Privacy Policy

Last updated: May 23, 2018

This Privacy Policy applies to ZETHA LTD and any of its affiliated websites, applications and other digital services in connection with which this Privacy Policy is linked or posted (collectively, “Services”). This Privacy Policy does not apply to information that is collected offline or by any third-party websites or services that you may access through the Services.

This Privacy Policy explains how ZETHA LTD Ltd (collectively, “ZETHA LTD”) collects and uses data and information that may identify or can be directly associated with an individual person (“Personal Information”). ZETHA LTD respects your right to privacy. Your ability to make informed choices about the uses of your information is important to us. This Privacy Policy explains ZETHA LTD’s policy regarding the collection, use, disclosure and protection of any information we receive including your Personal Information (if any).

Information ZETHA LTD Collects from End Users

ZETHA LTD uses the Platform and/or Services to collect information regarding End Users’ activities and operations that interact with the Platform or that interact with any content that may be available through the Platform. Such information includes IP-address, Session ID, browser type, mobile or desktop ID, referrer, user language and feedback or answers provided by the End User to any interactive content unit made available with the Platform. Such information may qualify as Personal Information in some End Users’ jurisdictions, however, we do not make any use of such data to directly identify individuals or to associate it with individuals.

Information ZETHA LTD collects from visitors of the ZETHA LTD website

When you access the ZETHA LTD website, we may collect information from the computer or device that you use to access the Services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.

How ZETHA LTD Protects Information

ZETHA LTD follows applicable laws and generally accepted industry standards to protect the Personal Information submitted to ZETHA LTD by implementing adequate technical and organizational protection measures, both during transmission and once ZETHA LTD receives it. These measures will be continuously adjusted and updated in accordance with current industry standards. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while ZETHA LTD strives to use commercially acceptable means to protect Personal Information, ZETHA LTD cannot guarantee its absolute security.

How ZETHA LTD Uses Information

Where required by applicable laws, ZETHA LTD will only process, use or share User’s Personal Information with third parties with User’s explicit permission or as described in this Privacy Policy. ZETHA LTD will only disclose Personal Information as described in this Privacy Policy or where required by law, regulation, subpoena or court order. ZETHA LTD uses Personal Information to the extent necessary for internal purposes – for example, in connection with offering the Services, to help diagnose problems with ZETHA LTD’s servers, to make ZETHA LTD’s Services more useful.

Use of Partners’s Employee Personal Information:

ZETHA LTD collects, processes and uses Custimer’s Employee Personal Information for purposes of administering the Services, and to improve the experience of the ZETHA LTD Services.

Use of End User’s Personal Information:

ZETHA LTD may use information it collects, including Personal Information, to provide the End User with the Services and in order to provide End Users with advertising that ZETHA LTD reasonably believes may be more useful or interesting to the End User. The Personal Information collected by ZETHA LTD will not be connected by ZETHA LTD to any other personal information collected by third parties for advertisement purposes. In addition, by analyzing all information ZETHA LTD receives, including all information concerning End Users and their interaction with the Platform and content made available through the Platform, ZETHA LTD may irreversibly compile aggregated statistical information across a variety of mobile applications and End Users (“Statistical Information”). Statistical Information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be improved and tailored to customer desires. Statistical Information is anonymous and does not, in and of itself, identify any specific end user or customer of ZETHA LTD. ZETHA LTD may share such Statistical Information with its partners or any third party, without restriction, on commercial terms that ZETHA LTD can determine in its sole discretion.

Personal Information is not transferred or disclosed to third parties other than as set forth in this Privacy Policy.

Opt-Out

If End User does not wish its Personal Information to be collected, processed or shared for the above purposes, he may opt out from this use with effect for the future. For opting out, the End User can do so by sending an email to [email protected] or sending a paper letter to ZETHA LTD’s Privacy Officer at the following address:  40 Bloomsbury Way, Lower Ground Floor, London WC1A 2SE, England. However we do encourage you to reach out via email which is checked more often.

Cookies

A cookie is a small piece of text that is sent to the End User’s browser and stored on his computer or mobile device. All cookies used by ZETHA LTD are persistent cookies, i.e. they will be stored on the User’s device after the browser session has expired. Any cookie will be deleted within one month after it has been placed unless configured otherwise. Most Web browsers are initially configured to accept cookies, but the User can change this setting so his browser either refuses all cookies or informs him when a cookie is being sent. Also, the User is free to delete any existing cookies at any time with future effect. Some features of ZETHA LTD’s Services may not function properly when cookies are disabled or removed.

Cookies placed on End Users’ computers:

Cookies placed on an End User’s computer will transmit the End User’s Personal Information as specified above to ZETHA LTD for the purposes also specified above.

Online Links to Other Sites

Links to third-party websites

ZETHA LTD may link to other websites of third-parties that provide useful information/services. Any information User provides on the linked pages is provided directly to this third-party and is subject to that third-party’s provider’s privacy policy. ZETHA LTD is not responsible for the content or privacy practices of Web sites to which it links. Links from ZETHA LTD’s site to third parties or other sites are provided for User’s convenience. You should learn about the privacy practices of each web site before providing them with Personal Information.

Social media websites and widgets

ZETHA LTD may link to other websites of third-parties that provide useful information/services. Any information User provides on the linked pages is provided directly to this third-party and is subject to that third-party’s provider’s privacy policy. ZETHA LTD is not responsible for the content or privacy practices of Web sites to which it links. Links from ZETHA LTD’s site to third parties or other sites are provided for User’s convenience. You should learn about the privacy practices of each web site before providing them with Personal Information.

Use of ZETHA LTD by Children

ZETHA LTD does not knowingly collect Personal Information from individuals under the age of 18. In the event you become aware that an individual under the age of 13 has enrolled without parental permission, please advise us immediately.

ZETHA LTD will disclose any information, including Personal Information, to the extent required by applicable law. ZETHA LTD will fully cooperate with any law enforcement authorities or court order requesting or directing it to disclose the identity, behavior or digital content of any User suspected to have engaged in illegal or infringing behavior.

Uses of Personal Information described in this Privacy Policy may be accomplished by ZETHA LTD or its service providers. In providing the Platform and Services, ZETHA LTD may use subcontractors or service providers that are located in countries other than User’s own, including countries that might be outside the European Economic Area, and transfer to them Personal Information ZETHA LTD collects and processes as further specified in here.

ZETHA LTD currently uses Google Cloud Services as a cloud and storage service provider with servers in the US, and where information obtained from the Platform or ZETHA LTD’s website is stored. Google Cloud’s terms and privacy policy is available at: https://cloud.google.com/terms/ and here: https://www.google.com/policies/privacy/. The Cloud Services are Privacy Shield certified (information can be found here: https://cloud.google.com/security/compliance/eu-data-protection/).

ZETHA LTD uses Google Analytics, a web analysis service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google places cookies on User’s computer to analyze User’s use of the Platform and the ZETHA LTD website. The information collected by the cookie is transferred to and stored on Google servers located in the US. ZETHA LTD is using commercially reasonable efforts to leverage the IP-anonymization service of Google, i.e. a service offered by Google whereby a User’s IP address will be shortened before transfer to the US. After shortening the IP addresses, the collected data cannot be directly matched to a User. Google will process and use the collected information on behalf of ZETHA LTD in order to analyze User’s use of the Platform and the ZETHA LTD website, to compose respective reports and to provide certain other services to ZETHA LTD related to the use of the Platform and the ZETHA LTD website. The IP address collected by the cookie will not be collated with other Google data. User can change the settings of his browser so it refuses all cookies of third parties. Also, User is free to delete any existing cookies at any time with future effect. User can also contradict the collection and use of data by the Google cookie by installing the browser plugin available for download under the following hyperlink: https://tools.google.com/dlpage/gaoptout?hl=en. For further information regarding Google Analytics please see examples of Google’s terms of use (https://www.google.com/analytics/terms), data protection overview (http://www.google.com/intl/de/analytics/learn/privacy.html) and privacy policy (www.google.de/intl/de/policies/privacy).

ZETHA LTD may share some of the information collected via the Services with certain trusted partners and/or technology platforms in order to present personalized advertisements to Users. In such cases, the transfer and storage practices of the information shall be governed by the policies provided by such partners and/or technology platforms.

ZETHA LTD uses commercially reasonable efforts to ensure that all its service providers will be subject to nondisclosure and non-use obligations and bound to process Personal Information solely as instructed by ZETHA LTD in a separate Data Processing Agreement as required under applicable law. Nevertheless, some countries where ZETHA LTD’s service providers are located may have levels of protection of personal and other information which are not as high as in the User’s country of residence or business.

ZETHA LTD may transfer its databases containing Personal Information of Users in connection with a sale of its business or assets or any part of them that requires the use of the databases.

ZETHA LTD may transfer Personal Information to other countries whose privacy laws may not be as protective as in your place of residence. By providing your Personal Information to us, you consent to the transfer of your Personal Information to other countries for processing consistent with this Privacy Policy, as well as to subsequent transfers of such information consistent with the other terms of this Privacy Policy.

Marketing Communications

We may send you email or other messages about us or our products and services. By the Privacy Policy or using the Services, you affirmatively consent to receive such commercial messages. You can ask to have your Personal Information removed from our mailing list and stop receiving future communication from us by following the unsubscribe link located at the bottom of each communication or by emailing us at [email protected]. You will also be given the opportunity to unsubscribe from commercial messages in any such email or other message we send. Please note that we reserve the right to send you service related communications, including service announcements and administrative messages, relating either to your account or to your transactions using the Services without offering you the opportunity to opt out of receiving them unless you cancel your account.

User’s Rights

User may at any time request information from ZETHA LTD regarding his Personal Information stored at ZETHA LTD, its origin, recipients or categories of recipients the data has been transferred to and the purpose of storage.

Upon written request by User ZETHA LTD will make all commercially reasonable efforts to delete any information provided to it, unless required otherwise for further execution of an agreement with a Customer or required by applicable laws. ZETHA LTD cannot restore information that it has deleted.

For executing any of these rights User may contact ZETHA LTD by sending an email to [email protected] or sending a paper letter to ZETHA LTD’s Privacy Officer at the following address:  40 Bloomsbury Way, Lower Ground Floor, London WC1A 2SE, England. However we do encourage you to reach out via email which is checked more often.

Changes

ZETHA LTD may update this Privacy Policy from time to time – we encourage you to review it periodically. We reserve the right to modify this policy. If required under applicable law, we will provide you with written notice of our changes. We will not make changes that have a material retroactive effect unless we are legally required to do so. Your continued use of the Services constitutes your acceptance of the amended policy. The amended policy supersede all previous versions, notices or statements of or about the policy.
Comments and Questions / Contact Information

If you have any comments or questions about our privacy policy, please contact us at [email protected].