Zeplug U.S.A. LLC (“Zeplug,” “we,” “us,” or “our”) is committed to protecting the privacy of our clients, individuals interested in our business, and visitors to our website, zeplug.com (the “Site”). This Privacy Policy explains our privacy practices and the types of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as defined by applicable privacy laws (“Personal Information”) that we may collect or receive from the Site; any of our affiliates and subsidiaries’ websites; any other web address, mobile site, or application controlled by Zeplug that links to this Privacy Policy.  Please note, this Privacy Policy does not apply to our information collection practices in the European Union (EU) or United Kingdom (UK), for more information about our privacy practices in the EU and UK please refer to our separate GDPR privacy policy.

By accessing and using the Site, or otherwise providing information to Zeplug, you consent to the terms of this Privacy Policy, and consent to our privacy practices described herein including our use and disclosure of your Personal Information. If you do not agree to the terms and conditions of this Privacy Policy, then please do not provide us with your information. Please note, however, that if you choose to limit the information that you provide to us while using the Site, you may not be able to use or participate in certain features of the Site.

1.     MODIFICATIONS AND REVISIONS

We may update this Privacy Policy from time to time to reflect changes to our privacy practices. We will notify you of any changes to this Privacy Policy by posting the revised or updated Privacy Policy and its “Last Modified” date on the Site. If the revision or modification is material, we will provide you notification via email. Your continued use of the Site after the “Last Modified” date constitutes your acceptance of and agreement to the Privacy Policy and its revisions or updates. You should periodically read the Privacy Policy to learn of any revisions or updates.

2.     COLLECTION OF PERSONAL INFORMATION

During your use of the Site, Zeplug collects both Personal Information and non-personally identifiable information about you in various ways, including

• Directly from you when you provide it to us;
• Automatically as you use the Site; and
• From third parties.

a.     Information Provided by You

We may collect the following types of Personal Information and other information directly from you when you use the Site to subscribe to our newsletter, download our brochure, fill in contact forms on the Site, or communicate with our team.  We may collect the following types of Personal Information:

• Identifiers, including name, postal address, email address, phone number, and name of Company; and
• Information in Customer Records, including name, postal address, phone number, and name of Company;

b.    Information Automatically Collected by the Site

Zeplug and third-party service providers may automatically collect information about you when you use the Site.  Like many other websites or apps, Zeplug and its providers may collect and store information that is generated automatically as you navigate through the Site. This information is primarily needed to maintain the security and operation of the Site, and for our internal analytics so that we can improve the Site. This information includes:

• Internet and Electronic Activity Information, including cookies, details of your visits to the Site, including traffic data, generalized location data, logs, and other communication data and the resources that you access and use on the Site, device’s unique device identifier, operating system, browser type, mobile network information, device’s telephone number, browsing history, browser and device information, advertising identifiers, clickstreams, search history, usage details, Internet Protocol (“IP”) address, pixel tags, browser version, operating system, other tracking technologies.
• Cookies, are small data files that we transfer to your computer’s hard disk for record-keeping purposes. Cookies do not personally identify you; they merely identify the computer or device with which you access the Site. The Site use cookies to analyze trends, recognize you, tailor our Product and Business Services to you, or to detect and prevent fraud. You can instruct your browser, by changing its options, to disable cookies or to prompt you before accepting a cookie from the Site. If you disable cookies, however, you may not be able to use all portions or functionality of the Site;
• Third Party Cookies
• Google Analytics, we use Google Analytics on the Site to help us analyze the traffic on the Site. For more information on Google Analytics’ processing of Personal Information, please see http://www.google.com/policies/privacy/partners/ You may opt out of the use of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• Stirista Visitor ID Graph Tag, We use Stirista Visitor ID Graph (“VIG”) Tags to gain comprehensive insights about our visitors, tailor user experience, determine best outreach methods, and better measure, optimize, and retarget our marketing campaigns. More information about the protection of your privacy can be found in Stirista’s Privacy Policy: https://www.stirista.com/privacy-policy/

c.     Information Received from Third Parties

In some instances, Zeplug may receive Personal Information and/or anonymous data about you from other parties, such as our affiliates, business partners, and service providers. That information may be obtained online, offline, or through publicly available resources.  We may combine this information with the information you provide, and other data we already have about you.

We may also receive information about you from social media platforms, when you interact with us on those platforms, access our social media content, if you use a third-party account to sign-in to the Site, or link a third-party account to your account. Please note that the information we may receive from those third parties (such as Linkedin and Twitter) is governed by the privacy settings, policies and/or procedures of the applicable platform, and we strongly encourage you to review them before submitting any information using a social media platform.

3.     PURPOSE OF COLLECTION

We use your Personal Information for a variety of purposes, including to:

• Monitor the Site. We collect your Personal Information for monitoring purposes to help us diagnose problems with our servers, administer and troubleshoot the Site, calculate usage levels, analyze industry standards, and analyze transactions, trends, and statistics regarding the use of the Site.
• Respond to Inquiries and Fulfill Requests.  We may use your Personal Information to respond to your inquiries and to fulfill your requests for information. 
• Communicate with You.  We may use your Personal Information to send you marketing information about Zeplug services (the “Zeplug Services”), special promotions, and other items that may be of interest to you.  We may also contact you on behalf of our third-party business partners about a particular offering of theirs that may be of interest to you.
• Improve the Site.  We may use your Personal Information to make the Site more stable and user-friendly, to analyze service issues, improve the design and content of the Site, personalize your experience, analyze how the Site is used, offer new Zeplug Services, and to develop new marketing programs relating to the Zeplug Services.
• Customer Service. We may use your Personal Information when contacting you regarding customer service or in response when you provide feedback. We may also use your information to inform you of any changes to this Privacy Policy, our Terms of Use, or our third-party partner’s terms.
• Support Business Operations. We may use your Personal Information to support our internal and business operations, including marketing, security, and advertising.
• Enforce Agreements. We may use your Personal Information to enforce separate agreements between you and us, enforce this Privacy Policy, our Terms of Use, or our third-party partner’s terms of use, or in connection with a transaction with a similar effect.
• Fulfill Other Purposes. We may use your Personal Information to fulfill: (a) any other purpose for which you provide it; (b) any legal or regulatory requirements and any of our internal policies; (c) other purposes disclosed at the time of collection; (d) any other purpose with your consent; and (e) any other purposes set forth in this Privacy Policy.

4.     DISCLOSURE OF PERSONAL INFORMATION

Except as otherwise described in this Privacy Policy, we do not sell, share, rent, or otherwise disclose your Personal Information that we collect from the Site to any third parties for monetary or other valuable consideration, unless stated below or with your consent:

• Subsidiaries and Affiliates. We may disclose Personal Information about you to our subsidiaries and affiliates.
• Service Providers & Contractors. To help us provide superior service, your Personal Information may be shared with our service providers, contractors, and other third parties we use to support our business and who will safeguard it in accordance with this Privacy Policy. Such third parties may help us with order processing and fulfillment, providing customer service, maintaining and analyzing data, and sending customer communications on our behalf.
• Live Chat and Interactive Support. The Site may include “live chat” or other live interactive features. We may provide these features through technology provided by third parties, and you consent to the transfer of your Personal Information to these providers by using these features.
• Marketing Partners. We may share your Personal Information with entities that perform marketing or data aggregation services on our behalf, or with which Zeplug or an affiliate has joint marketing arrangements
• Advertising Partners. We may share your Personal Information with third party advertising partners, including but not limited to Instagram, LinkedIn, and Google Display Advertising and Remarketing services.  These advertising partners may use first- and third-party cookies together to inform, optimize, and serve ads based on your past visits to the Site. You can opt out of these services using the Ads Preferences Manager or you can use the Google Analytics opt-out browser add-on. These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks, commonly referred to as “interest-based advertising.”
• In the Event of Merger, Sale, Divestitures, or Change of Control. Zeplug reserves the right to transfer Personal Information to a buyer or other successor in interest that acquires rights to that information as a result of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of Zeplug or substantially all of its assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about you is among the assets transferred.
• With Your Consent. We may share your information for other purposes pursuant to your consent or at your direction.
• Other Disclosures. We may disclose your Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) conform to legal requirements and comply with any court order, law, or legal process, including responding to any government, law enforcement, or regulatory request; (ii) enforce the Terms of Use, other agreements, including between you and us, and any other documents included or referenced therein (all of which are incorporated into and made a part of this Privacy Policy by reference); (iii) fulfill the purpose for which you provide it; (iv) detect, prevent, or otherwise address fraud or security issues; or (v) protect against harm to our, your, or third parties’ rights, property, or safety.

We may share and disclose de-identified and/or aggregate analytics with third-party partners for the purposes described in this Privacy Policy or where it is collected, or any other legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable information combined with Personal Information.

5.     CHOICES

We strive to provide you with choices regarding how we use the Personal Information you provide to us. Please understand that if you choose not to disclose information to us, it may affect your ability to use some features of the Site. We have created mechanisms to provide you with the following control over your information:

a.     Advertising

We may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements about the Zeplug Services. Such third parties may gather information about your visit to the Site, monitor your access or market Zeplug Services or services to you, monitor the ads you view, click-on, or interact with, when they were delivered, and the screens and pages that they are on. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

We and our service providers may use information about your interactions with the Site to predict your interests and select the ads you see on and off the Site. This is known as interest-based advertising. In providing interest-based ads, we follow the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance (“DAA“).  For more information about interest-based advertising and how you can opt out, visit:

• Digital Advertising Alliance: http://www.aboutads.info/choices
• Network Advertising Initiative (NAI): http://www.networkadvertising.org/choices/

b.    Marketing

From time to time if you have supplied your email address, we may send you marketing or informational emails. If you prefer not to receive any or all of our marketing and promotional communications, you may opt-out of these communications by following the opt-out prompts on these communications. You also may ask us not to send you other marketing or informational communications by contacting us as specified in the Contact Information section below, and we will honor your request. Please note that even after you are removed from our marketing lists, we may still send you non-promotional communications, such as responding to your support requests.

c.     Do Not Track

Some browsers have a “Do Not Track” (“DNT”) feature that lets you tell websites and online services that you do not want to have your online activities tracked. Such browser features and industry standards are not uniform. As such, Zeplug does not monitor or respond to DNT browser requests.  If a standard is adopted that we must follow in the future, then we will inform you about that practice in a revised version of this Privacy Policy.

6.     THIRD-PARTY LINKS AND WEBSITE

The Site may contain links to third-party services, websites, mobile applications, and/or contain advertisements from third parties that are not affiliates with us – and which may link to other websites, services, or applications. While we endeavor to work with third parties that share our respect for user privacy, we are not responsible for the privacy policies or privacy practices of such third parties. Any information collected by third parties are not covered by this Privacy Policy. You are responsible for knowing when you are leaving the Site to visit a third-party website, service, or application and for reading and understanding the terms of use and privacy policy statements for each such third party. This Privacy Policy only governs information collected through the Site.

7.     CHILDREN

The Site is not intended for children, and we encourage parents and guardians to be aware of and monitor the websites visited by their children. Zeplug does not knowingly collect any Personal Information from children under 16 years of age. If Zeplug learns that a child under the age of 16 has submitted Personal Information to the Site without guardian or parental consent, we will take all reasonable measures to remove or delete such information as soon as practicable and not use such information for any purpose, except where necessary to protect the safety of the child or others or as required or allowed by law. If you believe a child under age 16 has provided us with Personal Information, please contact us as specified in the Contact Information section below.

8.     RETENTION PERIOD

Zeplug may retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law. We are under no obligation to store such Personal Information indefinitely and, to the extent permitted by law, disclaim any liability arising out of, or related to, the destruction of such Personal Information.

9.     CONFIDENTIALITY AND SECURITY

We take the security of your Personal Information seriously and have implemented appropriate technical and organizational measures to protect it from unauthorized access, disclosure, or destruction. While we implement these measures, please note that 100% security is not possible, and we cannot guarantee that the security measures we have in place to safeguard Personal Information will never be defeated or fail, or that those measures will always be sufficient or effective.

10.  PUBLIC FORUMS

We may provide public areas on the Sites, such as forums, blogs message boards, and chat rooms (“Public Forum”), where you can post information about yourself and others. Please exercise discretion and use caution with respect to your information, especially in such public areas. We do not control who reads postings on the Sites, or how they may use or disclose such information. If you choose to voluntarily disclose information on Public Forums, that information will be publicly available and can be collected and used by others.

11.  TESTIMONIALS

From time-to-time, with your consent, we may display personal testimonials or customer reviews of yours received via email or as otherwise received from you by Zeplug.  If you would like for us to remove your testimonial or customer review at any time, please contact us via the Contact Information section below, and we will promptly do so. 

12.  INTERNATIONAL TRANSFER OF INFORMATION

The Site is hosted in the United States. If you are visiting the Site from outside the United States, your Personal Information may be transferred to, stored, and processed in the United States in accordance with this Privacy Policy and applicable U.S. laws. Please note your Personal Information will be transferred, processed, collected, use, accessed, and/or stored in the United States, a country and jurisdiction that may not have the same data protection laws or rights as the country in which you reside, and subject to U.S. laws. Please do not provide your Personal Information to us if you do not want this information to be transferred or processed outside of your country, or if the laws in your country restrict such transfers. By using the Site, you consent to the transfer of your information to our facilities and the practices described in this Privacy Policy.

13.  CALIFORNIA PRIVACY RIGHTS

This section explains how we collect, use, and disclose Personal Information about users, customers, and visitors who reside in California (“consumers” or “you”). It also explains certain rights afforded to consumers under California’s Shine the Light law and the California Consumer Privacy Act of 2018 (“CCPA”), as revised and updated by the California Privacy Rights Act (“CPRA”). This section uses certain terms that have the meaning given to them in the CCPA including Personal Information.

a.     Shine the Light

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the Contact Information section below with a reference to California Disclosure Information.

b.    Categories of Personal Information Collected

We may collect (and have collected during the 12-month period prior to the “Last Modified” date of this Privacy Policy) the above categories of Personal Information about you in the Collection of Personal Information section above.

c.     Purpose of Collection

We may use (and may have used during the 12-month period prior to the “Last Modified” date of this Privacy Policy) your Personal Information for the business or commercial purposes described in the Purpose of Collection section above.

d.    Sources of Personal Information

During the 12-month period prior to the “Last Modified” date of this Privacy Policy, we may obtain (and may have obtained) Personal Information about you from the sources identified in the Collection of Personal Information section above.

e.     Selling and Sharing Personal Information

We do not sell or share your Personal Information in exchange for monetary consideration; however, we may use tools described above such as Google Analytics, which may be interpreted as sharing your Personal Information.  As such, please see the above Personal Information Automatically Collected and Choices sections for more information regarding opting out of use of these tools.

During the 12-month period prior to the “Last Modified” date of this Privacy Policy, we may have shared or disclosed the following categories of Personal Information about you for a business or commercial purpose with certain categories of third parties, as described below:

 

Categories of Personal Information that May Be Sold, Shared, or Disclosed	Categories of Third Parties to whom Personal Information May Be Sold, Shared, or Disclosed	Business or Commercial Purpose of Selling, Sharing, or Disclosing Personal Information
Identifiers	·       Subsidiaries and Affiliates ·       Service Providers and Contractors ·       Business Partners ·       Marketing Partners ·       Advertising Partners	·       Market the Zeplug Services ·       Communicate with You ·       Monitor the Site ·       Respond to Inquiries and Fulfill Requests ·       Improve the Site ·       Support Business Operations ·       Fulfill Other Purposes
Personal Information Categories Listed in The California Customer Records Statute (Cal. Civ. Code §1798.80(e))	·       Subsidiaries and Affiliates ·       Service Providers and Contractors ·       Business Partners ·       Marketing Partners ·       Advertising Partners	·       Market the Zeplug Services ·       Communicate with you ·       Monitor the Site ·       Respond to Inquiries and Fulfill Requests ·       Process payment ·       Improve the Site ·       Support Business Operations ·       Fulfill Other Purposes
Internet or Other Electronic Network Activity	·       Subsidiaries and Affiliates ·       Service Providers and Contractors ·       Business Partners ·       Marketing Partners ·       Advertising Partners	·       Provide the Site ·       Monitor and maintain the Site ·       Improve the Site ·       Support Business Operations ·       Fulfill Other Purposes

 

f.      California Consumer Privacy Rights

Under CCPA, consumers have certain rights regarding their Personal Information, as described below.

• Right of Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
  • The categories of Personal Information that we collected about you;
  • The categories of sources from which the Personal Information is collected;
  • The business or commercial purpose for collecting or selling Personal Information;
  • The categories of third parties with whom we share Personal Information;
  • The specific pieces of Personal Information that we have collected about you;
  • The categories of Personal Information that we disclosed about you for a business purpose or sold to third-parties; and
  • For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.
• Right of Deletion: You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law.
• Right to Opt-Out: You have the right to opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration. However, we do not sell any Personal Information.
• Right to Opt-In: We do not have actual knowledge that we collect, share, or sell the Personal Information of minors under the age of 16.
• Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Information that is collected or processed for “the purpose of inferring characteristics about a consumer.” However, we do not collect or process Sensitive Personal Information for this purpose.
• Right to Correction: You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.

If you would like to exercise your California privacy rights, please refer to the Consumer Requests and Verification section below. 

14.  VIRGINIA, COLORADO, CONNECTICUT, AND UTAH PRIVACY RIGHTS

This section is applicable to residents of Virginia, Colorado, Connecticut, or Utah. If you are a resident of Virginia, Colorado, Connecticut, or Utah, you have certain rights described below. The following do not apply to individuals who do not live in Virginia, Colorado, Connecticut, or Utah on a permanent basis, individuals we do not collect personal information about, or individuals for whom all of the information we collect is exempt from the statutes. “Personal Data,” for purposes of this section regarding the rights of residents, means any information that is linked or reasonably linkable to an identified or identifiable natural person and does not include de-identified information or publicly available information.

This section applies only to Virginia, Colorado, Connecticut, or Utah residents to the extent their Personal Data is subject to the Virginia Consumer Data Protection Act (VCDPA), or the Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), Utah Consumer Privacy Act (UCPA) or any amendments or acts thereto upon their effective dates.  The categories of Personal Data processed, the purposes of processing, the categories of Personal Data shared, and the categories of third parties to which Personal Data is shared are provided in the above sections of this Policy, including the chart depicted in the above section California Privacy Rights.

a.     Rights under VCDPA, CPA, CTDPA, and UCPA

Virginia, Colorado, Connecticut, and Utah privacy law provides residents with specific rights regarding Personal Data, including:

• Right to Access. You have the right to confirm whether or not we are processing your Personal Data and to access such information.
• Right to Correction. You have the right to correct inaccuracies in your Personal Data which we have collected, taking into account the nature of the Personal Data and the purposes of processing the Personal Data.
• Right to Deletion. You have the right to request deletion of Personal Data provided by or obtained about you, subject to legal exemptions.
• Right to Data Portability. You have the right to obtain a copy of your Personal Data.
• Right to Opt-Out. You have the right to opt out of the processing of Personal Data for purposes of (1) targeted advertising; (2) the sale of Personal Data; or, if you are in Virginia or Colorado (3) profiling in furtherance of decisions that produce legal or similarly significant effects.

If you would like to exercise any of the rights provided, please refer to the Consumer Requests and Verification section below.

15.  CONSUMER REQUESTS AND VERIFICATION

a.     Right to Non-Discrimination

We may not discriminate against you because you exercise any of your rights under CCPA, including, but not limited to:

• Denying goods or services to you;
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Providing a different level or quality of goods or services to you; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

b.    Verifying Requests

You may request to exercise your rights of access, deletion, or correction under CCPA by contacting us as described in the Contact Information section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request.  If you request access to or deletion of your Personal Information, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address. When you make such a request, you can expect the following:

• As required under applicable law, we will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.
• We will confirm that you want your information accessed, corrected, and/or deleted.
• We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.
• We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
• In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.

c.     Authorized Agents

You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the Contact Information section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:

• The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;
• You to verify your identity directly with us; or
• You to directly confirm with us that you provided the authorized agent permission to submit the request.

d.    Virginia and Connecticut Appeal Process

If you have made a request to access, correct, or delete your Personal Data under VCDPA and CTDPA, and we have declined to take action, you may appeal our decision within 45 days of the denial. When you make such an appeal, you can expect the following:

• We will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.
• We will review your appeal and respond in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision, within 45 days upon receipt of your appeal. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
• In certain cases, an appeal may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order. If we deny your appeal, we will explain why we denied it and provide you with a method to contact your state’s Attorney General to submit a complaint.

16.  CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy or our privacy practices, you can contact us via:

Email: info@zeplug.com

Mail: 1 Center Plaza, Ste. 425 Boston, MA 02108

Phone: +1 888-339-8428