Privacy Policy.

The privacy of users (“Users”) of the website www.zoovu.com (“Website”) and of Zoovu’s services (“Services”), including our platform (“Platform”) as relevant, is important to Zoovu.

Zoovu is the controller of Users Personal Data and processes Personal Data in accordance with Regulation (EU) No. 2016/679 of 27 April 2016 on the protection of natural persons regarding the processing of personal data (“GDPR”), the UK GDPR as well as any other local applicable laws relating to Personal Data protection that may apply where Zoovu and its subsidiaries are located.

Zoovu’s corporate group (Zoovu Group) comprises the following companies: Zoovu US Holdings, LLC, Zoovu Limited, Zoovu (USA) Inc., Zoovu Canada Inc., Zoovu (Germany) GmbH, Zoovu (Austria) GmbH, Zoovu France SAS, Zoovu (Belgium) BV, Zoovu (Poland) Sp. z o.o. Zoovu Group’s entities act as joint controllers of Users Personal Data. For further information about our joint controller arrangement, please contact us at: [email protected].

Users will find in this privacy policy (“Privacy Policy”) the rules that Zoovu applies when processing information that directly or indirectly allows for the identification or identifiability of Users (“Personal Data”), when Users use the Website, the Services or the Platform. This Privacy Policy applies to any personal data that Zoovu processes as a data controller under the GDPR and the UK GDPR, including data of our Website visitors, personal data processed as part of the provision of our Services and Platform when Zoovu is the controller and contact details and other personal data of our customers, except for personal data of our employees.

By accessing and using the Website, the Services and the Platform, Users acknowledge that they have read and understood this Privacy Policy, which may be amended or updated from time to time without prior notice. All amendments or updates will be posted on the Website. If amendments to the Privacy Policy involve matters for which consent of the Users was previously required or otherwise any significant changes, Zoovu will notify Users accordingly and collect their consent where applicable.

1. Types of Personal Data collected

Among the types of Personal Data that Zoovu collects, by itself or through third parties, there are:

• Identification data: first name and last name.
• Professional data: work email address, work phone number, company name, job title.
• Usage data: data generated by customer’s use of the Services and Platform including event data (Digital Assistant performance, questions and answers flow, navigation, product), traffic source, information as to log-in and log out times, browser, device used;
• Cookies and Technical Data (as defined below).
• Any comments Users may provide to Zoovu when completing a form on the Website.

Technical Data shall refer to information collected automatically through this Website (or third-party services used in this Website), which can include: the IP addresses or domain names of the computers used by the Users, the URI addresses (Uniform Resource Identifier), the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system used by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within this Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

In our role as a controller, we normally process Personal Data about the following categories of data subjects:

• Website visitors.
• Our clients and business contacts.
• Authorised users of our Platform.

Personal Data may be provided directly by Users, or, in the case of Technical Data, collected automatically when using the Website.

Unless specified otherwise, all Personal Data requested on this Website or as part of the provision of the Services are mandatory and failure to provide such Personal Data may limit access to the Services or this this Website. In cases where this Website specifically states that certain Personal Data is not mandatory, Users are free not to communicate them without consequences to the availability of the services.

2. Purposes of processing of personal data and lawful bases

Personal Data is collected and processed for the following purposes:

• Analytics and tag management: monitor and analyze web traffic and keep track of Users’ behavior on the Website (main legal basis: consent of Users and legitimate interest);
• Contacting Users: answers to Users’ enquiries to schedule a demo, obtain a personalized proposal or to give Users information on Zoovu partner program (main legal basis: steps required to enter into a contract);
• Provision of the services (main legal basis: contract).
• Managing the relationship with our customers (main legal basis: contract and legitimate interest).
• To administer and protect our business, products and services and this Website (main legal basis: legitimate interest).
• To diagnose problems with our servers, to administer our servers and to monitor servers and optimize traffic and flows (main legal basis: legitimate interest).
• For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (system logs) and use other Personal Data (such as the IP Address) for this purpose (main legal basis: legitimate interest);
• To send you marketing communications, where you have not opted out (main legal basis: legitimate interest and/or consent).
• To establish, exercise or defend legal claims (main legal basis: legitimate interest).

We may also process your Personal Data as required to comply with a legal obligation we are subject to. Whenever we process any Personal Data based on legitimate interest, we will conduct a Legitimate Interest Assessment to ensure that the individual’s interests do not override those legitimate interests.

We may ask for consent if we need to process Personal Data for a different purpose.

3. Protection and storage of Personal Data

Personal Data shall be processed and stored for as long as required for the purpose they have been collected for or as is otherwise required by applicable law. Our retention periods will vary depending on the type of data involved, but, generally, we will refer to these criteria to determine retention period:

• Whether we have a legal or contractual need to retain the data.
• Whether the data is necessary to provide our Services.

When calculating the appropriate retention period for the Personal Data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods.

Therefore, Users are informed that Personal Data is stored for up to three (3) years from the last contact using the contact form.

If an agreement has been entered into between Zoovu and Users after using the contact form, Zoovu will store Users’ Personal Data for up to five (5) years after the termination of the agreement.

Zoovu will retain Personal Data for a longer period if Zoovu is required to do so for complying with a legal obligation or upon the order of an authority or if necessary for the establishment, exercise or defense of legal claims.

Once the retention period expires, Personal Data shall be deleted.

4. Disclosure of Personal Data

We do not rent or sell your personal information to anyone without your explicit consent, but, subject to the need to perform the contract with you based on the contract you enter with us and our legitimate interests, we may share your personal information as set out below:

• Other companies in the Zoovu Group;
• Our third-party service providers who perform functions on our behalf in connection with the operation of our business such as IT service providers and system administrators, third parties who host and manage data or provide programming or technical support;
• Our third-party analytics providers to analyze website traffic and understand User or customer needs and trends or our third-party marketing service providers to help us to communicate with Users or customers;
• Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services;
• Third parties if we are the object of a merger acquisition or merger absorption;
• Third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites, Users or customers.

5. Transfers of Personal Data

We may transfer the data to a destination outside the European Economic Area (“EEA”) or the UK.

Where we transfer the data outside the EEA or the UK, we will take all steps reasonably necessary to ensure that the Personal Data is treated securely and in accordance with this Privacy Policy, by ensuring at least one of the following safeguards is implemented:

• transferring your personal data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission or the ICO, including the US when it comes to transfers of personal data to entities participating in the EU-US Data Privacy Framework, the Swiss-US Data Privacy Framework and the UK Extension to the EU-US Data Privacy Framework;
• entering into specific contractual terms which have been approved by the European Commission or the ICO, as applicable, and which give personal data the same protection as within the EEA.

6. Rights of Users

Users may exercise certain rights regarding their Personal Data processed by Zoovu.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given such consent to the processing of their Personal Data;
• Object to processing of their Personal Data. Users have the right to object to the processing of their Personal Data if the processing is carried out on a legal basis other than consent when Personal Data is processed based on Zoovu legitimate interest. Users may object at any time when their Personal Data is processed for marketing purposes;
• Access their Personal Data. Users have the right to learn if Personal Data is being processed by Zoovu, obtain disclosure regarding certain aspects of the processing and obtain a copy of Personal Data undergoing processing;
• Verify and seek rectification. Users have the right to verify the accuracy of their Personal Data and ask for it to be updated or corrected.
• Restrict the processing of their Personal Data. Users have the right, under certain circumstances, to restrict the processing of their Personal Data. In this case, the Zoovu will not process them for any purpose other than storing it;
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Personal Data, except for Personal Data that Zoovu is under a legal obligation to hold.
• Receive their Personal Data and have it transferred to another controller. Users have the right to receive their Personal Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.;
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

How to exercise these rights

Any requests to exercise Users’ rights can be sent to the following email address: [email protected] or to Zoovu Limited, 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom. Alternatively, you can fill in the contact form on our Contact page to submit your request.

These requests can be exercised free of charge and will be addressed by Zoovu as early as possible and always within one month from the receipt of the request.

7. Cookie List

A cookie is a small piece of data (text file) that a website, app or platform – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. In these cases, the vendor Privacy Policy and Terms may apply. Please see the “View Vendor Details” section of our cookie banner for further information. More specifically, we use cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies

Strictly Necessary cookies are essential to our Website and Platform functioning as expected. You cannot turn off Strictly Necessary cookies because they are required to deliver security, enable core site functionality, and help you use our site’s features and services as you would expect (including remembering your cookie consent preferences). Zoovu does not use these cookies to track individuals across websites.