ZEPIC Privacy Notice


Effective Date: 12/10/2023

This privacy notice (“Notice”) explains how ZEPIC, Inc. or any of its affiliates or subsidiaries, (“We”, “Us”, “Our”, “Zepic”) processes Personal Data collected from natural persons as specified in the section “How We Collect, Use and Share Your Personal Data” below, as a Controller which shall include but is not limited to Our collection, use and disclosure of information obtained through Our Websites.

For Personal Data processed, stored or hosted by Us when We act as a Processor on behalf of You in the course of providing the Service(s), our data processing agreement will govern Our processing of Your Personal Data.

1. DEFINITIONS

Terms not specifically defined herein shall have the meaning ascribed thereto in the Terms.

1.1.  “Controller” means the natural or legal person, public authority, agency, or other body which alone or jointly with others, determines the purposes and means of the processing of Personal Data.

1.2.  “End-User” means any person or entity with whom the User interacts using the Service(s).

1.3.  “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1.4.  “Processor” means a natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller.

1.5.  “Service(s)” shall have the meaning ascribed to it in the Terms.

1.6.  “Subscriber” means the natural or legal person that has subscribed to the Service(s) by agreeing to the Terms or signing any other agreement for the subscription and use of the Service(s).

1.7.  “Terms” means the Terms of Service at https://zepic.com/terms/.

1.8.  “Website(s)” means the websites owned and operated by Us including zepic.com.


2. HOW WE COLLECT, USE AND SHARE YOUR PERSONAL DATA

2.1. PERSONAL DATA THAT YOU PROVIDE US

When you
are a(n)

What personal
data we collect

How we use your

personal data

Whom we share your

personal data with

Website user who enters information in the landing pages used by marketing teams

Your contact information, such as Your full name, email, phone, location, country, business name and address

To inform, promote and sell Our Services to You

Third party partners that provide Us marketing services

Individual who registers for Our event(s), promotions webinar or contest

Your contact information, such as Your full name, email, phone, location, and business name

To ensure that the event is conducted in a secure and effective manner

To inform, promote and sell Our Services to You

Sponsors of such contests

Third party organisers that assist Us with the organisation of such events, webinars, contests

Individual who
communicates with Us

Your name or any other Personal Data You may provide Us in the course of such interaction

Unless prohibited by law, We may record any telephonic conversation We have with You

To respond to Your queries or requests

To inform, promote and market Our Services to You

Third party partners who assist Us in providing Our Services to You

Individual who requests a demo

Your contact information, such as Your full name, email, phone, business name and shipping address

To give You the demo and

To inform, promote and market Our Services to You

Individual who is a Subscriber

Billing information, name, address, e-mail id

To enable Your subscription and collect the fees

Third party payment
processors who process payment information for Us but who are otherwise not permitted to store, retain or use such information

User who is onboarded to use the Services on behalf of the Subscriber

Your contact information, such as Your full name, email address, unique identifiers such as username, account number or password

Creation of a User account, verification of a User’s identity and help a User log into Our Services

To communicate with a User regarding existing products and Services availed by Subscriber including notifications of any alerts or updates

To send the User
information about Our other products or services, events, webinars or programs which may be of interest to such User

Third party partners who assist Us in onboarding You and providing Our Services to You

User who requests customer support

Your name, usage information or any other Personal Data You may provide Us in the course of such interaction

To provide support in relation to Your use of Our Services

Third parties who assist Us in providing these support services

User who submits certain information to Our Services, such as filling out a survey about their user experience or feedback

Information You have provided as part of it

To improve Our Services

Third parties who assist Us in providing these services

Individual who registers as a partner with us

Name and other contact information

To register and onboard You as a partner

Third parties who assist Us in managing partner enrolment or partner program management

Individual who applies for an employment opportunity with Us through Our online recruitment system

Your contact information, such as name, email address, mailing address, phone number; any other information You volunteer, including during any interview or Your interactions with Us and contained in the resume that You submit to Us

To evaluate You for any position that You have applied for or that We may consider You at the time that You submitted Your resume or on a later date

With external recruiters and organizations like those that do candidate information verification on Our behalf and on behalf of Our group entities

Third parties whose products We use in maintaining a record of and evaluating You for the position applied


2.2. PERSONAL DATA THAT WE COLLECT NOT PROVIDED DIRECTLY BY YOU

As You navigate through the Website, We may also automatically collect details about Your visits to the Website, including Your IP address, usage patterns, traffic data, location data, logs, other communication data, and the resources that You access, as well as information about Your device and internet connection, including Your operating system and browser type.

We also collect some of this information using cookies and similar tracking technologies. For detailed information, please see our Cookies Policy section in clause 8

When You

are a(n)

What Personal Data 

We Collect

How We use Your

Personal Data

Whom We share Your

Personal Data with

Website visitor

Your device and details about your visits to the Website like, IP address, usage patterns, traffic data, location data, logs, other communication data, company website URL and the resources that you access, as well as information about your device and internet connection, including your operating system and browser type

As described in the section “Cookie Policy”

For market analysis, and market research

To protect Our data from threats, violations, and breaches if any

To inform, promote and sell Our Services to You

Third party partners who provide Us with services in connection with such processing

User who uses and interacts with Our Services

Your device and details about your Service access like, IP address, usage patterns, traffic data, location data, logs, other communication data, and the resources that you access, as well as information about your device and internet connection, including your
operating system and browser type

To evaluate, develop and improve Our products and
Services

For market analysis, product analysis and
market research

To provide support in connection with Your queries

Third party partners who assist Us in such processing

Individual whose
information (a) third party sources share with Us without breach of any confidentiality clause; or (b) is available on public platforms

Your contact information, such as Your full name, email address, phone number, designation and business name. We may combine this information with any Personal Data
provided by You

To update, expand, and analyze our records and create more tailored advertising to provide services that may be of interest to You

Third party partners who assist Us in such processing


2.3.
If You provide Us with any Personal Data relating to other individuals, You represent that You have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Notice.


2.4. In addition to the details provided in the table above, We may also share Your Personal Data with
3. LEGAL BASIS FOR PROCESSING

3.1.  If You are a data subject from the European Economic Area, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it. We will normally collect Personal Data from You only where We need it to perform a contract with You, where the processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where We have Your consent. In some cases, We may also have a legal obligation to collect Personal Data from You. If We process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.

3.2.  If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided under clause 11.

4. INTERNATIONAL TRANSFER

4.1.  We mainly process Personal Data in the United States, India and Australia. However, We may transfer Personal Data outside the United States, India and Australia for the purposes referred to in clause 2. We will ensure that the recipient of Your Personal Data offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws. 

4.2.  If You are a resident of the European Economic Area and when Your Personal Data is processed outside EEA, We will ensure that the recipient of Your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.

5. RETENTION OF PERSONAL DATA

5.1.  We retain the Personal Data collected where an ongoing legitimate business requires retention of such Personal Data.

5.2.  In the absence of a need to retain Personal Data under clause 5.1. above, We will either delete it or aggregate it, or, if this is not possible then We will securely store Your Personal Data and isolate it from any further processing until deletion is possible.

6. SECURITY OF PERSONAL DATA

We use appropriate technical and organizational measures to protect the Personal Data that We collect and process. The measures We use are designed to provide a level of security appropriate to the risk of processing Your Personal Data. If You have questions about the security of Your Personal Data, please contact Us immediately as described in this Notice.

7. YOUR RIGHTS

You are entitled to the following rights:

7.1.  You can request Us for access and correction of Your Personal Data.

7.2.  If We have collected and processed Your Personal Data with Your consent, then You can withdraw your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We have conducted prior to Your withdrawal, nor will it affect processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.

7.3.  You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. For more information, please contact Your local data protection authority.

7.4.  You have the right to opt-out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails We send You. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact Us.

7.5.  If You are a resident of the EEA, UK, or Switzerland, You are also entitled to the following rights:
7.6.  If You seek to exercise Your rights under this clause, please contact Us at the details provided in clause 11. We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

8. COOKIE POLICY

8.1.  Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behaviour information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We also use certain monitoring and tracking technologies, such as cookies, beacons, pixels, tags, and scripts (collectively, “Cookies”). These technologies are used in order to provide, maintain, and improve our website and platform or any other website or webpage operated by Us, to optimize our offerings and marketing activities, and to provide You with a better experience (for example, in order to track users’ preferences, to better secure our Service(s), to identify technical issues, and to monitor and improve the overall performance of our Service(s).  We also set cookies to collect information that is used either in aggregate form to help Us understand how Our Website(s) is being used or how effective Our marketing campaigns are, to help customise the Website(s) for You or to make advertising messages more relevant to You.

8.2. Essential Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, You may disable these by changing Your browser settings, but this may affect how the Website(s) functions.

8.3. Analytics, Customisation and Advertising Cookies: We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.

8.4. When You visit the Website(s), a cookie banner will be displayed providing additional information about cookies and options to opt out of non-essential cookies as required by applicable laws.

9. NOTICE FOR CALIFORNIA RESIDENTS 

9.1  This clause applies only to California residents and the Personal Information We collect as Business. “CCPA” means the California Consumer Privacy Act of 2018 as amended by the CPRA. “CPRA” means the California Privacy Rights Act. For the purposes of this section, the terms “Business”, “Business Purpose”, “Consumer“Personal Information”, “Sale/Sell”, “Service Provider” and “Sensitive Personal Information” and “Share” shall have the meaning given to them under the CCPA.

9.2  The categories of Personal Information We have collected in the twelve (12) months prior to the Effective Date and that We may collect include
9.3 Disclosure of Personal Information. We have disclosed the categories of Personal Information listed in clause 9.2 above for a business purpose in the twelve (12) months prior to the effective date and may disclose such Personal Information to service providers or contractors or to any other third parties who support our business provided (a) they do not Sell or Share such Personal Information or (b) retain, use or disclose such information for any purpose other than for the specific purpose of performing the services specified in our contract with them or (c) combine such information with any other information received directly by them. We do not Sell or Share (as the terms are defined in the CPRA) the Personal Information We collect without providing You a right to opt out. We do not Sell or Share Personal Information of minors of at least the age of thirteen (13) but less than sixteen (16) years without receiving such minor’s consent or the consent of the minor’s guardian if the minor is less than thirteen (13) years. We have not Sold or Shared any Personal Information in the twelve (12) months prior to the effective date. We shall not disclose further the Personal Information collected for verification of a consumer’s request or retain it longer than it is necessary for the purpose of verification.

9.4 You are entitled to the following rights under the CCPA:
California Consumers may make a request pursuant to their rights under the CCPA by contacting Us at the details provided in clause 12. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with the CCPA. Consumers may also designate an authorised agent to exercise these rights on their behalf.

10. PRIVACY OF CHILDREN

10.1. We recognize the importance of children's safety and privacy. We do not request, or knowingly collect, any Personal Data from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided Us with Personal Data, they should write to us at the email address provided in clause 12.

11. NOTICE TO CUSTOMER AND OTHER EXCLUSIONS

11.1. Other than the Personal Data collected for the purposes set forth in clause 2 for which We shall act as the Controller, for any other processing of Personal Data collected from or transmitted by a Subscriber, We will only act as a Processor of Personal Data and such processing will be governed by the terms and conditions of the agreement with the Subscriber. Where the Services are made available to an End-User through a Subscriber, the Subscriber is the Controller of the End-User’s Personal Data. An End-User will be directed to contact Our Subscriber for assistance with any requests or questions relating to their Personal Data. We are not responsible for Subscribers’ privacy or security practices which may be different from this notice. Subscribers to Our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, relating to the collection of Personal Data in connection with the use of Our Services by End-Users.

11.2. Our Website(s) contain links to other websites. Our Notice applies only to our Website(s), so if You click on a link to another website, You should read their privacy notice. We encourage You to review the privacy statements of any such other websites to understand their Personal Data practices.

12. CONTACT INFORMATION

You may contact Our privacy officer if You have any enquiries or feedback on Our personal data
protection policies and procedures, or if You wish to make any request, in the following manner:


Kind Attention: ZEPIC Privacy & Compliance

Email Address: privacy@zepic.com

Address: 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, USA.

13. CHANGES TO THE NOTICE

We keep this Notice under regular review and may update this webpage at any time. This Notice may be amended at any time and You shall be notified only if there are material changes to this Notice.