625 Massachusetts Ave, 2nd Floor
Cambridge, MA 02139, United States
Phone: +1 (617) 855-5944
CEO: Florian Wegener
Registered in Delaware under file number 5716779
About Privacy at ZAGENO
Our company’s first and most important value is that we put our customers and their needs at the center of everything we do, which means that we are committed to protecting your privacy and giving you an outstanding experience across our platform. This policy will help you understand how we use and protect your data. If you have any questions, feel free to contact us at firstname.lastname@example.org.
- We never share your Private Personal Information with other users without your explicit permission.
- We never sell your information to any third parties.
- We keep a copy of your Personal Information on our servers, which are protected by industry-standard security practices (e.g., disk and network encryption, hashed values), to better enhance the experience of all of our users.
1. Questions; Contacting Company; Reporting Violations
- ZAGENO Inc.
- Attn: David Pumberger
- 625 Massachusetts Ave,
- MA 02139,
- United States
Data Protection Officer
- For the UK: Information Commissioner’s Office
- For Germany: Berliner Beauftragte für Datenschutz und Informationsfreiheit
2. User Consent
3. Types of Data Collection
“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
- We may collect Personal Data from you, such as your first and last name, gender, email and mailing addresses, professional title, company name, and password when you create an account to log in to our network (“Account”)
- If you use our Services on your mobile device, including through our Application(s), we may collect your phone number and the unique device id number.
- If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can either reinstall the Application(s) or deactivate GPS on your mobile device.
- Our mobile homepage lets you store preferences like your location, safe search settings, and favorite widgets. We may associate these choices with your ID or the mobile device, and you can edit these preferences at any time on our mobile homepage.
- When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
- Certain Services may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
- When you order products or services on our Site, we will collect all the information necessary to complete the transaction, including your name, credit card information, billing information, and shipping information. This information may be shared with third parties who help process and fulfill your purchases. When you submit credit card numbers, we encrypt that information using industry-standard technology.
- We retain information on your behalf, such as files and messages that you store using your Account.
- If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
- When you post content (text, images, photographs, messages, comments, or any other kind of content that is not your email address) on our Site, the information contained in your posting will be stored in our servers and other users will be able to see it, along with your profile photo and any other information that you choose to make public on your public profile page (“Profile”). The information that you provide in your Profile will be visible to others, including anonymous visitors to the Site
- When you post messages on the message boards of our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.
- When you participate in one of our surveys, we may collect additional profile information.
- We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via email regarding support for the Services.
- If you participate in a sweepstakes, contest or giveaway on our Site, we may ask you for your email address and/or home number (to notify you if you win or not). We may also ask for first and last names, and sometimes post office addresses to verify your identity. In some situations we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.
- We may also collect Personal Data in other areas of our Site, and in these areas, it will specifically state that Personal Data is being collected.
- Information Collected by Our Servers: To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- first-party cookies, served directly by us to your computer or mobile device; and
- third-party cookies, which are served by our partners or service providers on our Site.
Our Site uses the following types of cookies for the purposes set out below:
- Essential Cookies: These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. (For example, they allow you to log in to secure areas of our Site, remembering your login details, remembering the changes you make to other parts of our Site which you can customize, help the content of the pages you request to load quickly, etc.) Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
- Analytics and Performance Cookies: hese cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. (It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information.) We use this information to help operate our Site more efficiently, to gather broad demographic information, and to monitor the level of activity on our Site. Additionally, we use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: https://policies.google.com/privacy?hl=en.
- Targeted and advertising cookies: These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third-party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.
- Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Instagram. The social network will record that you have done this.
- Pixel Tags: In addition, we use “Pixel Tags” (also referred to as clear gifs, web beacons, or web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track the online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send email messages in a format users can read, and they tell us whether emails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data
- How We Respond to Do Not Track Signals: We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Site.
- Mobile Services: We may also collect non-personal information from your mobile device if you have downloaded our Application(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Application(s), and information about the type of device you use. In addition, in the event our Application(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
- If you decide to invite a third-party to create an Account, we will collect your and the third-party’s names and email addresses in order to send an email and follow up with the third-party. We rely upon you to obtain whatever consent from the third-party that may be required by law to allow us to access and upload the third-party’s names and email addresses as required above. You or the third-party may contact us at email@example.com to request the removal of this information from our database.
- We allow you to use your Google ID to set up an Account. If you wish to use your Google account, you are taken to the Google website to login to your account and this information is then shared with us for the sole purpose of setting up your Account.
- We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site. These third-party companies may supply us with Personal Data. We may add this information to the information we have already collected from you via our Site in order to improve the Services we provide.
These third-party sources are shown in the table below, together with a description of whether they are publicly available or not.
|Third-Party Data Source||Publicly Available?||Category(ies) or Other Types of Personal Data Received|
|Credit Reference Agencies||No|
|Social Media Sites||Yes|
- We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses
Our Site uses the following types of cookies for the purposes set out below:
- Identity Data: First name, last name, username, title, employer, professional role.
- Contact Data: Billing address, shipping address, work address, email address, and telephone numbers.
- Financial Data: Organization tax number, bank account, and payment details.
- Transaction Data: Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third-parties.
- Marketing and Communications Data: Your preferences in receiving marketing from us and our third-parties and your communication preferences.
- Behavioral Data: Inferred or assumed information relating to your behavior and interests, based on your online activity. This is most often collated and grouped into “segments” (e.g., there may be a segment for scientists, living in London and aged under 25, who are interested in Genomics).
- Technical Data: Internet protocol (IP) address, location, your login data, browser type and version, operating system and platform, and other technology on the devices you use to access this website or use our services.
4. Use of Personal Data
4.1 General Use
In general, Personal Data you submit to ZAGENO is used either to respond to requests that you make, or to aid us in serving you better. We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
- identify you as a user in our system;
- provide improved administration of our Site and Services;
- provide the Services you request;
- improve the quality of experience when you interact with our Site and Services;
- send you a welcome email to verify ownership of the email address provided when your Account was created;
- send you administrative email notifications, such as security, or support and maintenance advisories;
- respond to your inquiries related to employment opportunities or other requests;
- make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback; and
- send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Company.
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you ("Contractual Necessity”).
- Where it is necessary for our legitimate interests, and your interests and fundamental rights do not override those interests (“ Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally, we do not rely on your Consent as a legal basis for using your Personal Data.
All the legal bases that we rely on in respect of the relevant Purposes for which we use your Personal Data, are outlined in the table below.
|Purpose||Category(ies) of Personal Data Involved||Why We Do This||Our Legal Basis for This Use of Data|
|Account Creation||To register you as a new customer.||Contractual Necessity|
|Payment processing for subscriptions to the Sites (and their associated services and functionalities)||To process and deliver your order, including managing payments, fees, and charges.||Contractual Necessity.|
|Fraud Prevention||To keep our website, our services, and associated systems operational and secure.||We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website, and associated IT services and networks.|
|Troubleshooting||Technical Data||To track issues that might be occurring on our systems.||It is in our legitimate interests that we monitor and ensure the proper operation of our Sites and associated systems and services.|
|Marketing||To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.||We will only provide you with updates on our Sites and services as well as offers related to your purchase history after obtaining your consent to do so.|
4.2 User Testimonials and Feedback
We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with our Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.
4.3. Creation of Anonymous Data
We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.
5. Disclosure of Personal Data
Your Personal Data may be shared within the ZAGENO Group. This may involve transferring your data outside the United States ("US") or outside the European Economic Area (“Europe”).
Many of our external third-parties are based outside of the United States ("US") and/or outside of the European Economic Area (“Europe”), so their processing of your Personal Data will involve a transfer of data to countries based outside of these regions.
We endeavor to ensure that the people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data outside of Europe or the US, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
- Where we use service providers outside of Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
All the Personal Data we disclose, as well as whom we share it with and for what purposes, are outlined in the table below.
|Recipients||Category(ies) of Personal Data We Share||Why We Share It||Location(s)|
|Our Affiliates||Our affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison, etc).|
|Service Providers||Our service providers provide us with IT and system administration services.|
|Professional Advisers||Our lawyers, bankers, auditors, and insurers provide consultancy, banking, legal, insurance, and accounting services.|
|Tax authorities, regulators, and other authorities||Authorities may require reporting of processing activities in certain circumstances.|
5.1 Third Parties Designated by You
When you use the Services, the Personal Data you provide will be shared with third parties that you designate to receive such information, including other websites, your friends, relatives and business associates. Depending on the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information. You may change your settings at any time as to who has access to your information by going to your account settings and changing your publishing options.
5.2 Third Party Service Providers
We may share your Personal Data with third party service providers to: fulfill orders you place through the Services; provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate the creation of accounts; to provide technical support; and/or to provide other services to the Company. These third party service providers are required not to use your Personal Data other than to provide the services requested by Company.
5.4 Corporate Restructuring
5.5 Disclosure to Third Party Companies
We may enter into agreements with companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website (“Third Party Companies”). A Third Party Company may want access to Personal Data that we collect from its customers. As a result, we may disclose your Personal Data to a Third Party Company; however, we will not disclose your Personal Data to any Third Party Company for the Third Party Company’s own direct marketing purposes, unless you have “opted-in” by following the instructions we provide to allow such disclosure. If you have opted-in to receive email communications from a Third Party Company and later wish to discontinue receipt of these emails, please contact the Third Party Company directly to update your preferences. The privacy policies of these Third Party Companies may apply to the use and disclosure of your Personal Data that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of our Third Party Companies, you should read and understand their privacy policies.
5.6 Public Profile
Certain portions of the information you provide to us may also be displayed in your Profile. As an essential element of the Services, most of the Personal Data you explicitly provide to us when you register or update your Profile is displayed on your Profile. In order for your Profile to be made public, you must go to your Profile Settings and then to Profile Visibility. By default, your Profile is not for public viewing. Your photos, posts, friends, and other content you post to the Site are also meant for public consumption. We may display this content on the Site, and further distribute it to a wider audience through third party sites and services. Once displayed on publicly viewable web pages, that information can be collected and used by others. We cannot control who reads your posting or what other users may do with the information that you voluntarily post, so it is very important that you do not put Personal Data in your posts. Once you have posted information publicly, while you will still be able to edit and delete it on the Site, you will not be able to edit or delete such information cached, collected, and stored elsewhere by others (e.g., search engines).
5.7 Other Disclosures
Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary:
- in connection with any legal investigation;
- to comply with relevant laws or to respond to subpoenas or warrants served on Company;
- to protect or defend the rights or property of Company or users of the Site or Services;
- to third party suppliers of products.
6. Your Choices Regarding Your Information
You have several choices regarding the use of information on our Services:
- Cookies: If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can typically remove or
reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help”, “tools”, or
“edit” facility) to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Many browsers are set to accept cookies until you change
your settings. Please consult your browser’s technical information.
If you do not accept cookies, you may experience some inconvenience in your use of portions and/or all of the Site and Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.
If you have any questions about how to disable or modify cookies, please let us know at the contact information provided above.
You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
- Changing or Deleting Your Personal Data: All Users may review, update, correct, or delete the Personal Information in their User account (including any imported contacts) by contacting us or by editing their profile via the Service. If you completely delete all of your Personal Information, then your User account may become deactivated. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes. (For more information on how to control your User Content on the Service, including information regarding the use and storage of your User Content, please see the “Sharing Your Content” section in our Terms of Service.)
- Applications: You can stop all collection of information by the Application(s) by uninstalling the Application(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. To serve ads in our Application(s) where Cookie technology is not available, the Company hashes users’ device ID. Users may choose to reset or opt out of anonymous IDs at any time. If users choose to opt out, ads delivered to the Application(s) by ad serving technology will not be served on an anonymous ID. You may at any time opt-out from further allowing us to have access to your location data by managing your location preferences either from the Application or device level.
- Failure to Provide Personal Data: Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site). In this case, we may prevent you from using our Site, but we will notify you if this is the case at the time.
7. Personal Data Rights
- By law you have the right to:
- Request access to your Personal Data:This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you.This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data.This enables you to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data.This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal DataThis enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data.We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent.This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
- Exercising Personal Data Rights:
If you want to exercise any of the rights described above, please contact us using the contact details above.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made multiple requests. In this case, we will notify you and keep you updated.
8. Security of Personal Data
Our Company is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while our Company uses reasonable efforts to protect your Personal Data, our Company cannot guarantee its absolute security.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
9. Storage of Personal Data
We will only retain your Personal Data for as long as we reasonably need to use it for the purposes set out above, unless a longer retention period is required by law (for example, for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention Period|
|Behavioral Data||For as long as you remain a customer of Zageno.|
|Financial Data||For 7 years, unless a longer period is required by law.|
|Identity Data||For as long as you remain a customer of Zageno.|
|Transaction Data||For 7 years, unless a longer period is required by law.|
|Technical Data||For as long as you remain a customer of Zageno.|
|Marketing and Communications Data||For as long as you remain a customer of Zageno.|
|Contact Data||For as long as retention is necessary to fulfill the Purposes/Use for which it is used.|
10. Policy on Minors
This Site is not intended for use by minors below the age of 16, and we do not knowingly collect data relating to such minors.
11. Third-Party Websites
12. Marketing Communications Preferences
You can ask us to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences AND/OR by following the opt-out links on any marketing message sent to you AND/OR by contacting us at any time using the contact details shown above.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails for order processing, such as order confirmation or account statement emails.