ZillionSource Privacy Policy

This Privacy Policy applies to users (“You”, “Your”) of the ZillionSource Services (“Services”, “Service”, or “ZillionSource Services”), including the ZillionSource device, data and software, as provided by ZillionSource Technologies and its third party manufacturers, service providers, and distributors ("ZillionSource", “ZillionSource Technologies”, “We”, “Us”, “Our”). This Privacy Policy describes how We collect, use, and disclose Your Personal Information when You use the Services.

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), We process Your personal information under the following lawful bases:

• Your consent;

• The performance of the contract between You and Us;

• Compliance with Our legal obligations;

• To protect Your vital interests;

• To perform a task carried out in the public interest;

• For Our legitimate interests, which do not override Your fundamental rights and freedoms.

Personal data that is processed when You create a ZillionSource account

When You create a ZillionSource account, We ask You to provide Your email address and name. You can choose to provide only Your first name or a nickname instead of Your full name if You wish.

PURPOSES AND LEGAL GROUNDS:

(a) We process Your email address because You use Your email address and Your password to sign in to Your account. The legal ground for processing Your email address for this purpose is based on Our legitimate interest in protecting the security of Your account.

(b) We also process Your email address for the purpose of sending You important information about Your ZillionSource products, apps or account, such as important safety information or material changes to this Privacy Policy. The name You provide is associated with Your account profile, and may be displayed when You submit comments or other material on a ZillionSource website or app. The legal ground for processing Your email address and name for these purposes is Our legitimate interest in providing You important safety or other information about Your ZillionSource products, apps, account or material changes to this Privacy Policy, and in providing You an opportunity to engage with other ZillionSource users.

(c) If You provide Your opt-in consent to receiving marketing information from ZillionSource, We will also process Your email address for the purpose of sending You marketing information about ZillionSource products and apps. The legal ground for processing Your email address for this purpose is Your consent. You may withdraw Your consent at any time by changing Your preferences in Your ZillionSource account or through the unsubscribe link at the bottom of Our marketing emails. The marketing emails You receive from ZillionSource are based on the preferences You provide in Your ZillionSource account, the locale indicated by Your Internet Protocol (IP) address, the types of ZillionSource devices You have added to Your ZillionSource account, and any subscriptions included in Your ZillionSource account. The legal ground for processing this data for this purpose is Our legitimate interest in reducing the number of marketing emails sent to each particular customer by selecting which customers receive a relevant email rather than sending every marketing email to every customer who has consented to receiving marketing emails.

(d) We also process Your email address to associate it with Your ZillionSource account when You interact with Our customer support representatives. The legal ground for this processing is Our legitimate interest in providing quality customer support.

Personal data that is processed when You sign in to Your ZillionSource account with Social Media Credentials if You so choose

You may choose to sign in to Your ZillionSource account using Your social media sign in credentials (e.g., Your Facebook sign in credentials). If You choose to do this, the first time You do so You will be asked whether You agree that the social media provider may provide certain information to ZillionSource, such as Your name, email address, profile photo, posts, comments and other information associated with Your social media account.

All of this information is made available to Us by the social media provider due to the way the social sign-on configuration works. However, the only information We retain and processes is Your email address. If You do not want Your information to be shared with Us by the social media provider, then You can simply sign in to Your ZillionSource account using Your ZillionSource account credentials instead of Your social media account credentials.

PURPOSE AND LEGAL GROUND:

We associate the email address provided by the social media provider with Your ZillionSource account so that You can use Your email address to sign in to Your ZillionSource account in the future if You no longer wish to sign in using Your social media account credentials. The legal ground for processing this information for this purpose is Our legitimate interest in providing You an alternative sign in method and in securing Your account.

Personal data that is processed when You communicate with Us

When You interact with Our customer support representatives via email, telephone, online or in person, We collect personal data, such as Your name, mailing address, phone number, email address and contact preferences; and information about the ZillionSource products You own, such as their device ID and date of purchase. We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, We may also record and review conversations with customer support representatives, and analyze any feedback provided to Us through voluntary customer surveys. With Your consent, Our customer support representatives may sign in to Your ZillionSource account, if appropriate, to help troubleshoot and resolve Your issue.

PURPOSE AND LEGAL GROUND:

We use this information to provide You with customer and product support and to monitor the quality and types of customer and product support We provide to Our customers. The legal ground for processing this information for these purposes is Our legitimate interests in providing quality product support. The legal ground for signing in to Your ZillionSource account, if appropriate, to help troubleshoot and resolve Your issue is Your consent, which You may withdraw.

Personal data that is processed when You purchase a product on an e-Commerce website

When You visit the any of Our e-Commerce Site (“Site”), the Site may collect certain information about Your device, Your interaction with the Site, and information necessary to process Your purchases. See the list below for more information about what Personal Information the Site collects and why.

Device information:

Source of collection: Collected automatically when You access the Site using cookies, log files, web beacons, tags, or pixels.

Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products You view, search terms, and how You interact with the Site.

Order information:

Source of collection: collected from You.

Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.

PURPOSE AND LEGAL GROUND:

The Site collects device information in order to load the Site accurately for You, and to perform analytics on Site usage to optimize the Site. The Site collects Your Personal Information in order to fulfill Your order, to process Your payment information, arrange for shipping, and provide You with invoices and/or order confirmations, communicate with You, screen the orders for potential risk or fraud, and when in line with the preferences You have shared with Us, provide You with information or advertising relating to Our products or services. The legal ground for processing Your name, mailing address and telephone number for these purposes is performance of a contract. We also process Your personal data as part of the fraud detection processes. The legal ground for processing Your personal data for that purpose is Our legitimate interest in protecting Us and Our customers from attempts to engage in fraudulent transactions.

Personal data that is processed on ZillionSource Mobile apps

We also collect data from users about their usage of ZillionSource mobile apps. The types of analytical information that are collected include the date and time the app accesses Our servers, app version, the location of the device, language setting, what information and files have been downloaded to the app, user behavior (e.g., features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions. We use this data to improve the quality and functionality of Our mobile apps, to develop and market products and features that best serve You and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible.

PURPOSE AND LEGAL GROUND:

The legal ground for processing this analytical information is Our legitimate interest in understanding how Our customers interact with Our products, apps and website so We can enhance the user experience and functionality of Our products, apps and website.

Other disclosures

We may disclose personal data about You to others: (a) if We have Your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of Our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims. We may also transfer Your personal data to an affiliate, a subsidiary or 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, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that We transfer personal data to will not be permitted to process Your personal data other than as described in this Privacy Policy without providing You notice and, if required by applicable laws, obtaining Your consent.

Transfers of Personal Data

We are a global business. To offer Our products, apps and services, We may need to transfer Your personal data to affiliated group companies in other countries. When You create a ZillionSource account, add personal data in Your account profile, or upload data to Your ZillionSource account, Your personal data will be collected and stored on Our servers in the United States or in Europe.

All Our group companies are required to follow the privacy practices set forth in this Privacy Statement.

Cookies and Similar Technologies Website

To help analyze how You and other visitors navigate ZillionSource related website, and compile aggregate statistics about site usage and response rates, We, with assistance from third-party analytics service providers, collect certain information when You visit Our site. This information includes IP address, geographic location of the device, browser type, browser language, date and time of Your request, time(s) of Your visit(s), page views and page elements (e.g., links) that You click. We may use cookies, pixel tags, web beacons, clear GIFs or other similar tools on Our site or in Our email messages to assist Us in collecting and analyzing such information. We use this information to provide better, more relevant content on Our site, to measure the effectiveness of advertisements, to identify and fix problems, and to improve Your overall experience on Our site. We may also engage one or more third-party service providers to provide online advertisements on Our behalf. They may use a pixel tag or other similar technology to collect information about Your visits to sites, and they may use that information to send You targeted advertisements. For more information regarding this practice and to opt-out of such collection and use of this information by Our third-party service providers, please visit Networkadvertising.org (https://www.networkadvertising.org/).

If You do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows You to automatically decline many of these technologies, or to be given the choice of declining or accepting them.

If You reside in the European Union or other jurisdiction that requires the site operator to obtain Your consent to use cookies on Our sites, then You will have an opportunity to manage Your cookie preferences on the sites; except that certain cookies are required to enable core site functionality, and You cannot choose to disable those cookies.

Here are examples of third-party providers of analytics and similar:

Google: Google Analytics is used to track site statistics and user demographics, interests and behavior on website. We also use Google Search Console to help understand how Our website visitors find Our website and to improve Our search engine optimization. Find out more information (https://tools.google.com/dlpage/gaoptout) about how this analytics information may be used, how to control the use of Your information, and how to opt-out of having Your data used by Google Analytics.

Application Performance Monitoring:

We use various software tools to analyze and monitor the performance of Our complex ecosystem. To provide such services, Our app receives basic request information, including IP address, necessary to detect and diagnose anomalous errors and response times.

Social Networks:

Third-party social networks that provide interactive plug-ins or social networking features (e.g., to allow You to connect to Facebook or Google to find friends to add as connections or to “Like” a page) on ZillionSource website or mobile apps, may use cookies or other methods (e.g., web beacons) to gather information regarding Your use of Our website and apps. The use of such information by a third party depends on the privacy policy available on that social network’s website, which We encourage You to carefully review. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about Your use of Our site with any of Your Personal Information that they may have. We may also obtain analytics information from social networks that help Us measure the effectiveness of Our content and advertisements on social networks (e.g., impressions and clicks).

Children

The ZillionSource device is not intended to be purchased by anyone under the age of 13 years old. When a parent and or legal guardian purchases a device for use by a child and to locate a child the parent is acknowledging that any personal information transmitted to Us is solely the parents and not that of a child under the age of 13. We do not knowingly collect personal information from children under 13 years of age. We do not collect personal identifying information such as name, address, zip code from anyone and there is no place in Our interfaces with the public to collect such info. If We learn that We have collected personal information from a child under age 13, We will delete that information as quickly as possible. If for some reason You believe that We might have any information from a child under age 13, please contact Us through support.

Automatic decision-making

If You are a resident of the EEA, You have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on You or otherwise significantly affects You.

We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Privacy Policy Updates

We may update this Privacy Policy from time to time in order to reflect, for example, changes to Our practices or for other operational, legal, or regulatory reasons. You can determine when this Privacy Policy was last revised by referring to the “Last updated” legend at the end of this policy. Any changes will become effective upon Our posting of the revised Privacy Policy.

We will provide notice to You if these changes are material and, where required by applicable law, We will obtain Your consent. This notice will be provided by email or by posting notice of the changes on the ZillionSource website and apps that link to this Privacy Policy.

Retention of Personal Data

We will retain Your Personal Information for Our records unless and until You ask Us to erase this information. For more information on Your right of erasure, please see the ‘Your rights’ section below.

Your rights

GDPR

If You are a resident of the EEA, You have the right to access the Personal Information We hold about You, to port it to a new service, and to ask that Your Personal Information be corrected, updated, or erased. If You would like to exercise these rights, please contact Us through the contact information below.

CCPA

If You are a resident of California, You have the right to access the Personal Information We hold about You (also known as the ‘Right to Know’), to port it to a new service, and to ask that Your Personal Information be corrected, updated, or erased. If You would like to exercise these rights, please contact Us through the contact information below.

If You would like to designate an authorized agent to submit these requests on Your behalf, please contact Us through the contact information below.

Contact:

After reviewing this policy, if You have any questions, want more information about Our privacy practices, or would like to make a complaint, please contact Us by e-mail at support@ZillionSource.com.

Effective from October 2023

Last updated: October 2023