Changes to our Privacy Policy

We may change this Policy from time to time. If we make any changes to this Policy, we will change the "last updated" date above. We encourage You to check this Policy whenever You use our sites and services to understand how Your personal information is used.

For the purpose of the Data Protection Act 1998 (the Act), the Data Controller for Zephyr's own information is Zephy Platform. The Data Processor for Zephyr Client's is Zephyr Platform.

Information we may collect from You

We may collect and process the following data about You:-

• We collect information from You when You complete forms on our website (https://zephyrplatform.com which can also be accessed using a custom domain name e.g. app.zephyrplatform.com) – "our sites" – including when registering to use our Sites or subscribing to our services or updating Your profile. Information You provide is stored in Zephyr databases. The information we may collect about You includes, Your name and email address; Your title, company and other profile information You provide as well as aggregate information about Your use of the features of the Services we provide to You such as the number of times You upload/download files and documents.

• Information that You provide to us by completing surveys on our site or as carried out by our approved third parties.

• If You contact us for customer or technical support, we may keep a record of that correspondence or conversation.

• Information we receive from third party search engines such as but not limited to Google, Yahoo and Microsoft (Bing and MSN) relating to Your search activity.

• Details of Your visits to our site including, but not limited to, traffic data, location data, IP addresses, weblogs and other communication data and the resources that You access.

On registration with Zephyr or when completing forms on our Sites, Zephyr does not require nor ask for sensitive personal data such as – Medical, race/ethnicity, political opinions or sexuality. Where You believe You have either submitted or been asked to provide this information as part of registration or completion of forms, You are to contact privacy@zephyrplatform.com to opt-out.

Uses made of the information

Zephyr may use the information You provide in the following ways:-

1. To provide our services and features to You, to measure and improve those services and features and to provide You with customer and technical support through Customer Relationship Management systems.

2. To contact You with any service-related announcements from time to time.

3. To ensure that content from our site is presented in the most effective manner for You and for Your computer.

4. To provide You with information concerning our products or services that You request from us or which we feel may interest You by email unless You have opted-out of receiving this information (see Marketing Communications and Opting out below).

5. To carry out our obligations arising from any contracts entered into between You and us.

You may at any time opt-out of receiving this information by clicking on the opt-out link in the footer of a marketing email You have received or by sending us an email at privacy@zephyrplatform.com. Opt out requests will not apply where Zephyr sends You a notice regarding the status of service, security alerts or any notice pertinent to Your service and account.

Information We collect may be stored and processed in and transferred between any Zephyr offices in order to enable us to use the information but strictly in accordance with this privacy policy.

Zephyr may use trusted 3rd parties ("Agents") to assist in the delivery, provision, analysis and improvement of the Services including but not limited to data storage, maintenance services, database management, analytics, payment processing, Customer Relationship Management services/systems and improvement to the Services features ("tasks"). These 3rd parties may have access to Your Information only for the purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy. All 3rd parties will be risk assessed by Zephyr prior to receiving any Information in order to ensure compliance and the protection of Your Information.

Cookies, IP addresses and Email Tool

We may collect information about Your computer, including where available Your IP address, operating system and browser type, for system administration and to report aggregate information. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Cookies

We use Cookies which are information packets sent by web servers to web browsers, and stored by the web browsers. The information is then sent back to the server each time the browser requests a page from the server. This enables a web server to identify and track web browsers. There are two main kinds of cookies: session cookies and persistent cookies. Session cookies are deleted from Your computer when You close Your browser, whereas persistent cookies remain stored on Your computer until deleted, or until they reach their expiry date. Cookies contain information that is transferred to Your computer's hard drive. We use Cookies to help us to improve our site and to deliver a better and more personalised service.

We use the following cookies within our Services:-

Refusing Cookies

You may refuse to accept our cookies by activating the setting on Your browser which allows You to refuse the setting of cookies. However, if You select this setting, this may adversely affect Your user experience of our site.

IP Addresses

Our Sites use Internet Protocol (IP) addresses. IP addresses are assigned to Your computer by Your Internet Service Provider (ISP) so You can access the internet. Typically the IP address assigned to You will change each time You connect to the internet providing You with a dynamic address. If You are accessing our Sites via broadband connection it is possible that the IP address we collect or even a cookie we might use, may contain information that could be deemed identifiable. This is because with some broadband connections the IP address does not change so is termed static which could be associated with Your personal computer. We use Your IP address to report aggregate information on use and to help improve our Sites.

Areas of our Sites that collect Your information use industry standard secure socket layer encryption (SSL); however, to take advantage of this Your browser must support encryption protection (found in internet explorer release 3.0 and above).

Email Tool

The Email Tool within Zephyr is built using Context.io technology. By signing up or using this tool, you understand and agree that DokDok, Inc., its parent company, Return Path, Inc. and their affiliates (collectively "Context.io Providers"), who provide Context.io, will have access to your information and will be permitted to use that information in accordance with Return Path's Privacy Policy - http://returnpath.com/data-privacy-policy/. If you wish to opt out of sharing your information with Context.io Providers, you may do so at https://optout.context.io/.

Marketing communications and opting-out

We will provide You with information concerning our products or services that You request from us or which we feel may interest You by email unless You have opted-out of receiving this information.

You may at anytime opt-out of receiving this information by clicking on the opt-out link in the footer of a marketing email You have received or by sending us an email at privacy@zephyrplatform.com.

How You can change or remove information

You understand that by accepting an invitation into Zephyr, those who are in an Environment with you, will be able to identify you by your Zephyr profile.

You may change or remove Your profile information displayed through our site at any time by going to Your profile and editing Your information. However, if You want to change the personal information we hold about You in our systems, You will need to email Your request to privacy@zephyrplatform.com.

If You want to stop using Your account You may request us to deactivate it by emailing deactivate@zephyrplatform.com. When You deactivate an account, You will not be able to use our Sites or services and Your information will not be capable of being viewed through our sites. However, even after You deactivate Your account, copies of Your information including but not limited to name and email address may be retained by us as backup copies for legal and compliance reasons.

Where we store Your personal data

The data that we collect from You may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of CRM services, marketing campaigns, and support services on our behalf. We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this privacy policy.

All information You provide to us is stored on secure servers operated by us or our third party providers. Where we have given You (or where You have chosen) a password which enables You to access certain parts of our site, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone.

Although we will do our best to protect Your personal data, we cannot guarantee the security of Your data transmitted to our site; any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.

Security of Your personal information

We will take all reasonable technical and organisational precautions to prevent loss or misuse of Your personal information. Your information is stored on password protected servers and transmission of data is encrypted. You acknowledge that the transmission of information over the internet is inherently insecure and we cannot guarantee the security of data that is sent over the internet. You are responsible for Your passwords to our Services.

Disclosure of Your information

We may disclose Your personal information to any of our employees, officers, agents within Zephyr which means our subsidiaries in so far as reasonably necessary for the purposes set out in this privacy policy.

We may disclose Your personal information to third parties:-

• In the event that we sell or buy any business or assets, in which case we may disclose Your personal data to the prospective seller or buyer of such business or assets.

• If we or substantially all of our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets.

• If we are under a duty to disclose or share Your personal data in order to comply with any legal obligation, or in order to enforce or apply our Subscriber Agreement or Terms of Use.

• In connection with any on-going or prospective legal proceedings.

• In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

Contact Us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Chief Information Security Officer by emailing privacy@zephyrplatform.com.