Effective May 25, 2018
Personal data is information that can identify you as a person, such as an email address, street address or phone number etc. Processing your personal data is necessary for us to serve our Customers. Please do not use Zen Planner or our services if you do not agree with how we process personal data according to this Privacy Statement.
The following terms will have the meanings indicated below.
This version was last updated on May 25, 2018. In all things, we constantly aim to do the right thing and always seek to improve. If we need to update this policy, we will do so to be more clear, open, and honest with you. Such modification will be effective upon its posting to our website; it is therefore important that you review this policy regularly.
Zen Planner processes personal data about our Customers. In addition we process personal data about persons representing potential Customers (prospects) that approach us via Zen Planner Sites or other channels. Our statement in these regards is to be found in the data controller section.
We also process End User data on behalf of our Customers of which the Customer controls. Our statement in these regards is to be found in the data processor section.
When Zen Planner determines the purpose and means of processing your personal data, Zen Planner acts as data controller. This includes scenarios where Zen Planner collects personal data in the context of you being a Customer or potential Customer.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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 offences.
In addition to this, our customers can create custom fields using our Services that our customers to collect information using their own customer-created forms or in connection with an individual’s profile. See the “Use by our Customers” section below for more information about use by our customers.
We use different methods to collect data from and about you including through:
Purpose of Processing and Legal Basis
We will only collect and process your personal data when we have a lawful basis for doing so.
The legal basis that we rely on for processing your data will depend upon the circumstances in which it is being collected and used. Most commonly, we will use your personal data in the following circumstances:
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We may use your personal data in the following ways:
We respect your privacy and will limit our communications to the following situations. We will only send you email messages that are necessary to keep you informed about the status of your account, to provide you with customer service that you’ve requested, or to inform you of relevant services or offers that Zen Planner or our partners are providing.
You can opt-out of or limit the types of marketing communications you receive from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your account, or by contacting us at: email@example.com.
We will not sell your information to any third parties, except in the limited circumstances involving a corporate affiliate, as described below, in connection with a sale of the Zen Planner business as a whole. We may have to share your personal data with the parties set out below. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
Zen Planner will need to share your personal data in order to ensure the adequate performance of our contract with our customer.
For example, service providers may help us:
In addition, we may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We may disclose your personal data to courts, law enforcement or governmental authorities, or authorized third parties, if it is necessary or we are required or permitted to do so by law, including for the following reasons:
Where appropriate, we may notify customers or individuals about legal requests unless:
In instances where we comply with legal requests without notice for these reasons, we will attempt to notify customers or individuals impacted promptly when we determine in good faith that we are able to provide such notice.
The Zen Planner Services may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Zen Planner doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Zen Planner, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 whether we can achieve those purposes through other means, and the applicable legal requirements.
A copy of Zen Planner’s Data Processing and Disposal Policy is available upon request to firstname.lastname@example.org.
Upon request we will provide you with information about whether we hold any of your, or your member’s, Personal Information. You have the following rights with respect to personal information:
To exercise any of these rights, please contact us at please contact us at: email@example.com. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
Information you share publicly using the Services (including through Integrated Websites) may be indexed through third party search engines. In some cases, you may opt-out of this feature in your account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
Also, we may retain some of your information as necessary for our legitimate business interests, such as fraud detection and prevention. For example, if we suspend Zen Planner account for fraud reasons, we may retain certain information from that Zen Planner account to prevent that individual or business from opening a new Zen Planner in the future.
We may retain and use your information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others (e.g., forum postings, etc.) may continue to be publicly visible, even after your Zen Planner account is cancelled.
Because we maintain the Zen Planner Services to protect against accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time in accordance with the Zen Planner Data Processing and Disposal Policy, a copy of which is available upon request to firstname.lastname@example.org.
The Services are not directed to individuals under 16. We require our Customers to seek consent from the holder of parental responsibility before collecting personal information about a child aged under 16.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We are always improving administrative, technical, and physical security measures to help protect information against unauthorized access, loss, destruction, or alteration, through the use of protective measures such as firewalls and data encryption, and information access controls. If you have reason to believe that your Zen Planner account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Zen Planner account, please contact us at: email@example.com.
Zen Planner provides many different services to our Customers which involve processing of the Customers’ members (or End Users) data. The purposes of processing is determined by our Customers not by Zen Planner, making the Customer the data controller. Zen Planner acts as data processor and process the data on behalf of and according to instructions given by the Customer. The relation between the Customer as data controller and Zen Planner as data processor shall be regulated by a data processing agreement.
Customer and Zen Planner obligations
When the Customer acts as data controller the Customer shall, according to applicable privacy legislation, ensure the legal grounds for processing the personal data. Further, the Customer shall assess and establish ownership to the risks posed to data subjects by processing their personal data. Another important aspect of the Customer’s duty as data controller is to comply with the information duty towards data subjects.
Zen Planner is a natural part of the Customers duties as data controller, in the sense that Zen Planner’s services constitutes parts of the processing of personal data that the Customer must ensure are compliant with applicable privacy legislation. Thus, when Zen Planner processes personal data on behalf of its Customers, we must do so in accordance with privacy legislation applicable for data processors.
In short, the Customer and Zen Planner are obligated to cooperate to ensure privacy for data subjects. Zen Planner shall provide the information necessary for the Customer to be compliant with applicable privacy legislation.
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