Privacy Policy

 
 
 

Effective Date: October 21, 2019

Last Updated: October 21, 2019

Zena Software Labs – Pocket 409A - Privacy Policy

1. Introduction

Welcome! Your use of the Zena Software Labs (“Zena”) app called POCKET 409A (and the services made available through same (together, the “App”) constitutes your acceptance of this Privacy Policy (the “Privacy Policy”), which incorporates by reference our Terms and Conditions of Use located at www.pocket409A.com If you do not accept this Privacy Policy, you may not use the App. If at any time you do not agree to this Privacy Policy, you must cease your use of this App.

We value our customers and are committed to protecting their privacy and informing them as to how their personal data will be used. As a general matter, we collect customer information in an effort to improve your experience using the App and that of our other App users, and to communicate with you about our services and promotions, as well as other matters in which you may be interested. We recognize that we must maintain and use customer information responsibly. We have created this Privacy Policy to address our practices regarding information collected from visitors to, and users of, the App.

This Privacy Policy does NOT apply to other websites or apps to which we may otherwise link, or to other companies, third-party vendors who provide services to us, or entities who might be listed as third-party contacts on this App, each of which may be governed by their own privacy policies. This Privacy Policy also does not apply to information we may obtain from other sources about you. By using the App and/or by contacting us and providing any personal data, you consent to the collection, transfer, storage, disclosure and use of information by us in accordance with this Privacy Policy. If we decide to change our Privacy Policy, we will post those changes on this page.

Please do not visit or use this App from the European Union or European Economic Area, or anywhere else whose laws may conflict with this Privacy Policy; this App is not intended for your use if you are attempting to use from any of these countries and you do not have permission to use the App. Please note that this exclusion is solely because the laws of your country may not conform with our policies as set forth in this Privacy Policy.

2. Why We Collect Information

We collect personal data because: (a) it allows us to provide the services offered through the App; (b) it allows us to respond to questions you or others may have about the App or the information provided to you or others on or through the App; (c) it helps us provide and improve the App and the information provided from or through the App; and (d) it allows us, with your consent, to post your comments and annotations and related information, and for us to provide other useful information on the App. In addition, your personal data helps us communicate to you through the App, as well as to provide additional related information and events about which you might like to hear. We also may correlate your personal data with information from other sources. For example, we may cross-check the personal data you provide to us against information that might be otherwise available through other entities in order to prevent or detect fraud, or to provide credit or otherwise allow you to finance products or services offered on the App.

3. What Information We Collect About You

We may collect all types of “personal data.” For purposes of this Privacy Policy, the term “personal data” means any data which relates to a natural person (as opposed to a business or corporate entity) that makes you identifiable, and may specifically include:

  • Names and contact information, including phone number, physical address, and e-mail address;

  • Professional license or title (i.e., attorney licensed to practice in New Jersey) and professional experience

  • Financial information related to or required for payment (i.e., credit card or financial account information);

  • Referral source data (i.e., how you ended up at the App);

  • Your photo, if you provide one.

Any other similar information provided to us by you or on your behalf in connection with our Services (as defined below).

You agree that we may collect and process all such personal data that you provide to us to enable us to provide the services (the “Services”). These Services may include:

  • Management of the App and all content and services therein.

  • Providing you access to certain laws, rules and regulations, including the ability to annotate same and/or view the annotations of others.

  • Allowing others to view annotations you make in the App

  • Responding to or addressing any questions or inquiries from you or otherwise regarding us, any services we provide, or our App (whether your question or inquiry was via e-mail, directly on the App, hard copy or otherwise).

You also hereby consent that we may use your personal data for the following additional purposes which may be included in, or part of, the Services:

  • Updating our records;

  • Monitoring your App use history, information reviewed and comments or annotations made;

  • Obtaining demographical information of our users;

  • In connection with any application for employment with the Company;

  • Internal analysis for our business management purposes;

  • Any statutory or regulatory purpose which requires the processing of your personal data;

  • Legal and regulatory compliance;

  • Fraud and crime prevention;

  • Internal or external audits; and

  • Any other purpose for which valid consent is obtained.

In addition to the above, we may also collect other data (apart from personal data) from you which is not personal data, such as annotations or comments you provide or submit on the App. All such annotations and comments you provide or submit on the App are owned exclusively the Company and Company may share, sell or use such information or data as it deems appropriate.

Please do not supply the following to us:

  • Any other person's personal data, unless the Company explicitly asks you to do so;

  • Any categories of your personal data that have not been explicitly requested by the Company;

  • Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by the Company to provide; and

  • Any confidential, proprietary, secret or legally protected information which are under any legal obligation to not provide to or share with the Company.

4. How We Collect Information About You

We collect information about you (including personal data) when:

  • You Give Us Information - You may provide us information when:

  • You set up an account with us;

  • You provide it to us by filling out forms, including in connection with providing annotations or comments on the App;

  • You send us e-mail or submit any inquiry on or through the App, including in connection with a “contact customer service” request or inquiry;

  • You provide information via phone or in person;

  • You provide us with information in writing and send it to us other than via e-mail, phone or in person (i.e., mail, FedEx, etc.);

  • You provide us with documentation;

  • You provide us with information which may contain personal data;

  • You provide us with information in connection with seeking employment with the Company.

  • We Collect Information Automatically – We automatically collect certain types of information when you visit our App (as explained below).

  • We Collect Information From Other Sources – We may also obtain information about you from outside sources. For example, we may obtain commercially available information about you from third-parties or purchase e-mail lists from third parties for advertising and marketing purposes. We may also receive information from third-parties who provide services for us through web-beacons and other technologies described in this Privacy Policy.

5. Use of Cookies

Cookies

Cookies are bits of electronic information that a App may transfer to a visitor’s device to identify specific information about the visitor’s visits to the App. The App may use a feature known as a cookie, which assigns a unique identification to your device. Cookies are typically stored on your device’s hard drive and are used to help track clicks as you go through the pages within our App. We may also use cookies to tell us whether you have previously visited the App. We also use cookies which may be set by third-parties with whom we have entered into agreements which may enable us to obtain analytics information about the use of our App. You can set your browser or operating system not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. You may also use commonly available tools in your browser to remove cookies which may have been placed onto your computer. Shared local objects (commonly referred to as “FLASH cookies”) are cookies that are placed on your device that are not removed through normal browser management tools. If we use FLASH cookies, we will only do so in a manner consistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service.

Cookies That We Use

We use cookies for the following purposes related to the Services we provide for and to you and our users:

  • authentication - we use cookies to identify users of the App and/or the location of individuals accessing the App;

  • status - we use cookies to help us to determine if you are logged into our App;

  • personalization - we use cookies to store information about your preferences and to personalize the App for you;

  • security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our App and services generally;

  • advertising - we use cookies to help us to display advertisements that will be relevant to you

  • diagnosis – we use cookies to diagnose problems with our Services and servers;

  • analysis - we use cookies to help us to analyze the use and performance of our App and Services; and

  • cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally and in the event you open an account with us.

Cookies Used By Our Service Providers And Vendors

  • Our service providers and vendors may use cookies and those cookies may be stored on your computer when you visit our App. These service providers and vendors include:

  • Google Analytics (see https://support.google.com/analytics/answer/6004245?hl=en and information therein)

  • You should review the privacy and cookie policies of the above apps/website(s) to learn more about the cookies that are used in connection with the above.

  • The above apps and cookies may change from time to time as we use different vendors or service providers to provide some or all of the Services offered or provided by the above services and apps, or additional services we decide to include. While we will periodically update our list of such vendors and service providers, the above list may not be complete at any given time.

Managing Cookies

  • Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. To obtain more information about managing cookies on your device, please see: https://www.allaboutcookies.org/mobile/ or these links:

  • https://support.google.com/chrome/answer/95647?hl=en (Chrome)

  • https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

  • http://www.opera.com/help/tutorials/security/cookies/ (Opera);

  • https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

  • https://support.apple.com/kb/PH21411 (Safari); and

  • https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

  • Blocking some or all cookies may have a negative impact upon the usability of the App.

6. How We Use the Information We Collect

We use the information we collect in a variety of ways. Generally, we use the information we collect, including information provided by you, your personal data, and aggregate/de-identified data, to provide the Services.

We may also use the information we collect internally in our business for many business purposes, such as to: (i) provide the Services you may seek or which are available on the App; (ii) provide aggregated or other data to third parties concerning the results of your reporting and monitoring on and through the App, with or without other aggregated data; (iii) analyze trends and conduct research; (iv) provide support and respond to questions from our users, App visitors and customers; (v) improve our App; (vi) learn about users’ and customers’ needs; (vii) contact users for research, informational, and marketing purposes, including customizing our App; (viii) track traffic patterns and App usage; (ix) provide customer service and technical support; (x) correlate information with other commercially available information to identify demographics, reporting and monitoring needs, trail conditions, user impact and any other service or information offered on or through the App; (xi) provide specific relevant marketing, promotional, or other information to you; (xii) address information security and/or privacy practices, network functioning, engineering, and troubleshooting issues; (xiii) investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (xiv) comply with law, or based on our good faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud to reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the App, our partners or customers, or the public; and (xv) process or engage in a sale of all or part of our business/organization(s), or if we go through a reorganization or merger.

We may also share personal data and non-personally identifiable information externally with our affiliates and business partners, as well as with other third-party service providers who help us provide operational services for the site and our business, which might include, but is not necessarily limited to: business entities that provide e-mail address management and communication contact services, network equipment and application management providers and hosting entities, judicial, administrative and/or legal or financial accounting providers in the event that information must be reviewed or released in response to civil and/or criminal investigations, claims, lawsuits, or if we are subject to judicial or administrative process (such as a subpoena) to release your information or to prosecute or defend legal actions, and other service providers which may be involved in the other types of services and activities otherwise discussed in this Privacy Policy.

We may also use your personal data to contact you in ways other than e-mail or regular mail, such as via telephone contact or facsimile. All use of personally identifiable information will be as permitted by applicable law.

7. Business Transfers

If the Zena or substantially all of its assets were acquired, or in the unlikely event that the Zena goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of the Zena may continue to use your personal data as set forth in this Privacy Policy.

8. Your Choices about the Information We Collect

If you do not consent to the way in which we may use your personal data, please do not submit any personal data to us. Please note that if you do not provide us with certain personal data the Zena may be unable to allow you to use or access the App, or the services and/or information on or through the App may not be as good as they otherwise could be.

If you do not wish to receive emails from us, click the unsubscribe link located in our emails or opt out in your account profile.

If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal data with other entities as stated in this Privacy Policy, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be. Please note that de-identified and aggregate data including your personal data may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request to the following contacts:

E-mail Address: hello@pocket409A.com

9. Privacy of Children Who Visit the App

We recognize the importance of children's safety and privacy. The App is not designed to attract children, and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18.

10. Your California Privacy Rights

We collect various types of personal data about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us to disclose the categories or personal data of yours which we have shared with third parties, for the third parties’ direct marketing purposes during the prior year. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same brand name, if the third party will use such information for its direct marketing purposes.

If you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below. Please include your postal address in your request. Within thirty (30) days of receiving your written request, we will provide you with a Third Party Direct Marketing Opt-Out Form so you may request that your personal data not be disclosed to third parties for their direct marketing purposes.

E-mail Address: hello@pocket409A.com

Postal Address:

200 Park Avenue - 17th Floor,
New York, New York 10166

Attn: Sandra W. Cohen

11. Visitors to the App From Outside of the United States

If you are visiting the App from a location outside of the United States, you should not use this App and you are not permitted to do so. Your connection may be through and to servers located in the United States. Please note that the data protection laws in the United States and other countries might not be the same as those in your country. By using this App and/or submitting information to us, you specifically consent to the transfer of your information to the United States to the facilities and servers we use, and to those with whom we may share your information.

12. Security

We believe in providing a safe and secure experience for all of our online visitors. To that end, we have implemented security measures to protect the information collected from you. We maintain reasonable physical and electronic safeguards designed to limit unauthorized access to your personally identifiable information, and to protect you against the criminal misuse of that information.

While we use the foregoing security measures to protect your information, please note that no data transmitted over the Internet or stored and utilized for business purposes can be guaranteed to be completely secure. No security measures are perfect or impenetrable. We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share on the App will not become publicly available. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.

13. Questions / Changes in Notice

If you have questions or concerns with respect to our Privacy Policy, you may contact us at privacy@pocket409A.com We may elect to change or amend our Privacy Policy; in such event, we will post the notice changes in our Privacy Policy on www.pocket409A.com.

This assumes App solely used through mobile devices. If not, below can also be inserted.