(ii) User Data: personal data concerning our Customers’ internal focal persons who directly engage with PlanZero concerning their organizational account, and users of the Platform on behalf of such Customers, e.g., the account administrators and users, billing contacts and authorized signatories on behalf of the Customer (collectively, “Users”); as well as the Customer’s business needs and preferences, as identified to us or recognized through our engagement with them;
1. Data Collection & Processing
Personal data contained in Customer Data which is provided by our Customers or processed on their behalf and under their instruction, which may also include any of the types of personal data described above (with respect to Users or other individuals whose data is contained in the Customer Data), in accordance with our Data Processing Addendum with them.
2. Data Uses
We use personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Customers, Users, Prospects, ourselves and our Services (“Legitimate Interests”).
Specifically, we use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
Customer and User personal data
Customer, User and Prospect personal data
3. Data Location
4. Data Retention
We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements. If you have any questions about our data retention policy, please contact us by e-mail at [email protected].
5. Data Disclosure
We disclose personal data in the following ways:
Service Providers: We may engage selected third party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal information, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
Service Integrations: You may choose to use a third-party service to integrate with our Services, for example in order to upload or retrieve personal data to or from the Services, or to enrich the data you have processed on either service or enhance your usage thereof (provided that such integration is supported by our Services). The provider of this integrated third-party service may receive certain relevant data about or from your account on the Services, or share certain relevant data from your account on the third-party provider’s service with our Services, depending on the nature and purpose of such integration. This could include your Customer Data and/or User Data. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key in order to integrate with them).
Event Sponsors: If you attend an event or webinar organized by us, or download or access an asset on our Sites related to such an event, webinar or other activity involving third party sponsors or presenters, we may share your personal data with them. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your personal data will be subject to the sponsors’ privacy statements. If you do not wish for your personal data to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with Section 9 below;
Business Customers: Our Customers have access to any personal data we process on their behalf in our capacity as a “processor” or a “service provider.”
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of PlanZero, any of our Users or Customers, or any members of the general public.
For the avoidance of doubt, PlanZero may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
6. Cookies and Data Collection Technologies
Further information about the privacy practices of our analytics service providers is available at: www.google.com/policies/privacy/partners/; https://mixpanel.com/terms/ and https://mouseflow.com/terms/. Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout; https://mixpanel.com/optout; and https://mouseflow.com/opt-out/. Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking. For more information on our cookie and data collection technologies practices, you may also use the “Cookie settings” feature available in our Services depending on your location and activity on our Services, as applicable.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications. Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. If you are registered as a User to our Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices). Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify PlanZero at any time by sending an e-mail to: [email protected], changing your communications preferences in your profile settings whilst being logged as a User to our Services, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
8. Data Security
We implement systems, applications and procedures designed to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Sites or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. To learn more, please visit www.planzero.io/security.
9. Data Subject Rights
Individuals have rights concerning their personal data. Please contact us by e-mail at: [email protected] if you wish to exercise your privacy rights under any applicable law, such as – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with PlanZero, or to restrict or object to such personal data’s processing (including the right direct us not to sell your personal data to third parties now or in the future), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you).
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request). We may redact from the data which we will make available to you, any personal data related to others.
10. Data Controller/Processor
11. Additional Notices & Contact Details
California Requirements: This policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), the and our retention (Section 4) and deletion (Section 9) practices. We also included information about how we may process your information (in Sections 2 through 7), which includes for “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intents and purposes of CCPA. We may disclose personal data with third parties or allow them to collect personal data from our Services as described in Section 5 above, if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Services, or direct us to disclose your personal data to third parties. If you have any questions or would like to exercise your rights under the CCPA, you can contact [email protected]
Children: Our Services are not designed to attract children under the age of 16. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at [email protected].
Last updated: November 4, 2021.