ZayZoon US Inc. (together, “ZayZoon”,“we”or “us”) is a leading fintech provider that assists small to midsize businesses in providing low cost, transparent, and innovative financial products and solutions to their employees.  This Privacy Notice (“Notice”) covers the Personal Information that ZayZoon and its affiliates located in Canada (“Affiliates”) collect through zayzoon.com and other websites or applications (the ZayZoon apps (“Apps”) are the sub-domains of our Websites) that post a link to this Notice (collectively, our “Websites”).

This Notice informs you about how we collect, use, disclose, and store Personal Information in our role as a Controller of Personal Information when you: 

• Interact or use our Websites, including when you download materials from our resources page, request a demo or ask us to contact you. 
• Provide your Personal Information for the purposes of administering our services and managing our relationship with you in any manner (collectively “Services”) e.g. setting up an account or collecting your Personal Information to provide you with access to your accrued but as yet unpaid wages. 

Definitions

Personal information means information that (either in isolation or in combination with other information) enables you to be directly or indirectly identified (“Personal Information” or “Personal Data”)

Data controller or a Business (“Controller”) is a party that sets out the purposes and means of processing of Personal Information. Data processor or a Service Provider/Contractor/Third Party (“Processor” or “Third Party”) is a party that processes Personal Information on the Controller’s behalf.

 

1. Personal Information ZayZoon Collects 

Personal Information you provide to us

From Websites or Events: We collect Personal Information that you choose to provide to us, for example, on our “Get a free demo” (or similar) online form, when you interact with a chat bot on one of our Websites, or if you register for any Events. If you contact us through the Website, we will keep a record of our correspondence.

From the Services:  We receive and store the Personal Information you provide directly to us, or through your payroll provider, employer, bank, or other third-party service. For example, when setting up new account and to provide you the services, we collect Personal Information, which may include, but is not limited to, name, e-mail address, postal address, phone number, job title, date of birth, employment information such as wages, time and attendance, and scheduling information. We may collect and store media, documents, or other information you provide to us. We collect commercial information, such as records of your use of the Services or information related to requests for demos. 

Cookies

Our website and mobile app may utilize cookies and other tracking technologies in order for us to provide or advertise our Services, and to enable, optimize, and analyze operation of our Services. A cookie is a small text file that may be used, for example, to collect information about website and Service activity. Certain cookies and other technologies may serve to recall information, such as an IP address, previously indicated by a user.

• Browser Control. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

 

• Website Control. You may also set your cookie preferences on our website. If you are not logged in or your IP address is blocked, you may have to re-set your preferences on a subsequent visit when you are logged in or your address is unblocked. You may also have to do so on each device from which you access our Services.

 

Personal Information we automatically collect

When you use the Websites: When you visit our Websites, we collect Internet or other electronic network activity information through the use of cookies and other trackers. Depending on your tracking preferences, the information we collect may include for example your device’s Internet Protocol (“IP”) address, referring website, what pages your device visited, and the time that your device visited our Website. We also rely on analytics and tools used to prevent spam and other security risks related to the use of abusive automated software. You can choose your preferences with regards to the cookies and other trackers by accessing the preference center on our Websites.

When you use the Services: Internet or other electronic network activity information is also collected when you use the Services: 

• Identifying information – we collect information to identify you as part of our KYC/AML obligations, such as your first and last name, email address, phone number, date of birth and last four digits of your SSN.
• Employment information or financial-related information – we collect employment information such as pay information, time and attendance, and information relating to the account to which the pay is directed.
• Usage information – we keep track of user activity in relation to the types of Services our customers and their users use, the configuration of their computers, the performance metrics related to their use of the Services, and user interface information on our site or in our mobile application, such as keystrokes, mouse clicks, page flips, and what you viewed to provide faster and better user support and aid our engineering team in solving bugs and improving user experience.
• Geolocation data – If you have chosen to sign up for Automatic Work Verification, we also collect a very limited portion of your location data. The times of entry and exit at your place of work are the only data that we collect and retain. We use solely use this geolocation tracking to record when you arrive and leave your place of work.
• Log information – we log information about our customers and their users when they use one of our Services, including login credentials, browser type, service provider, or operating system, and their IP addresses. 
• Information collected by cookies and other tracking technologies – we use various technologies to collect information, including saving cookies to users’ computers. 
• Customer feedback – We collect your communications with ZayZoon via chat or telephone to provide customer service. While using the Services, you may be asked to provide feedback (e.g., in the software directly or after receiving help from our support team). Providing this feedback is entirely optional. 

Information we collect from trusted third parties 

If your Personal Information has been collected as (i) you interacted or used our Website, or (ii) part of the Services, your Personal information, as stored in our CRM service provider, may be enriched or updated to ensure it is accurate and up to date, and we achieve the purpose for which it was originally collected. Please note that we will also obtain non-personal information related to your organization’s name, structure, industry, and similar attributes through the use of third parties’ data sets, for the purpose of enriching or updating your Personal Information we already hold. 

We may obtain information about you, such as mailing address, gender, age, marital status, and job status from third-party data providers. We may use this information for marketing purposes and research purposes.

• We may use this info to market our products and services to you.
• We may use this info to provide aggregated, anonymized insights to third-party entities for the purpose of determining the impact of Services on user financial wellness.

 

2. How and on what grounds do we use your Personal Information?

Personal Information we collect directly from you via our Websites

 We use the Personal Information we collect through our Websites for the purposes of:   

• administering our Websites and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes. 
• improving our Websites so the content is presented most effectively for you and your device, including system maintenance and repair. 
• trend monitoring, marketing, and advertising. 
• purposes made clear to you at the time you submit your Personal Information, for example, to fulfill your "Get a free demo", to provide you with access to one of our webinars or whitepapers, to provide you with information you have requested about our Services, or to provide you with information on Services we think might be of interest to you. 
• data security and integrity, including fraud or illegal activity prevention and detection.
• providing the Services, including verifying customer information, processing or fulfilling transactions, processing payments.
• customer service.
• For research and development of new products or improvement of existing products.

Personal Information we collect directly from you as part of the administration of our Services

We use the Personal Information we collect, directly or indirectly, from our customers, in connection with the Services we provide for the following reasons: 

• Set up a user account. 
• Provide, operate and maintain the Services. 
• Process and complete transactions, and send related information, including transaction confirmations 
• Manage our customers’ use of the Services, respond to inquiries and comments, and provide customer service and support. 
• Send customers technical alerts, updates, security notifications, and administrative communications. 
• Investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities. Undertake analysis of conversion rates, sales, system usage, marketing effectiveness and other analytics projects.  
• For any other purposes about which we notify customers and users. 
• Cookies: When ZayZoon customers access the Services, we use strictly necessary cookies and other trackers to provide authentication tools, enhance security, and prevent fraud. The preferences signaled on our Websites (through the cookie banner and preference center) will be reflected on the Apps. For example, if you choose to accept performance cookies on one of our Websites, these will be active in the Apps unless you modify your choices by resurfacing the preference center.

We use your Personal Information in this context to provide the Services to you or our legitimate interests, typically, either for security purposes or business practice improvement (e.g., the prevention and investigation of fraudulent activities). We may use your designated email address or mobile phone number to: (i) send you updates or news regarding the Services; and/or (ii) respond to a Contact Us or administrative requests (for example, to change your password).

You authorize your wireless carrier to use or disclose information about your account your wireless device, if available, to us or our service provider for the duration of your business relationship solely to help them identify you or your wireless device and to prevent fraud. This Notice sets out how we treat your data.

 

3. How do we share and disclose Personal Information to third parties?

We do not sell your data. Our use and sharing of the data is solely limited to what is reasonably required for providing, developing, marketing, and improving the Services. We share and disclose information, including Personal Information, about our customers in the following limited circumstances: 

Vendors, consultants, and other service providers

We may share your Personal Information with our affiliates, vendors, consultants, and other Processors we employ to perform services on our behalf.  These Processors include our payment processing providers (e.g. Interchecks), website analytics providers (e.g., Google), tools we use to prevent spam and other security risks related to the abusive automated software (e.g., Cloudflare), online activities, product feedback or help desk software providers (e.g., Intercom), CRM service providers (e.g., Hubspot), and e-mail service providers (e.g., Twilio). These transfers will typically be based on our legitimate interests, such as to provide and improve our Services, to create insights about our users, to contact you in connection with the Services and certain programs, features or offerings that you may have registered for, to advertise our Services, and to identify and authenticate your access to the parts of the Services that you are authorized to access.

Marketing operations

Our use of cookies and other tracking technologies in our marketing operations is based on the choices you make in our preference centers which you may access from the footer of our Websites or by clicking on a cookie icon that appears on our Websites. We process your Personal Information through the tools provided to us by Google Analytics and Meta Events Manager to provide and enhance our advertising services. Our use of Personal Information collected for marketing operations is limited to the following purposes: 

• Targeting specific audiences based on users’ location and interests related to the search query.
• Personalizing the ads that users see based on their search queries.
• Optimizing our campaigns based on front-end metrics provided by Google Ads (e.g. clicks and webpage impressions).
• Tracking the performance of our campaigns and measuring key metrics such as clicks, conversions, and return on investment to understand how our campaigns are performing and make data-driven decisions.
• Adopting Brand Safety protection: ensuring we are not displaying our ads on unsafe or inappropriate websites, to protect our brand reputation.
• Adopting of fraud prevention in our campaigns to protect our campaigns from online fraud (e.g. click fraud).

Direct marketing

We may send you direct marketing communications as permitted by law, including by email. Our direct marketing purposes are based on your consent. For example when you contact us directly, create an account with us, agree to receive communications after an Event, and similar circumstances. We may also rely on our legitimate interests to contact you to offer related services that may be of interest to you based on your employer and/or your payroll provider offering our Services as an employee benefit. You always have the right to opt out of any direct marketing by using the unsubscribe link in our emails, or texting STOP in response to any text messages.

Business transfers

We may choose to buy or sell assets and may share and/or transfer customer information, including Personal Information, in connection with the evaluation of and entry into such transactions and based on our legitimate interests. Also, if we or our assets are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be one of the assets transferred to or acquired by the third party.

ZayZoon group companies

We may also share your Personal Information within the ZayZoon family of companies for the purposes consistent with this Notice and based on our legitimate interests or contractual necessity.   

Protection of ZayZoon and others

We reserve the right to access, read, preserve, and disclose any Personal Information as necessary to i) administer our Services, ii) comply with a law, regulation, legal process or a governmental request, iii) enforce or apply our Terms with you and other agreements, including investigations and of potential violations thereof, or iv) protect the rights, property, or safety of ZayZoon, our employees, our users, yourself, or others. 

Disclosures for national security or law enforcement

Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements, based on our legitimate interests or legal obligations.

Use of anonymous information

We may create anonymous data from personal information by excluding information that makes the data personally identifiable, and use that anonymous data for our lawful business purposes, including to provide workforce insights to our employer clients.

 

 4. How long do we store your Personal Information?

We store your Personal Information for different time periods depending on the category of Personal Information and the nature of relationship that you have with us. We determine how long we need Personal Information on a case-by-case basis, but our goal is to keep your Personal Information for as short period as possible to achieve the purpose for which Personal Information is collected. We consider the following criteria when we are making decisions on how long we will retain your Personal Information: 

• The category of Personal Information. 
• Whether the Personal Information is typically deleted based on specific schedules, such as marketing information. 
• Whether the Personal Information is necessary to operate or provide our services.
• How long we need to retain the Personal Information to comply with our legal obligations.
• Our legitimate interests or legal purposes, such as network improvement, fraud prevention, record-keeping, promoting safety, security and integrity, or enforcing our legal rights.  

 

5. Security and certifications 

We use appropriate technical, organizational, and administrative security measures to protect any Personal Information we store from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

No company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user’s Personal Information at any time. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately (including but not limited to selecting a unique password that you have not previously used for any other account) and limiting access to your computer or device and browser by signing off after you have finished accessing your account. 

 

How can I exercise my privacy rights? 

You may have certain rights relating to your Personal Information, depending on your location and subject to local applicable laws. These rights may include, subject to any exceptions or limitations:

• The right to know what Personal Information is being collected and for what purpose.  
• The right to know what Personal Information is being “sold” or “shared”, for what purpose and the categories of recipients of your Personal Information.
• The right to access your Personal Information.
• The right to have your Personal Information rectified, corrected or updated.
• The right to have your Personal Information deleted, including from any third parties where your Personal Information has been sold, shared or disclosed.  
• The right to opt out of the “sale” or “sharing” of your Personal Information. 
• The right to object to the processing of your Personal Information.
• The right not to be subject to any automated decision making and profiling.  

If you would like to access, review, update, correct, and delete any Personal Information we hold about you, or exercise any other privacy rights available to you, you can contact our customer success team through online chat at our Website.  Our privacy team will review your verifiable privacy rights request (“Privacy Rights Request”) and respond to you as quickly as possible. If we are unable to comply with your request due to an exception or limitation, we will explain this in writing. If we need more time, we will inform you of the reason and extension period in writing. 

Opting In and Opting Out. You may choose to receive promotional and advertising text messages from us by providing us with your written consent directly or through your employer. You may choose not to receive future promotional or advertising emails or text messages from us by selecting an unsubscribe link at the bottom of such emails or by texting STOP to opt-out of such text messages. If you opt-out of receiving the foregoing emails or text messages, we may still send you a response to any live chat request as well as administrative emails necessary to facilitate your use of our Services (for example, in connection with a password reset request, an email/text message verification, or a payment-related email/text message).

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. Privacy regulations in the United States, such as the laws of California and Delaware, require ZayZoon to indicate whether it honors your browser’s “Do Not Track” settings concerning targeted advertising. ZayZoon adheres to the standards set out in this Policy and does not monitor or respond to Do Not Track browser requests. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

Online Tracking Opt-Out. There are a number of ways to opt-out of having your online activity and device data collected:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery, or uBlock Origin, and configuring them to block third-party cookies/trackers
• Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:
  • Google: https://adssettings.google.com
  • Hotjar: https://www.hotjar.com/legal/policies/privacy/
  • Twitter: https://twitter.com/settings/account/personalization?lang=en
  • Sailthru: https://getstarted.sailthru.com/audience/managing-users/user-optout-levels/#Opt-out_Management
• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance: http://optout.aboutads.info
  • Network Advertising Initiative: http://optout.networkadvertising.org

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.

State-Specific opt-outs. You may opt-out using methods for which you are eligible identified in U.S. Consumer Data Rights below.

If you would like an authorized agent to make a Privacy Rights Request on your behalf, the agent may do so by filling out this request form.   We will ask for written, signed permission that the agent has been authorized to act on their behalf. Once written authorization is provided, we will review your Privacy Rights Request and respond to you as quickly as possible. We will respond directly to the e-mail address provided by the authorized agent regarding the fulfillment of the Privacy Rights Request.

ZayZoon does not discriminate against you for exercising your privacy rights. We remind you that you have a right to lodge a complaint with a supervisory authority should you feel unsatisfied with our treatment of your Personal Information. 

6. Multi-State Consumers Notice.

We are required to provide consumers in California (CA) and Virginia (VA), effective 1/1/2023; Connecticut (CT) and Colorado (CO), effective 7/1/2023; and Utah (UT), effective 12/31/2023 notice of certain privacy rights regarding the information we have collected, used, or disclosed relating to them. You are entitled to exercise these rights free from discrimination.

Multi-State Consumer Notice Scope. If you are a resident of one of these states and your engagement with ZayZoon has been limited to visiting our website or communicating with us, this Notice applies to you because your information is not subject to the federal Gramm-Leach-Bliley Act (“GLBA”).

Shared Rights.

• This Privacy Policy explains how we may have used and shared personal information through the Services during the past 12 months, or may use and share your personal information through the Services. We describe the types or categories of personal information processed; the purposes for processing the personal information; the categories of data shared with third parties; and the categories of third parties with whom data is shared in Information Collected and Purpose/Use of Personal Information, and their subsections, above.
• Access and Portability. You can request a copy of the personal information provided by your employer that we maintain about you.
• Opt-out of Sale of Personal Information. You can opt-out by: (1) the methods identified in Submitting Requests (12.3) above; or (2) visiting the Do Not Sell My Personal Information. Furthermore, we offer instructions on how to limit online tracking in the “Online Tracking Opt-Out” section above.
• Opt-out of Targeted Advertising. We may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests. You can opt-out by the methods identified in Submitting Requests (12.3) above. You may receive less relevant ads instead.

Limitations. This Multi-State Consumers Notice and the rights it sets out do not apply to the personal information we collect, use or disclose about:

• Consumers who initiate or complete the process of onboarding to our Services. This is because this information or ZayZoon is subject to the GLBA and implementing regulations, or the California Financial Information Privacy Act (“FIPA”). This means that if you have initiated or completed an application for a ZayZoon account, this Notice and the rights it sets out do not apply to you to the extent that the GLBA governs.
• Representatives of businesses that seek to obtain our products or services, or to provide products or services to ZayZoon, except CA residents from whom ZayZoon collects personal information reflected in certain business-to-business communications.

Please note that the states below limit these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request.

Exercising Rights. You may submit requests via the methods identified in How can I exercise my privacy rights? above.

Other U.S. Consumer Data Rights

Under the California Privacy Rights Act (‘CPRA’) and Virginia Commonwealth Data Protection Act (‘CDPA’), residents of California and Virginia have certain rights regarding the Personal Information that businesses collect and process about them. This includes the rights to request access or deletion of your Personal Information, as well as the right to direct a business to stop selling or sharing your Personal Information. 

We are required to detail the categories of Personal Information that we that we collect and/or share for the purposes described in the section “How and on what grounds do we use your Personal Information?” of this Notice and, to the Processors and Third Parties listed in the section “How do we share and disclose Personal Information to third parties?”  

At this time, ZayZoon honors verified consumer deletion requests, irrespective of the consumer’s eligibility that would otherwise be determined by jurisdiction, with limited exceptions for compliance, investigations, providing a product or service requested by the consumer, data security and integrity, research and development, or as otherwise allowed or required by applicable law. Our deletion policy is subject to change from time to time and ZayZoon reserves the right to make changes to this policy in a manner consistent with applicable law.

We collect and in the past 12 months have collected the following categories of Personal Information for our business purposes:

• Personal Identifiers.
• Information collected by cookies and other technologies, including IP address.
• Internet or other electronic network activity information`, including app log information, content you view or engage with, and app, browser and device information.
• Inferences drawn from any of the above categories of Personal Information. 

Notice to CA Consumers.

In addition to the above, the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”) entitles you to this supplemental privacy notice of the rights below to CA residents. CA defines resident as every individual who is in the State for other than a temporary or transitory purpose, or domiciled in the State, but outside the State for a temporary or transitory purpose. Consumers include CA residents from whom ZayZoon collects (1) workforce-related personal information; or (2) personal information reflected in certain business-to-business communications. All other individuals are nonresidents to whom the CCPA and CPRA are inapplicable.

While ZayZoon does not sell Personal Information in exchange for any monetary consideration, we do share Personal Information for other benefits as defined by Cal. Civ. Code 1798.140(ad)(2). We have shared in the preceding 12 months Personal Information as necessary for specific “business purposes,” as defined by Cal. Civ. Code 1798.140(e) and specified in the section “How do we share and disclose Personal Information to third parties?” This includes sharing personal identifiers, commercial information, and internet or other electronic network activity with payment processing providers, customer relationship management, consulting, e-mail, product feedback, helpdesk services, advertising networks, and website analytics companies. You have a right to direct ZayZoon not to sell or share your Personal Information.  ZayZoon does not collect the Personal Information of consumers who are under 16 years of age.

For the CA residents to whom this CCPA notice applies, in addition to the right identified in the Multi-State Consumers Notice above, you have the following rights.

• Opt-out of Selling or Sharing My Personal Information. You can ask us not to sell or share your personal information for interest-based (i.e. cross-context behavioral) advertising by: (1) the methods identified in Submitting Requests (12.3) above; or via this “Do Not Sell or Share My Personal Information” link . You may receive less relevant ads instead.
• Correction. In addition to the capability to correct inaccurate personal information, ZayZoon will assist your employer or in our own discretion, directly correct verified requests to correct inaccurate personal information, to the extent doing so is neither impossible nor requires disproportionate efforts.
• Explanation of Denial. If we deny your request, we will provide the reason or reasons explaining the denial.

Authorized Agents. CA residents can empower an “authorized agent” to submit requests on their behalf. This agent may be subject to verification as applicable to the circumstances.

Notice to VA Consumers.

The Virginia Consumer Data Protection Act (“VCDPA”) entitles Virginia residents to this supplemental privacy notice of the rights below to VA residents. The VCDPA is inapplicable to all other nonresident individuals.

For the VA residents to whom this VCDPA notice applies, in addition to the rights identified in the Multi-State Consumers Notice above, you have the following rights.

• Correction. In addition to the capability to correct inaccurate personal information, ZayZoon will assist your employer or in our own discretion, directly correct verified requests to correct inaccurate personal information, to the extent doing so is neither impossible nor requires disproportionate efforts.
• Appeal. If we deny your request, we will provide the reason or reasons explaining the denial. You have the right to appeal the decision via the methods identified in Submitting Requests (12.3) above. If the appeal is denied, you may contact the Attorney General at (800) 552-9963 or www.ag.virginia.gov

Notice to CT Consumers.

The Connecticut Data Privacy Act (“CTDPA”) entitles Connecticut residents to this supplemental privacy notice of the rights below to CT residents. The CTDPA is inapplicable to all other nonresident individuals.

For the CT residents to whom this CTDPA notice applies, in addition to the rights identified in the Multi-State Consumers Notice above, you have the following rights.

• Correction. In addition to the capability to correct inaccurate personal information identified in Access/Accuracy (0.0) above, ZayZoon will assist your employer or in our own discretion, directly correct verified requests to correct inaccurate personal information, to the extent doing so is neither impossible nor requires disproportionate efforts.
• Appeal. If we deny your request, we will provide the reason or reasons explaining the denial. You have the right to appeal the decision via the methods identified in Submitting Requests (12.3) above. If the appeal is denied, you may contact the Attorney General at 860-808-5420 or https://portal.ct.gov/AG

Notice to CO Consumers.

The Colorado Privacy Act (“CPA”) entitles Colorado residents to this supplemental privacy notice of the rights below to CO residents. The CPA is inapplicable to all other nonresident individuals.

For the CO residents to whom this CPA notice applies, in addition to the rights identified in the Multi-State Consumers Notice above, you have the following rights.

• Correction. In addition to the capability to correct inaccurate personal information identified in Access/Accuracy (9.0) above, ZayZoon will assist your employer or in our own discretion, directly correct verified requests to correct inaccurate personal information, to the extent doing so is neither impossible nor requires disproportionate efforts.
• Appeal. If we deny your request, we will provide the reason or reasons explaining the denial. You have the right to appeal the decision via the methods identified in Submitting Requests (12.3) above. If the appeal is denied, you may contact the Attorney General at (720) 508-6000 or https://coag.gov/.

Notice to UT Consumers.

The Utah Consumer Privacy Act (“UCPA”) entitles Utah residents to this supplemental privacy notice of the rights below to UT residents. The UCPA is inapplicable to all other nonresident individuals. For the UT residents to whom this UCPA notice applies, your rights are identified in the Multi-State Consumers Notice above.

• Explanation of Denial. If we deny your request, we will provide the reason or reasons explaining the denial.

For more information on how to exercise your rights, including the list of privacy rights that may be available to you, please see section “How can I exercise my privacy rights?” of this Notice. If you would like to access, review, update, correct, delete any Personal Information we hold about you, or exercise any other privacy rights available to you, including the right to opt out from selling or sharing your Personal Information, you can click the “Exercise your Rights” link located on the top left corner of this Notice, fill out this request form or send your request to: support@zayzoon.com.  

We endeavor to respond to a Privacy Rights Request within the required timeframes. If we need more time, we will inform you of the reason and extension period in writing. If you submit your Privacy Rights Request electronically through our request form, we will deliver our written response to the verified email associated with the request. If you did not submit the request with us via the online webform, we will deliver our written response by mail or electronically, at your option. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Children 

We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for the services or send any Personal Information about yourself to us. 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 you believe that a child under 13 may have provided us their Personal Information, please contact us at support@zayzoon.com. 

Linked websites

 For your convenience, hyperlinks may be posted on the Websites that link to other websites (“Linked Sites”). We are not responsible for, and this Notice does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the Websites. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read each Linked Site’s privacy notice to understand how the Personal Information about you is used and protected. 

  Changes to this Notice

We are constantly trying to improve our Websites and Services, so we may need to change this Notice from time to time. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We will alert you about material changes by, for example, placing a notice on our Website and/or sending you an e-mail (if you have registered your e-mail with us) when we are required to do so by applicable law. You can see when this Notice was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Notice. Your continued use of the Services thereafter means that you accept those changes.

  

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