not be able to use certain features.

How we use personal information

We collect and process personal information about you where:

• We have your consent to do so;
• We have a contract with you and it is necessary to process your personal information to perform our contract with you, including to provide you with the benefits of the ZVAMY.ORG Platform and operate our business;
• The processing is in our legitimate business interests (in those jurisdictions where legitimate business interest is a legitimate basis for processing) such as operating our businesses, improving and developing the ZVAMY.ORG Platform, communicating with you, marketing our offerings and services and personalizing your experience, and to detect illegal activities; or
• We need to comply with legal requirements, including applicable laws and regulations.

Personal information is used for the following purposes including to:

• Provide you with the ZVAMY.ORG Platform, create your account and manage our relationship with you
• Improve and develop our products and services by analyzing how they are used and interacted with, as well as by assessing the use of and interactions with our Platform and certain content our customers send or display through the Platform, including by conducting data analytics to develop insights about you, your needs and preferences so we can make more informed predictions, recommendations and products for our customers
• Run and manage our business, including resolving billing and financial disputes
• Evaluate your eligibility for financial or other marketing offers, products and services
• Provide features to you, such as your free credit reports and scores
• Connect you with experts and other users
• Communicate with you, such as sending you electronic notifications concerning your financial privacy
• Protect against misuse or abuse of our services and ensure compliance with our terms, including in relation to content our customers send or display through the Platform
• Market our services, products and experiences, including to deliver gifts and promotional materials, product recommendations and other non-transactional communications via email, post, telephone, SMS or push notifications, in accordance with your marketing preferences
• Personalize your experience and tailor recommendations, advertising and offers presented to you, including through the development of insights about you and your needs based on your interactions with the products, services and offerings of our platform
• Combine and anonymize information about your interactions with ZVAMY.ORG to create aggregate, anonymized statistics for use in research and for marketing, promoting, improving and developing our platform
• Provide you with support and resolve disputes
• Conduct research, including by partnering with academic institutions
• Comply with our legal and regulatory requirements
• Authenticate your identity, including through the use of Biometric Data
• Manage event registrations and attendance, including sending related communications to you
• Register visitors to our offices for security reasons and manage non-disclosure agreements that visitors may be required to sign
• Protect the rights, property, safety or security of the ZVAMY.ORG Platform, our customers, employees or others and prevent fraudulent or illegal activity
• Exercise our rights in the course of judicial, administrative or arbitration proceedings
• Enforce, remedy or apply our Terms of Service or other agreements and/or
• Process your information for other purposes that are compatible with the disclosed purposes if and where this is permitted by applicable law.

Automated Processing

To provide you with valuable personalized advice, recommendations and experiences, we may process your personal information using automated and manual (human) methods. Our automated methods include artificial intelligence (AI) and a range of technologies that help our services learn and reason to improve our ability to personalize and enhance your experience in the ZVAMY.ORG Platform.

How we share your information

We may share your information in the following circumstances:

With your consent. In accordance with our Data Stewardship Principles, except for as outlined below, we only share your information with third parties when you have directed us to do so.

When you connect with an ZVAMY.ORG Platform partner. You may be provided with offers, products, and services from third-party companies who integrate with our ZVAMY.ORG Platform (“Platform Partner”). If you choose to interact with a Platform Partner, apply for their services or offerings or otherwise link or sync your account to a Platform Partner’s product or service, you consent and direct ZVAMY.ORG to share your information, including personal information, to the Platform Partner providing the service or offering. For example, when we send your personal information to partners in order to generate offers for you to review, when we send your application information directly to our partners, or when we send you to the partner’s site for you to provide the information directly to them.

In some cases, if you click through to go to a Platform Partner’s site, you will automatically be sending your personal information to that Platform Partner. When this happens, you will still have to submit your application on the Platform Partner’s site. Remember that any information you provide to a Platform Partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.

For certain product features. We may use third party API services, such as YouTube and Twilio, for certain product features. If you choose to use those features, you acknowledge and agree that you are also bound by the third party’s privacy policy, such as Google’s Privacy Policy for YouTube API services. You may manage your YouTube API data by visiting Google’s security settings page at https://security.google.com/settings/security/permissions. For more information about Twilio’s privacy practices, please visit https://www.twilio.com/legal/privacy.

When you connect to your social media account. Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider’s privacy policies (not this Privacy Statement). You should take care only to share information on social media that you are comfortable sharing.

For research. With appropriate controls, we may share information with third-parties, such as academic institutions, government and non-profit organizations, for research purposes or to publish academic or policy-related materials. We only share information in a way that would not allow any individual to be identified.

For joint features, sales, promotions and events. We may share your information with third-parties companies who are jointly providing features, sales initiatives, promotions or events with us.

With financial services providers. In connection with our financial products, we may share personal information with collection agencies, credit bureaus and loan services providers, and payment card association members. We may also share your personal information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, defaults, or debt collection.

When you publicly post the information. We may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include personal information, such as your name or user name. Anything you share in a public forum is public, and you should think carefully before you decide to share.

With service providers or agents. We share personal information with our service providers or agents who provide services on our behalf for the purposes described in this Privacy Statement. Service providers or agents are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Statement. Service providers or agents may include companies that assist us with our advertising, marketing and sales efforts, help us with our technology offerings (such as a hosting, security or anti-fraud providers) and help us run our business.

No sale of personal information to third parties. We do not and will not sell personal information to third parties. We do share personal information with third parties for the business purposes described in this Statement.

With our affiliates and subsidiaries and your right to limit information sharing. We may share your information with our affiliates and subsidiaries for everyday business purposes as described in this Statement, including for marketing purposes, for improving and developing our offerings and for personalizing your experience on our Platform. Certain laws may provide you with the right to limit our information sharing activities in certain circumstances. Please review these rights in the “Country and Region-Specific Terms” section below.

Cookies and other tracking technologies. You can find information on changing your browser settings to opt-out of cookies in your browser settings. In certain countries, you may also be able to make changes to your cookies settings by using our cookie preferences tool. If you disable some or all of the cookies the service, or parts of the service may not work.

For advertising and analytics. ZVAMY.ORG may use advertising networks and other providers to display advertising on our ZVAMY.ORG Platform or to manage our advertising on other sites. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests and determine the effectiveness of such advertisements. See also the “Country and Region-Specific Terms” section below for additional pages.

The ZVAMY.ORG Platform is not currently configured to respond to browsers’ “Do Not Track” signals because at this time no formal “Do Not Track” standard has been adopted.

For legal reasons. We may share your information with third-parties for legal reasons without your consent, and as permitted by law, including:

• When we reasonably believe disclosure is required in order to comply with a subpoena, court order, or other applicable law, regulation or legal process
• To protect the rights, property, or safety of ZVAMY.ORG, the ZVAMY.ORG Platform, our customers or others
• To protect or defend against attacks
• To enforce, remedy, or apply our Terms of Service or other agreements
• To prevent fraud, cybersecurity attacks or illegal activity
• With regulatory agencies, as necessary to help detect and combat fraud and/or protect our customers, users and/or the ZVAMY.ORG Platform, or in required institutional risk control programs.

Your information rights and choices

Your rights

At ZVAMY.ORG, we believe that you have rights to information that pertains to you, your household and/or your business. If another person has input or processed information in the ZVAMY.ORG Platform about you or on behalf of you, your family or your business (and we are processing such information as data controller), you may ask to receive a copy of your information, even if you do not have an account with us.

Depending on where you live, you may have certain state- or nation-specific rights with respect to your personal information that we collect and process.

For specific information on what steps you can take to manage your privacy, please see the “Country and Region-Specific Terms” section for your country, below.

Verification

To help protect privacy and the security of your information, you may be asked to provide additional information to verify your identity and/or ownership rights prior to us exercising your data rights. If we are unable to verify your identity or ownership rights to the data, we may not be able to provide you with data rights until you are able to provide us with proper documents.

Information retention

Unless you specifically ask us to delete your personal information, we retain your personal information as long as it is necessary to comply with our data retention requirements and provide you with services and the benefits of the ZVAMY.ORG Platform and successfully run our business. However, even if you request a deletion, we may be required to maintain your information for as long as necessary to:

1. comply with our legal or regulatory compliance needs (e.g. maintaining records of transactions you have made with us);
2. to exercise, establish or defend legal claims; and/or
3. to protect against fraudulent or abusive activity on our service.

This means we may keep different information for different periods. If your account is canceled because you’ve not used it in a long time, we may delete this information straight away.

There may be occasions where we are unable to fully delete, anonymize, or de-identify your information due to technical, legal, regulatory compliance or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.

International data transfers

You agree and ZVAMY.ORG reserves the right to store and process your personal information in the United States and in any other country where ZVAMY.ORG or its affiliates, subsidiaries, or service providers operate facilities in accordance with and as permitted by applicable laws and regulations. Some of these countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).

When we transfer, store or process personal information outside of your jurisdiction, we take appropriate safeguards to require that your personal information remain protected in accordance with this Privacy Statement and applicable law. We may use contracts or the Standard Contractual Clauses approved by the European Commission or, as may be applicable, the equivalent clauses approved by the UK Government, to help ensure your information is protected. For more information on the transfer safeguards we rely on and where they have been made available please contact us by using the details in the “How to contact us” section below.

Although not relied on for data transfers, ZVAMY.ORG complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU), the United Kingdom (UK), and Switzerland to the United States. We are subject to the investigatory and enforcement powers of the Federal Trade Commission. .

Security of your personal information

We use physical, technical and organizational safeguards designed to protect your information. However, despite these controls, we cannot completely ensure or warrant the security of your information.

Changes to our Privacy Statements

From time to time we may change or update our Privacy Statement. We reserve the right to make changes or updates at any time. If we make material changes to the way we process your personal information, we will notify you by posting a notice in our platform or on a community post; by sending you a notification; or by other means consistent with applicable law.

You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Privacy Statement. Please review this Privacy Statement periodically to stay informed about how ZVAMY.ORG protects your privacy.

Collection and use of children’s personal information

Our services are not intended for or directed to children. We do not knowingly collect personal information from children. If you believe we may have information from a child, please contact us.