Last modified on: 8th February, 2022

 

1. Introduction :

This Privacy Policy explains how we collect, use and disclose information from our website visitors, and our current and prospective customers when they use our website, Platform, mobile application, and other online products and services (collectively, the “Services”) that link to this policy. The Services are available through the website www.izooto.com, its sub-domains, mobile sites, mobile applications (the “Platform”) offered by Datability Technologies Private Limited and its Subsidiaries or Affiliates (“iZooto”, “us”, “our”, and “we”). Subsidiaries of iZooto refer to the following: 

  1. Datability Solutions Inc.
  2. Yieldmonk Technologies LLC

We respect your privacy and are committed to protecting it through our compliance with this Policy.

This privacy policy (“Policy”) applies when we are collecting information of the following categories of users (“you”): 

  1. Website Visitors: Individuals who visit our websites, including www.izooto.com (the “Website”)
  2. Customers: individuals who on behalf of themselves or of an entity, subscribe to use any of the Services offered through the Platform. 
  3. End Users: individuals who are end users of our Customers’ websites or mobile application or subscribers of Facebook pages of such Customers. 

This Privacy Policy explains iZooto’s approach to any Personal Data that we might collect from you, or which we have obtained about you from a third party, and the purposes for which we process your Personal Data in our capacity as a Controller (i.e. when iZooto determines the purposes and means of the processing of personal data). It also describes your rights in respect of our processing of your personal data.

This Privacy Policy only applies to the use of your personal data by us or on our behalf. It does not apply to:

  • Personal Data collected by third parties during your communications/dealings with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control).
  • Personal Data processed, stored or hosted by us when we act as a Processor on behalf of our Customers in the course of providing our Services, in which case the privacy statement of the relevant Customer will apply, and our data processing agreement with such Customer will govern our processing of your Personal Data.

This Policy may change from time to time. Your continued use of the Website, Platform or the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

 

2. Information We Collect About You and How We Collect It

2.1           Website Visitors

 Information we Process 

Purpose of processing 

Legal basis of processing 

Computer and internet connection (including your IP address, operating system and browser type), your mobile carrier, device information (including device and application IDs), search terms, cookie information, as well as information about the timing, frequency and pattern of your Website use (“Service Data”).

For your use of the various functionalities available on the Website. 

The legal basis for this processing is our legitimate interests, namely monitoring and improving our Website.

Contact information such as name, e-mail address, mailing address, organization represented, website of the organization, IP address, geographic location, or phone number (“Contact Data”)

Processed for advertising and marketing purposes with your prior express consent. 

Processed for the purposes of communicating with you and record-keeping.

For example, we may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding iZooto, its Subsidiaries, information about promotions or events.

The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

 

2.2           Customers:

Information we Process

Purpose of processing 

Legal basis of processing 

Your account data, which may include your name, email address, location, time zone and website (“Customer Account Data)

The Customer Account Data Payment Information and Service Data is processed for the purposes of providing to you our Services and of ensuring their security, maintaining back-ups of our databases and communicating with you. 

This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested Services.

We process financial information such as credit card information when you order Services in order to facilitate the processing of payments (“Payment Information”). 

The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

Service Data as defined above 

The legal basis for this processing is the adequate performance of the contract between you and us, to enable us to comply with legal obligations and our legitimate interest in being able to provide and improve the functionalities of the Services.

Third Party platform (i.e. Facebook) related information through Customer’s Facebook page:

  1. Customer’s Facebook page data such as email, pages_manage_metadata, pages_read_engagement, pages_show_list, pages_messaging, pages_manage_ads, pages_read_user_content
  2. Customer’s end users’ data such as PSID, Facebook Page Id, Facebook Page Name, Facebook Page Access Token, Facebook Page Picture & User Id, name, first name, last name and profile pic by retrieving details from User Profile API.
  3. The stored PSID and Facebook Page Access Token are used to send messages to users using the Send API 

(collectively known as Third Party Platform related Customer Data)

To enable Customers to send notifications, receive subscriptions, push out campaigns to their End Users or subscribers & view statistics of those campaigns. 

To also enable Customers to push out personalized messages like welcome message to new subscribers and quick responses to those end users who have interacted with their Facebook page and have consented to receive more messages from such page. 

To provide a window to our Customers where they can compose a message and send out to their end users.

The legal basis for this processing is the adequate performance of the contract between Customer and us, to enable us to comply with legal obligations and our legitimate interest in being able to provide and improve the functionalities of the Services.

 

2.3           End Users:

Information we Process 

Purpose of processing 

Legal basis of processing 

Information collected from end users on behalf of Customers to send such end users Notifications on desktops or through mobile applications (“Notification Data”) or through Facebook messenger (Third Party Platform related Customer Data defined above in Section 2.2)

The Notification Data and Third Party Platform related Customer Data may be processed for the purposes of sending you the relevant notifications on behalf of the Customer who is using our Services. 

The legal basis for this processing is informed consent.

Service Data defined above 

If you are an End User, we may automatically process Service Data with respect to Customer’s website. The Customer Service Data is processed for the purpose of providing our Services. 

The legal basis for this processing is the adequate performance of the contract between Customer and ourselves. 

End User’s transactions and interactions with Customer’s website or mobile application or Facebook messenger application (Transaction Data) which includes IP address, user agent of the device.

The Transaction Data is processed for the purpose of providing our Services to Customer. 

The legal basis for this processing is the End User’s consent and the adequate performance of the contract between Customer and ourselves. 

 

*Important Note related to processing of information of End Users of our Customers: Any personal data received as part of the data defined above as Third Party Platform Related Customer Data or Service Data or Transaction Data is processed by us only where we have checked that these Customers either have your consent to or are otherwise legally permitted or required to disclose your personal information to us as per their contract with such Third Party Platforms. In such cases, we act as processor of such data on behalf of our Customers and we are governed by the terms of the data processing agreement we enter with them. 

 

3. Facebook API usage Disclosure

3.1 Our Facebook Messenger integration allows Customers to connect their Facebook page to iZooto Platform to receive subscriptions from Send to Messenger & Get Started buttons, push out campaigns to their end users view statistics of those campaigns. We also provide Customers to push out personalized messages like welcome message to new end users and quick responses to those end users who have interacted with their Facebook page.

3.2 Such integration allows iZooto to collect and process Third Party Platform related Customer Data as defined in Section 2 in detail (specifically Section 2.2 and 2.3) 

3.3 iZooto’s use of such Third Party Platform related Customer Data received through Facebook APIs will adhere to their documentation available at https://developers.facebook.com/terms#privacypolicy

 

4. Disclosure of Personal Data

4.1 We may disclose your personal data to any member of our group of companies (this means Datability Technologies Private Limited and our subsidiaries defined above insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 Financial transactions relating to the Services are handled by our payment services providers. We will share Payment Information with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

4.3 We may disclose End Users’ Service Data an Transaction Data to the applicable Customers to provide information and analytics about the use of their website and to improve the functionalities of the Services.

4.4 We may disclose other Service Data to a variety of third party service providers insofar as reasonably necessary to improve the functionalities of the Services. For example, we may disclose Service Data to obtain useful analytics, provide support to our Customers, determine location data and provide search engine functionality to our Customers.

4.5 We may share aggregated data (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information to Customers for their own business purposes, for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

4.6 In addition to the specific disclosures of personal data set out in this Section ‎3, we may disclose your personal data if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; or in order to protect your vital interests or the vital interests of another natural person; to protect the safety or integrity of the Services, or to explain why we have removed content or accounts from the Services; or to address fraud, security, or technical issues; or to protect our rights or property or the rights or property of those who use the Services.

4.7 We offer individuals the opportunity to choose (opt out) whether their personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. In order to opt out from disclosure of your personal information, please email us at support@izooto.com

 

5. Your Rights with Regard to Personal Data including Deletion of Personal Data or objections to use of Personal Data

5.1. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request for your personal data by sending an email to support@izooto.com.

5.2 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You can request correction or modification by emailing us at support@izooto.com.

5.3. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims. You can request the deletion of your account by emailing us at support@izooto.com.

5.4 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. In order to change your privacy settings, email us at support@izooto.com.

5.5 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

5.6 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

5.7 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

5.8 To the extent that the legal basis for our processing of your personal data is consent; or    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. You can get your account information by sending out an email to support@izooto.com

5.9 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. 

 

6. Deletion of Third Party Platform related Customer Data stored with us


6.1 You have the right to erasure of your Third Party related Customer Data if you withdraw consent to such consent-based processing. This can happen by you removing the access to your Third Party Platform (like Facebook) from our iZooto Platform. Once you remove the access, we will stop processing any such data to which you provided us access through consent. Additionally, you can also request us to delete such data in your account by emailing us at support@izooto.com .

6.2 As an end user of our Customer, you may require deletion of any of your Third Party Platform data stored with us because of the Customer’s integration with us since you have withdrawn consent to consent-based processing to the Customer. In this case, apart from the Customer, you can also reach out to us to request deletion of your personal data available with us at support@izooto.com

 

7. Retention of Personal Data

7.1 This Section ‎sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3 We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Services to you, you can request that we erase your personal information and close your account.

7.4 Notwithstanding the other provisions of this Section ‎6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

8. Children


Our Services are not intended for children. You must also be old enough to consent to the processing of your personal data in your country without parental consent. No one under age of 13 may provide any personal data through the Services. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information through the Services or on or through any of their features or register an account, make any purchases through the Services, use any of the interactive features of the Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@izooto.com. 

 

9. Cookies


9.1 About cookie

  1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed
  3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
  4. We also use other technologies with similar functionality to cookies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device.

9.2 We use these technologies for the following purposes:

  1.  to identify you and log you into the Services
  2. to store information about your preferences and to personalise the Services for you;
  3. as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
  4. to help us display content that will be relevant to you;
  5. to help us analyse the use and performance of the Services; and
  6. to store your preferences in relation to the use of cookies more general

9.3 Cookies used by our service provide

We use the following service providers to analyse the use of the Services. Each service provider gathers information about the Services by means of cookies and this information is used to create reports about with usage information. You can find information about the service providers’ privacy policies and practices at the URLs set forth below:

Service Provider - Analytics

Privacy Policy

Google Analytics

https://support.google.com/analytics/answer/6004245

Freshmarketer

https://www.freshworks.com/freshmarketer-privacy/

Drift

https://www.drift.com/privacy-policy/

Hubspot

https://legal.hubspot.com/privacy-policy

 

9.4 Managing cookies on browser and through devices 

  1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
  2. Your mobile device may allow you to control cookies through its settings function. Refer to your device manufacturer’s instructions for more information.
  3. If you choose to decline cookies, some parts of the Services may not work as intended or may not work at all.

10. Data Security

We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Steps taken to ensure data security:

(a)            All the user information can only be accessed by authorized users;

(b)           Users need to authenticate themselves with a username-password combination; and

(c)            All data is hosted on Microsoft Azure.

However, the transmission of information via public networks such as the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted through the Services. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Services.

 

11. Changes to Our Privacy Policy


It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users' personal data, we will notify you by e-mail to the primary e-mail address specified in your account. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this Policy to check for any changes.

 

12. OPTING OUT PROCEDURE


If you no longer wish to receive marketing communications from iZooto, you may click on the “unsubscribe” link located on the bottom of our marketing emails or you can contact us at support@izooto.com. If you would like to object to the use of your Personal Data for analytics, you can contact us at support@izooto.com.  

 

13. CONTACTING IZOOTO


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

a. Datability Technologies Private Limited 

Grievance Officer: Shrikant Kale at shrikant@datability.co 

Secondary Contact: support@izooto.com

Address: A-35, near Sector 15, A Block, Sector 2, Noida, Uttar Pradesh 201301

b. Datability Technologies Inc. 

Contact person: Neel Kothari at neel@datability.co

Secondary Contact: support@izooto.com 

Address: 2035, Sunset Lake Road Suite B-2, Newark, NJ 19702

 

 

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