Privacy Policy

1. PREAMBLE AND SCOPE

Zoolatech Group (“Zoolatech,” “we,” “us,” or “our“) comprises a global network of affiliated companies committed to the highest standards of data privacy and security. This Privacy Policy (“Policy“) outlines how we collect, use, disclose, and safeguard the Personal Data of our website visitors, business partners, prospective clients, and vendor representatives (collectively, “you“).

This Policy applies to all internet properties, microsites, mobile applications, and digital services operated by the Zoolatech Group (the “Sites“) and to our offline business interactions.

Note on Recruitment: If you are applying for a job with Zoolatech, specific processing regarding your candidacy is governed by our Candidate Privacy Notice, though this Policy remains relevant regarding your use of our Sites.

2. IDENTITY OF THE CONTROLLER

For the purposes of applicable data protection laws, the Zoolatech Group entity responsible for your

Personal Data (the “Controller”) depends on your relationship with us:

• Website Visitors: The Zoolatech Group entity identified in the website footer or “Contact Us”
  section.
• Business Clients/Vendors: The specific Zoolatech Group entity with whom you or your employer have entered into a contract or commercial negotiation.

In instances where multiple Zoolatech entities jointly determine the purposes and means of processing (e.g., global marketing campaigns or shared CRM systems), these entities act as Joint Controllers. You may contact our Data Protection Office for details on specific controller arrangements.

3. PERSONAL DATA WE COLLECT

We collect data directly from you, automatically through your device, and from third-party sources.

A. Information You Provide Voluntarily

• Identity Data: First name, last name, username, or similar identifier.
• Contact Data: Billing address, delivery address, email address, and telephone numbers.
• Professional Data: Job title, department, employer name, industry, and professional background.
• Communication Data: Content of inquiries submitted via contact forms, emails, or during events/conferences.
• Marketing & Communications Data: Your preferences in receiving marketing from us and your communication preferences.
• Image & Audio Data: Photographs, video, or audio recordings taken at Zoolatech-hosted events,
  conferences, or webinars.

B. Information Collected Automatically

When you interact with our Sites, we automatically collect Technical and Usage Data via cookies, server logs, and similar technologies (pixels, tags, SDKs):

• Device Information: IP address, time zone setting, operating system, platform, browser type and version, and browser plug-in types.
• Usage Information: Full Uniform Resource Locators (URL) clickstream to, through, and from our Sites (including date and time); products/services viewed or searched for; page response times; download errors; length of visits to certain pages; and page interaction information (scrolling, clicks, mouse-overs).

C. Information from Third Parties

We may receive Personal Data about you from:

• Public Sources: LinkedIn, corporate registries, and public websites.
• B2B Data Partners: Lead generation vendors and business intelligence providers who provide contact details for prospective clients.
• Service Providers: Background check providers (where legally permissible and necessary for vendor screening) and event organizers where Zoolatech is a sponsor.

4. PURPOSES AND LEGAL BASES FOR PROCESSING

We process your data only where we have a lawful basis. The following matrix outlines our processing activities:

5. DISCLOSURE OF PERSONAL DATA

We do not sell your Personal Data for monetary consideration. We share your data strictly with the following categories of recipients:

1. Zoolatech Group Entities: For intra-group administration, global reporting, and shared service centers (e.g., centralized IT or Marketing).
2. Service Providers: Third-party vendors acting as processors who provide:

• IT and system administration services (e.g., cloud hosting, CRM platforms).
• Professional advice (lawyers, bankers, auditors, insurers).
• Marketing and analytics services (e.g., Google Analytics, advertising networks).

3. Business Partners: In the context of joint ventures or events where you have agreed to share data with sponsors.

4. Legal Authorities: Regulators, law enforcement, or other authorities if required by law or to protect our rights (e.g., fraud prevention).

5. Corporate Transactions: To third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

6. INTERNATIONAL DATA TRANSFERS

Zoolatech operates globally. Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.

Transfer Mechanisms:
Where we transfer Personal Data originating from the European Economic Area (EEA), UK, or Switzerland to countries not deemed to provide an “adequate” level of protection by the European Commission, we implement appropriate safeguards, including:

• Standard Contractual Clauses (SCCs): We utilize the EU Commission-approved SCCs (and the UK International Data Transfer Addendum) for transfers to third countries.
• Intra-Group Agreements: Strict internal data transfer agreements binding all Group entities to protect your data.

7. DATA SECURITY AND RETENTION

Security: We utilize enterprise-grade security measures (technical, administrative, and physical) designed to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorized way. Access to your Personal Data is limited to those employees, agents, contractors, and other third parties who have a business need to know.

Retention: We retain your Personal Data only for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. In general:

• Client/Vendor Data: Retained for the duration of the relationship plus the applicable statute of limitations (typically 3-10 years depending on jurisdiction).
• Marketing Data: Retained until you opt-out or withdraw consent, or after a defined period of inactivity.

8. YOUR GLOBAL PRIVACY RIGHTS

Depending on your location, you may have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate data.
• Erasure: Request deletion of your data (“Right to be Forgotten”).
• Restriction: Request suspension of processing.
• Portability: Request transfer of your data to you or a third party.
• Objection: Object to processing where we rely on a legitimate interest or for direct marketing.

To exercise these rights: Contact our Data Protection Officer at [email protected]. We may request specific information to confirm your identity before processing your request.

JURISDICTION-SPECIFIC PROVISIONS

A. EUROPEAN ECONOMIC AREA (EEA), UK, AND SWITZERLAND

Applicability: This section applies if you are located in the EEA, UK, or Switzerland.

• Supervisory Authority: You have the right to lodge a complaint with your local data protection authority (e.g., the ICO in the UK, the UDO in Poland). We seek the opportunity to resolve your concerns first.
• Marketing: We will generally rely on Consent for B2C email marketing and Legitimate Interest for B2B communications, subject to your right to opt-out at any time.

B. UNITED STATES (CALIFORNIA RESIDENTS)

Applicability: This section applies to residents of California under the CCPA, as amended by the CPRA.

1. Categories Collected: In the preceding 12 months, we have collected: Identifiers, Commercial Information, Internet/Network Activity, Professional/Employment-related Information, and Inferences.

2. “Sale” and “Sharing” of Data: Zoolatech does not sell personal information for monetary value. However, we may “share” personal information (identifiers, technical data) with third-party advertising networks (e.g., LinkedIn, Google) for Cross-Context Behavioral Advertising.

3. Your California Rights:

• Right to Opt-Out of Sharing: You may opt-out of the sharing of your data for cross-context behavioral advertising by contacting us or managing your cookie preferences.
• Right to Limit Use of Sensitive Info: We do not use Sensitive Personal Information for purposes other than those strictly necessary to provide our services.
• Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

C. ARGENTINA

Applicability: This section applies to residents of Argentina under Law No. 25,326.

• Data Accuracy: You have the right to update or rectify your data.
• Access: You may request access to your data at intervals of not less than six months, unless a legitimate interest is proven (Art. 14, subsection 3 of Law No. 25,326).
• Regulatory Body: The Agency of Access to Public Information (AAAPI) is the controlling authority with whom you may file complaints.

D. MEXICO

Applicability: This section applies to residents of Mexico under the LFPDPPP.

• ARCO Rights: You have the right to Access, Rectify, Cancel (delete), and Oppose the processing of your data.
• Consent for Transfers: By accepting this Policy, you consent to the transfer of your data to Zoolatech Group entities and third parties as described in Section 5, which are necessary for the maintenance of the legal relationship.
• Secondary Purposes: You may deny consent for the processing of data for secondary purposes (e.g., marketing) by contacting [email protected] without affecting our service delivery.

E. UKRAINE

Applicability: This section applies to processing activities conducted by Zoolatech entities established in Ukraine or regarding data subjects in Ukraine.

• Legal Rights: You possess all rights stipulated in Article 8 of the Law of Ukraine “On Personal Data Protection,” including the right to know the sources of collection, the location of data storage, and to receive a response regarding whether your data is being processed within 30 days of a request.
• Ombudsman: The supervisory authority is the Ukrainian Parliament Commissioner for Human Rights.

9. CONTACT US

For any questions regarding this Policy, or to exercise your rights, please contact the Zoolatech Group Data Protection Team:

Email: [email protected]

List of Main Operating Entities (Zoolatech Group):

• USA:
  Zoolatech Inc.,
  Zoolatech LLC
• Ukraine: Zoola Tech Ukraine LLC
• Mexico: Zoolatech Mexico, S. de R.L. de C.V.
• Poland: Zoola Tech Poland Sp. z o.o.