Zanbato Inc. Privacy Policy

TRUSTe Privacy Certification
Effective Date: 27 Sep 2016

Section 1 General

The privacy statement contained herein ("Privacy Statement") relates to the online information collection and use practices https://zanbato.com and its sub-domains (the "Site" as defined in the Terms of Use) owned and operated by Zanbato, Inc. ("We", "Us", "Our"). Zanbato, Inc. recognizes that many visitors and users of the Site are concerned about the information they provide to us and how we treat that information. This privacy statement has been developed to address those concerns. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

Zanbato, Inc and all of our U.S. affiliates participate in and have certified their compliance with the EU-U.S. Privacy Shield Framework. Zanbato, Inc is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

Zanbato, Inc is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Zanbato, Inc complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Zanbato, Inc is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Zanbato, Inc may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Zanbato, Inc complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Zanbato, Inc has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Zanbato, Inc’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.

The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged with Zanbato, Inc.

Section 2 Types of Information Collected

When you visit or access the Site, you may provide us with two types of information: (a) personally identifiable information, which is collected on an individual basis, and (b) general user information that does not contain personally identifiable information, which is collected on an aggregate basis. In some cases, if you choose not to provide us with requested information, you may not be able to access all of the Site Content or the Site's services.

2.1 Personally Identifiable Information. In order to access the Site, during the registration process, either you or your employer will be required to provide Zanbato, Inc. with certain information, including your name, employer, title, business address, business telephone number, and business e-mail address ("Registration Data"). Additionally, in accordance with FINRA/SEC requirements, you will be required to complete an investor questionnaire before closing a transaction on the site, which may collect your passport number and/or driver's license ID. Finally, when you request or view certain Site Content, such as Third-Party Content, the applicable Information Provider may obtain user identifiable information related to your request of, or access to, such content ("Access Data").

2.2 General User Information. In addition to Registration Data and Access Data, we collect and record certain other data and information from and about you in connection with your use of the Site ("User Data"). Technologies such as: cookies, beacons, tags, scripts, or similar technologies used by Zanbato, Inc and our partners, affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. We use cookies to remember users’ settings (e.g. language preference) and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. Additionally, while you are accessing the Site our Web servers may recognize your (i) domain name, (ii) ISP's domain name, (iii) IP address, (iv) browser type, and (v) operating system. Also, if you contact us with a technical question, we may collect certain information about your systems, including (i) your browser type, version and settings (e.g., Java and cookie settings), (ii) connectivity information (e.g., SSL/HTTPS compatibility, bandwidth capacity), and (iii) browser plug-in information (e.g., do you have Adobe, what is your media player, can you open Flash files, etc.). We use this information, which does not identify individual users, to analyze trends, to administer the Site, to track users' movements around the Site and to gather demographic information about our user base as a whole. We do link this automatically-collected data to personally identifiable information. We use Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here) Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Section 3 Disclosure/Use of Information

3.1 Personally Identifiable Information. Registration Data and Access Data may be shared with Information Providers (defined in the Terms of Use) authorizing your use of the Site or providing you with Site Content and third parties who are contracted to perform services on behalf of Zanbato, Inc., such as those who assist Zanbato, Inc. in bringing you the Site. Registration Data will be shared only with those Information Providers requested, by you or your employer, to authorize your use of the Site. Access Data will be shared only with the Information Providers providing Site Content you request or access. These companies are authorized to use your personally identifiable information only as necessary to provide these services to us. Each Information Provider's use of Registration Data and Access Data will be governed by such Information Provider's own privacy policies. In addition, Registration Data and Access Data may be used by Zanbato, Inc.: (i) in order to allow us to provide you with the products and services included within or accessible from the Site; (ii) in order for us to provide you with access to or from the Linked Sites; (iii) for our own marketing and/or research and development purposes; and (iv) in connection with our client services and client management systems; (v) in order to meet regulatory requirements imposed by the SEC and/or FINRA. We will share your personal information with third parties only in the ways that are described in this privacy policy. Except as otherwise noted in this Section 3.1, Zanbato, Inc. will not rent or sell personally identifiable information we have collected from or about you to their parties without your permission.

When you provide us with personal information about your contacts we will only use this information for the specific reason for which it is provided.

If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at privacy@zanbato.com.

3.2 General User Information. We use User Data in the aggregate to better understand your use of the Site and to enhance your enjoyment and experience. For example, we may use such information to improve the design and content of the Site or to analyze the programs and services that we offer. We may share User Data with Information Providers or other third parties. Any User Data shared with any Information Providers or other third parties will be disclosed as anonymized or aggregated data.

3.3 Legally Required Disclosure. Zanbato, Inc. may be required to disclose personally identifiable information to governmental, regulatory or self-regulatory entities or agencies in response to to lawful requests by public authorities, including to meet national security or law enforcement requirements, to their inquiries, to comply with applicable laws or other legal processes, to protect against misuse or unauthorized use of the Site, to limit our legal liability and protect our rights, or to protect the rights and safety of visitors to the Site or the public. In those instances, the information is provided only for that limited purpose. If Zanbato, Inc. is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your personally identifiable information.

Section 4 User Access and Choice

Upon request Zanbato, Inc will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at privacy@zanbato.com. If your personally identifiable information changes, or if you no longer desire our service, you may correct, update or delete/remove it by making the change on our member information page or by emailing our Customer Support at privacy@zanbato.com or by contacting us by postal mail at the contact information listed below. We will respond to your request to access within 30 days.

4.1 Data Retention. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

4.2 Opt-out Preferences. We will use your name and email address to send marketing or promotional emails to send the latest updates on our products and services. Out of respect for your privacy, you may choose to stop receiving these marketing emails by following the unsubscribe instructions included in these emails or you can contact us at support@zanbato.com.

Section 5 Consent to Transfer

The Site is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. You consent to the transfer of your information and to the processing by of your information in the United States and in other countries and territories for the purposes set out in the Terms of Use in accordance with applicable law and regulations.

Section 6 Data Security

The security of your personal information and our clients’ information is important to us. When you enter sensitive information (such as login credentials) we encrypt the transmission of that information using secure socket layer technology (SSL).

We take reasonable steps to maintain the security of the personally identifiable information that we collect, including limiting the number of people who have physical access to our database servers, as well as installing electronic security systems that guard against unauthorized access. No data transmission over the Internet can be guaranteed to be completely secure and we cannot ensure or warrant the security of any information that you transmit to us, so you do so at your own risk. If you have any questions about security on our Web site, you can contact us at support@zanbato.com.

Section 7 Additional Information

7.1 Links to 3rd Party Sites. The Site includes links to other Web sites whose privacy practices may differ from those of Zanbato, Inc. If you submit personally identifiable information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

7.2 Referrals. If you choose to use our referral service to tell a friend about the Site, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. Zanbato, Inc. stores this information for the sole purpose of sending this one-time email [and tracking the success of our referral program]. Your friend may contact us at support@zanbato.com to request that we remove this information from our database.

7.3 Single Sign-On. You can log in to the Site using sign-in services such as LinkedIn Connect. This service will authenticate your identity and provide you the option to share certain personally identifiable information with us such as your name and email address to pre-populate our sign up form. Services like LinkedIn Connect give you the option to post information about your activities on the Site to your profile page to share with others within your network.

7.4 Import Contacts. The Import Contacts feature allows you to import contacts by uploading a spreadsheet containing names and email addresses relevant to you. This feature allows you to keep track of prospective contacts within Zanbato who may not yet have user accounts on Zanbato. We will only use this information for the purpose of this feature.

Section 8 Changes to this Privacy Statement

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you or our Client by email (sent to the e-mail address specified in your account) or by means of a notice on the Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Section 9 Information Related to Data Collected through the Service

9.1 Information Related to Data Collected for our Clients. Zanbato, Inc. collects information under the direction of its Clients, and has no direct relationship with the individuals whose personally identifiable information it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personally identifiable information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

9.2 Access and Retention of Data Controlled by our Clients. Zanbato, Inc. has no direct relationship with the individuals whose personally identifiable data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate information should direct his query to the Zanbato, Inc.'s Client (the data controller). If requested to remove data we will respond within 30 days. We will retain personally identifiable information we process on behalf of our Clients for as long as needed to provide services to our Client. Zanbato, Inc. will retain this personally identifiable information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Section 10 Contact Information

In the event you have any questions regarding this Privacy Statement or your information that is held by us, you may contact us in writing at Zanbato, 711 N. Shoreline Blvd., Mountain View, CA 94043 or email us at support@zanbato.com.