ZENFULNOTE PRIVACY POLICY
Effective Date: December 2, 2023.
1. Introduction.
This Privacy Policy describes how Zenfulnote LLC (“Zenfulnote,” “we,” “our,” or “us”) collects, uses, and discloses information about you as well as your choices regarding such information. For purposes of this Privacy Policy, unless otherwise stated, “information” or “personal information” means information relating to an identified or identifiable individual, and does not include aggregate information or information that does not identify you.
This Privacy Policy applies to information we collect where we control the purposes and means of processing. Specifically, it applies to information we collect through any of our websites, apps, emails, and other online services that link to this Privacy Policy (the “Service”). It does not apply to information collected by third parties or information collected in the context of your employment with us.
Please note that your use of the Service is subject to our Terms of Use.
Some regions provide additional rights by law, as described below for California, Colorado, Connecticut, Utah, Virginia and Nevada. (See section 14, 15 and 16).
For our contact details, see the “Contact Us” section below.
2. How We Collect Information.
We collect information about you in a variety of contexts, as described below.
Information through our Websites.
When you visit our websites, we may request certain information from you. Please do not provide any information that we do not request. The categories of information we collect include:
In addition, we and third parties we work with automatically collect information from your browser or device when you visit our websites, or view our emails or advertisements. The categories of information we automatically collect include:
This information is automatically collected through tracking technologies incorporated into our websites, emails, and advertisements, as described in the “Tracking Technologies” section below.
Information through our Apps.
When you use our apps, we may request certain information from you. Please do not provide any information that we do not request. The categories of information we collect include contact identifiers, content, as well as the following:
In addition, we and our service providers automatically collect information from your device relating to your use of our apps. The categories of information we automatically collect include device identifiers, device information, internet activity, and non-precise location data.
This information is automatically collected through tracking technologies incorporated into our apps, as described in the “Tracking Technologies” section below.
Information from Other Sources.
We also collect information from other sources. The categories of sources from which we collect information include:
Information We Infer.
We infer new information from other information we collect, including using automated means to generate information about your likely preferences or other characteristics.
Sensitive Information.
To the extent any of categories of information we collect are sensitive categories of information under applicable law, we process such information only for the limited purposes permitted by applicable law. We do not sell or use sensitive categories of information for purposes of targeted advertising or to make inferences.
3. How We Use Information.
We collect and use information in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include:
We may aggregate or de-identify information so it is no longer considered personal information. We may use non-personal information for any purpose to the extent permitted by applicable law. For details on your choices around use of your information, see the “Your Privacy Choices” section below.
4. How We Disclose Information.
We disclose the information we collect in accordance with the practices described in this Privacy Policy. The categories of persons to whom we disclose information include:
We may aggregate or de-identify information so it is no longer considered personal information. We may disclose non-personal information for any purpose to the extent permitted by applicable law. For details on your choices around disclosure of your information, see the “Your Privacy Choices” section below.
5. Tracking Technologies.
As noted above, we automatically collect information through cookies and other tracking technologies incorporated into our Service, as described below:
For details on your choices around cookies and other tracking technologies, see the “Your Privacy Choices” section below.
6. Third Parties.
We may link to or offer parts of our Service through websites and services controlled by third parties. In addition, we may integrate technologies, including those disclosed in the “How We Collect Information” section above, controlled by third parties. Except where third parties act as our service providers, they, and not us, control the purposes and means of processing any information they collect from you, and you should contact them directly to address any concerns you have about their processing. Third party data practices are subject to their own policies and disclosures, including what information they collect, your choices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
7. Your Privacy Choices.
We provide a variety of ways for you to exercise choice, as described below.
Region-Specific Rights.
Some regions provide additional rights by law, as described in our region-specific terms. This subsection details how you may exercise some of those rights to the extent they apply to you.
Communications.
You can opt-out of receiving certain communications from us, as described below. Your opt-out is limited to the email address or phone number used and will not affect subsequent subscriptions.
Accounts.
If you hold an account with us, you can delete your account through your account settings. We will address your request in accordance with our data retention practices.
Browser and Device Controls.
Matched Ads.
To opt out of us disclosing your hashed email address to third parties for matched ads purposes, please email us at [email protected].
8. Children.
The Service is not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us as set out in the “Contact Us” section below. We will delete the personal information in accordance with COPPA.
9. Data Security.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
10. Retention.
We retain information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
11. International Transfer.
We are based in the U.S. If you are located outside the U.S., please be aware that your information may be transferred to and processed in the U.S. or another country where we operate. Where required by applicable law, we will provide appropriate safeguards for data transfers, such as through use of standard contractual clauses.
12. Changes to this Privacy Policy.
We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide additional notice to you, such as through email or prominent notice on the Service.
13. Contact Us.
If you have any questions about or trouble accessing this Privacy Policy, please contact us:
By email: [email protected]
To exercise choice, use the methods described in the “Your Privacy Choices” section above or your region-specific terms below.
14. California.
These additional rights and disclosures apply only to California residents. Terms have the meaning ascribed to them in the California Consumer Protection Act as amended by the California Privacy Rights Act (“CPRA”), unless otherwise stated.
Notice at Collection.
At or before the time of collection of your personal information, you have a right to receive notice of our data practices. Our data practices are as follows:
We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the CPRA. A “sale” is broadly defined under the CPRA to include a disclosure for something of value, and a “share” is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the following categories of personal information for commercial purposes: contact identifiers, characteristics or demographics, commercial or transactions information, device identifiers, device information, internet activity, non-precise geolocation data, and inferences drawn from any of the above. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. We do not knowingly sell or share the personal information of minors under 16 years old who are California residents. For details on your rights regarding sales and shares, please see the “Right to Opt-Out of Sales and Shares” section below.
Some of the personal information we collect may be considered sensitive personal information under the CPRA. For example, data relating to mood, emotions, and other health data you provide. We collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CPRA.
Rights to Know, Correct, and Delete.
You have the following rights under the CPRA:
To exercise any of these rights, please follow the instructions for data subject requests in the “Your Privacy Choices” section above. Please note these rights are subject to exceptions. If you have an account with us, we may require you to use the account to submit the request. We will confirm receipt of your request within 10 business days and respond to your request within 45 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
Right to Opt-Out of Sales and Shares.
To the extent we sell or share your personal information as those terms are defined under the CPRA, you have the right to opt-out of the sale or sharing of your personal information. To exercise this right, please follow the instructions for opting out of sales, shares, and targeted advertising in the “Your Privacy Choices” section above.
Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and may verify your identity directly.
Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
Shine the Light.
Under California’s Shine the Light law, customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make a request, please write us at the email or postal address set out in the “Contact Us” section above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
Minors.
If you are a California resident under 18 years old and registered to use the Service, under California’s Online Eraser Law, you can ask us to remove any content or information you have publicly posted on the Service. To make a request, please write us at the email address set out in the “Contact Us” section above with “California Under 18 Online Eraser Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
15. Colorado, Connecticut, Utah, and Virginia.
These additional rights and disclosures apply only to residents of Colorado, Connecticut, Utah, and Virginia. Terms have the meaning ascribed to them in the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”), as applicable.
Data Subject Requests.
You may have the following rights under applicable law:
To exercise any of these rights, please follow the instructions for data subject requests in the “Your Privacy Choices” section above. Please note these rights are subject to exceptions. We will respond to your request within 45 days. If you have an account with us, we may require you to use the account to submit the request. We may require specific information from you to help us confirm your identity and process your request. If we are unable to verify your identity, we may deny your request. We do not process personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.
Right to Opt-Out of Sales and Targeted Advertising.
You also may have the right to opt-out of the processing of personal data for purposes of targeted advertising or the sale of personal data. To exercise this right, please follow the instructions for opting out of sales, shares, and targeted advertising in the “Your Privacy Choices” section above.
Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and may verify your identity directly.
Appeals.
If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected] and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows:
16. Nevada.
If you are a Nevada consumer, you have the right to direct us not to sell certain information that we have collected or will collect about you. To exercise this right, please follow the instructions for opting out of sales, shares, and targeted advertising in the “Your Privacy Choices” section above.
17. European Economic Area, Switzerland, and United Kingdom.
These additional disclosures and rights apply only to individuals located in the European Economic Area, Switzerland, or the United Kingdom (collectively, “Europe”). Terms have the meaning ascribed to them in the General Data Protection Regulation (“GDPR”).
Roles.
Company acts as a controller with respect to personal data collected as you interact with our Service.
Lawful Basis for Processing.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.
Data Subject Requests.
You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please follow the instructions for data subject requests in the “Your Privacy Choices” section above. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request. For details on our retention practices for personal data, see the “Retention” section above.
You have the right to lodge a complaint with the data protection regulator in your jurisdiction.