Last updated: February 07, 2022
1. What information we collect, why we collect it, and how it is used
(i) We Process the Following Personal Information:
a. Information You Provide Directly to Us. We collect the following information you provide directly to us, including, without limitation, information when you browse, download, and make use of our Services: full name, email address, phone number, home address, passport number, past insurance claim information, , as well as any other information that you decide to provide/supply us with when you communicate with Zenner (via email, website or telephone).
b. Information from Other Sources. Zenner may also obtain information about you from other sources, including publicly - or commercially- available information, and through third-party data platforms, partners and service providers.
c. Automatic Data Collection. We may automatically collect certain information through your use of the Zenner Services, such as your Internet protocol (IP) address, cookie identifiers and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of the Zenner Services.
(ii) We process information for the following purposes:
a. To provide you with the Zenner Services. Zenner will use your information to provide the Zenner Services. For example, if you request insurance coverage, we will use the information to: (i) process your request; (ii) communicate with you about the options that you may have for the requested insurance; (iii) fulfill any orders for services or products made by you; (iv) track transactions conducted by you; (v) send you more information about our products, services and offerings; and (vi) to personalize your experience with the Zenner Services. We may also use your information to contact you about incomplete applications or other forms and submissions available through the Services.
b. For Administrative Purposes. Zenner may use your information (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future services; (ii) to provide you with the Zenner Services; (iii) for internal quality control purposes; (iv) to establish a business relationship; and (v) to generally administer the Zenner Services.
c. To Market the Zenner Services. Zenner may use information to market the Zenner Services. Such use includes (i) notifying you about offers and services that may be of interest to you; (ii) tailoring content, advertisements, and offers for you, including, targeting and re-targeting practices; (iii) conducting market research; (iv) developing and marketing new products and services, and to measure interest in Zenner’s services; (v) other purposes disclosed at the time you provide information; and (vi) as you otherwise consent.
d. Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.
e. De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Information and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. We may use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
2. How we protect and retain your information
2.1. Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
2.2. Retention of your information. Your information will be stored until we delete our records, and we proactively delete it, or if you send a valid deletion request. Please note that in some circumstances we may store your information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your information or dealings.
3. How we share your information
In addition to the recipients described above, we may share your information as follows:
3.2. In order to provide you with our services, and only where permitted by law, we may share information you submitted with: (1) our partners who may share with certified credit bureaus to verify information about your credit report; and (2) government agencies to verify your previous claims history and other relevant information. Your information is maintained by credit agencies and disclosed by them to others as permitted by law.
3.3. We may also share information with our affiliated companies about you.
3.4. We may use third party service providers to process your information for the purposes outlined above, including, without limitation:
3.4.1. With cloud service providers for hosting purposes;
3.4.2. With websites and web content creation platforms in order to help us manage our Website;
3.4.3. With email providers, marketing, CRM, other similar tool providers and/or sales dialer software;
3.4.4. With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy;
3.4.5. With insurance carriers integration platforms, comparative raters;
3.4.6. With government agencies, such as departments of insurance, where required by law;
3.4.7. With billing companies; and/or
3.4.8. With data validation and enrichment companies.
3.5. To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Zenner, our Services, customers, employees, property, and the public.
3.6. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.
3.7. Where you have otherwise provided your consent to us for sharing or transferring your information.
4. Your privacy rights
4.1. Rights: You can exercise your rights by contacting us at [email protected] Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we need further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
4.2. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to [email protected] Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.
5. Use by children
We do not offer our products or services for use by children and, therefore, we do not knowingly collect information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provide information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].
6. Interaction with third party products
We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
7. Analytics tools/cookies
• Through our Services we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you.
• We also use some targeting and retargeting tools, including, Google, Twitter, LinkedIn, Taboola, Criteo, AppsFlyer and Reddit.
• We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.
8. Specific provisions applicable under California privacy law
8.1. California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.
8.2. Our California Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
9. Contact us
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].