Zenus Privacy Policy
Effective Date: October 6, 2022
This Privacy Policy covers the practices of Zenus, Inc. (“Zenus,” “we,” “us,” or “our”) concerning personal information that we obtain about personnel of our past, present and prospective customers, business partners, and suppliers, subject to the important exception described below:
A special note about data processed by our products and services:
Zenus provides a facial analysis solution that allows Zenus’ customers and resellers to generate aggregate insights on people attending their events and visiting their premises. Once set-up, the Zenus IoT device observes and passively analyzes faces on the device to generate aggregated statistics on impressions, dwell time, age, biological sex, and positive sentiment, among other metrics, which Zenus uses solely to serve the particular customer or reseller that deployed the service. Further aggregations of this aggregate data may also be used to establish industry benchmarks. The Zenus IoT device does not receive, generate, or use unique biometric identifiers. It does not transmit any video, photos, individual-level data or personal information of any kind to Zenus, its service providers, or its customers. Instead, the Zenus IoT device performs all analysis on the device itself at the customer’s location, transmitting only the aggregate results of the analysis. Optionally, while first setting up the Zenus IoT device, the customer or reseller can choose to transmit a temporary video feed or snapshots to Zenus support technicians, which Zenus uses solely to advise that customer or reseller on optimal positioning and configuration of the device.
Zenus also provides a separate, unrelated QR code service for attendee tracking at events. In this service, the customer or reseller can include a unique QR code on each event attendee’s badge. When the Zenus IoT device scans a QR code at the event, Zenus will receive a record that the QR code was scanned by a particular scanning device at a particular date and time. Zenus then makes that data available to the customer or reseller. Zenus has no ability to link the QR code with a particular individual’s real identity, as Zenus does not accept any other information about the individual. Only the customer or reseller holds data that allows them to make that linkage. Zenus uses the QR code data solely to serve that particular customer or reseller as the customer’s or reseller’s “service provider” within the meaning of the California Consumer Privacy Act (“CCPA”) and “processor” within the meaning of the General Data Protection Regulation (“GDPR”) and similar laws.
Zenus also handles all of the customer/reseller information described above solely pursuant to our contract with that particular customer or reseller and not pursuant to Zenus’ own Privacy Policy. Thus, for example, the references in this Privacy Policy to performing our own analytics on the data we collect do not apply to that data. Any inquiries or requests relating to such data should be directed to the relevant customer or reseller, not to Zenus.
This Privacy Policy contains the following sections:
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Information We Collect
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Use of Information
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Sharing of Information
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International Data Transfers
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Legal Basis for Processing Information
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Your Rights and Choices
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Updates and Changes to This Policy
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Protection of Information
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Retention of Information
10. Contact Information
1. Information We Collect
a. Information You Provide to Us
You may provide the following types of information to us:
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Contact details, such as name, email address, phone number, employer, job title and address;
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Username and password for our websites;
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Information about your purchases and other business interactions with us;
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Information about your interests and preferences;
b. Cookies and Other Information Collection Technology:
Through our online properties, we and third parties may collect information from your computer or other device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality and other computer code. This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as advertising identifiers), other device information, Internet connection information, as well as details about your interactions with the relevant website, email or other online property (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in a website). In some cases (such as cookies), the tools described here involve storing unique identifiers or other information on your device for later use.
These technologies help:
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Display personalized content;
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Remember your settings on the pages you visit so that we can display your preferred content the next time you visit;
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Perform analytics, measure traffic and usage trends, and better understand the demographics of users;
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Diagnose and fix technology problems;
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Plan for and enhance our business; and
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Facilitate the other uses and disclosures described in this Privacy Policy.
To adjust your cookie consent settings, please click on the Cookie Settings link in our website footer and follow the instructions there. You will need to do this from each browser that you use to access our website.
You may be able to set your browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies. However, if you block or otherwise reject cookies, local storage, JavaScript or other technologies, certain websites (including some of our own websites) may not function as expected.
If you replace, change, upgrade or reset your browser or device, or delete your cookies, you may need to use these opt-out tools again. We do not respond to browser-based do-not-track signals.
c. Information From Third Parties
We may also receive personal information from third parties, including our service providers, affiliates, and partners such as resellers, systems integrators, technology vendors, and business information vendors, as well as from publicly available sources such as LinkedIn and company websites.
2. Use of Information
We and our service providers use the information described above for the following purposes:
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Administer your account, including to process your registration and verify your information;
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Provide, manage, and improve our services;
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Conduct business operations in support of our services, such as auditing, security, fraud prevention, invoicing and accounting, sales and marketing, analytics, and research and development;
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Contact you regarding Zenus and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you;
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Customize content, preferences, and advertising on our website, across the Internet and elsewhere;
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Create aggregated or de-identified information;
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Comply with laws, regulations, and other legal process and procedures; and
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Establish, exercise, or defend our legal rights.
3. Sharing of Information
We may share your information as follows:
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With Service Providers: We may share your information with companies that provide services to us, such as providers of data storage, marketing, web hosting, security, analytics, and fraud prevention.
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With Affiliates: We may share information with other members of our corporate family for the purposes described in this Privacy Policy.
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With Business Partners: We may share information with business partners, such as resellers and distributors.
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Legal: We may share information when we believe disclosure is appropriate due to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; or as otherwise required by law.
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Protection of Zenus and Others: We may share information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our employees, our customers, or others; and to enforce our contracts.
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Corporate Transactions: We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.
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Your Consent: If you have consented to additional sharing of your information, we may also share your information consistent with your consent.
4. International Data Transfers
We are headquartered in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as the laws of your country where you live. However, this Privacy Policy applies to Zenus’s operations worldwide.
5. Legal Basis for Processing Information
The General Data Protection Regulation (“GDPR”) and similar laws require data controllers to explain the legal bases that justify their processing of your personal information. To the extent such rules apply, our legal bases are:
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In many cases, our processing your personal information is necessary for our legitimate interests or the legitimate interests of others. For example, we may process your personal information on this legal basis to:
○ Manage and improve our services;
○ Conduct business operations in support of our services, such as auditing, security, fraud prevention, invoicing and accounting, certain sales and marketing activities, certain analytics activities, and research and development;
○ Contact you through certain channels regarding Zenus and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you;
○ Create aggregated or de-identified information; or
○ Establish, exercise, or defend our legal rights.
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In some cases, processing your personal information is necessary for us to comply with our legal obligations. For example, we will process certain personal information to comply with tax laws.
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In some cases, we process your personal information to perform our obligations pursuant to a contract with you or to take steps in anticipation of entering into such a contract. For example, we may process personal information on this basis to:
○ Administer your account, including to process your registration and verify your information; and
○ Complete transactions with you.
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In other cases, we process your personal information based on your consent. For example, in some cases the following activities will be performed on the basis of consent:
○ Contacting you through certain channels regarding Zenus and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you; and
○ Conducting certain other sales, marketing and analytics activities.
6. Your Rights and Choices
You can unsubscribe from Zenus marketing emails by clicking the unsubscribe link in a marketing email or contacting us as described below, and you can make certain choices regarding the use of cookies and similar technology as described in section 1 above.
Depending on which laws apply to particular situations, residents of the European Economic Area, the UK and some other jurisdictions have certain additional legal rights to do the following with personal information we handle:
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obtain confirmation of whether we hold personal information about them, and receive information about how it is used and disclosed;
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obtain a copy of the personal information, and in some cases, receive it in a structured, commonly used and machine-readable format, or have it transmitted to a third party in such form;
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update, correct or delete the information;
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object to the use or disclosure of the information;
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withdraw consent previously provided for the handling of the information (without affecting the lawfulness of prior use and disclosure of the information); and
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obtain a restriction on the use of the information.
For example, individuals whose personal information is subject to the GDPR have a right to opt out of our handling of their personal information for direct marketing purposes.
Many of the rights described above are subject to limitations or exceptions under applicable law.
If you wish to exercise any of these rights, or raise a complaint about our handling of your personal information, please contact us as described at the end of this Privacy Policy. You also have a right to file a complaint about our privacy practices with the relevant supervisory authority, but we respectfully invite you to contact us first, as we would like to do our best to resolve any concern you may have.
7. Protection of Information
To help protect personal information, we have put in place physical, technical, and administrative safeguards. However, we cannot assure you that data that we collect under this Privacy Policy will never be used or disclosed in a manner that is inconsistent with this Privacy Privacy.
8. Retention of Information
We will retain personal data as long as necessary to fulfill the purposes outlined in this Privacy Policy unless the law requires us to keep it for a longer period of time. To provide security and business continuity for the activities described in this Privacy Policy, we make backups of certain data, which we may retain for longer than the original data.
9. Updates and Changes to this Policy
Zenus may update this Privacy Policy from time to time, such as to reflect changes in our practices or for legal reasons. We will post those changes here or on a similarly accessible page.
10. Contact Information
If you have any questions or comments regarding our privacy policy and practices, or to submit a request or complaint, please email us at [email protected] or use the contact details below:
Zenus, Inc.
Attn: Privacy Officer
411 W Monroe St
Austin, TX 78704