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Last Revised: 2019-06-26 13:26:43
Zyro Inc, UAB, a private limited company established in Lithuania, legal entity code: 305222050, registered address Jonavos g. 60C, LT-44192 Kaunas, Lithuania ("Zyro"), provides you website builder service.
Zyro seeks to ensure the highest level of data privacy when offering its variety of quality products and services to Zyro customers and subscribers ("Subscribers") (collectively, "You", or "Users").
At Zyro, the privacy and security of our Users is of paramount importance. Zyro is committed to protecting the data you share with us.
All personal data are processed in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR").
For any questions regarding this Policy or any requests regarding the processing of personal data, please contact us at firstname.lastname@example.org .
2. GENERAL PRINCIPLES. CONFIDENTIALITY
Zyro shall process all Personal Data adhering to the general data processing principles:
All and any information stored on Zyro Platform is treated as strictly confidential. All information is stored securely and is accessed by qualified and authorized personnel only.
3. INFORMATION WE COLLECT
3.1. Information You provide to us.
Information that is necessary for the use of the Zyro Platform
We ask for and collect the following personal information about you when you use the Zyro Platform. This information is necessary for the adequate performance of the contractual arrangement which is in place between you and us and to allow us to comply with our legal obligations. Failing to provide any of this data or decision to delete or object to the processing of any of such data may result in de-activation of your Zyro Account.
You may also choose to provide us information when you fill in a form, conduct a search, update or add information to your Zyro Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Zyro Platform. We advise against posting any information you don’t wish to make public on the Zyro Platform. If you upload any content to your account or post it on your Website and provide it in any other way as part of the use of any Service, you do so at your own risk.
Zyro processes information you provide to us on the legal basis of:
Please always take care and observe at least the following minimum requirements for the protection of your personal information:
Right to delete your data
You may at any time access and edit, update or delete your contact details by logging into your Zyro platform Account.
Please note that you will only be able to delete your email during de-activation of your Zyro Account. To deactivate your Account, please send your request to email@example.com , and you will be provided with further guidance.
3.2. Information We Collect when You use the Platform
When you use the Zyro Platform or contact us directly by any communication channel, we may collect information, including personal information, about the services you use and how you use them.
This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Zyro Platform.
Automatic collection of data
Zyro processes this information on the legal basis of:
4. HOW WE USE YOUR DATA?
We use, store, combine and process information, including personal information, about you to provide, understand, improve, and develop the Zyro Platform, create and maintain a trusted and safer environment and comply with our legal obligations.
5. JOB APPLICATIONS
Zyro welcomes all qualified Applicants to apply to any of the open positions published at undefined/career , by sending us their contact details and CV ("Applicants Information") via the relevant Position Application Form on our Website, or through any other means provided by us.
We understand that privacy and discreteness are crucial to our Applicants and are committed to keep Applicants Information private and use it solely for Zyro internal and group companies’ recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).
Zyro may retain Applicants Information submitted to it for no longer than one year after the applied position has been filled or closed. We collect this information to re-consider Applicants for other positions and opportunities at Zyro; we can use their Applicants Information as reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to his/her work at Zyro.
If you previously submitted your Applicants Information to Zyro, but now wish to access it, update it or have it deleted from our systems, please contact us at firstname.lastname@example.org .
6. INFORMATION PERTAINING TO VISITORS AND USERS OF OUR USER’S WEBSITES OR SERVICES
We may collect, store and process certain information pertaining to visitors and users of our User’s websites or services, solely on our Users’ behalf and at their direction. Each of our Users is able to collect and manage information, including personal data, via their website. Such information and personal data are then stored with Zyro. For such purposes, within the meaning of the GDPR, Zyro may in certain limited cases, as specified in the Terms of Service, be considered as a "data processor" of such information pertaining to visitors and users of their websites or services. The Users controlling and operating such User websites, shall be considered as the "data controllers" of such information, and shall be solely, completely and fully responsible and liable for complying with all laws and regulations that may apply to the collection and control thereof, including all privacy and data protection laws of all relevant jurisdictions.
User shall be solely, completely and fully responsible for the security, integrity and authorized usage of information related to visitors and users of their websites or services, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.
Zyro has no direct relationship with the individual visitors and users of our User’s websites or services whose personal data it processes. If you are a customer of any of our Users, and would like to make any requests regarding your personal data, please contact such User(s) directly.
For more information about data processing arrangement between us and our Users, please see our Terms of Service.
7. DIRECT MARKETING
When creating an Account at our Platform, you are free to opt-out from receiving various offers directly to your e-mail, phone or in your Account. We use provided contact details and your preferences for direct marketing by sending various offers or newsletters.
These direct marketing offers, depending on your preferences, may be personalized taking into account any other information which you have provided to us (e.g. location, social media profile information, purchase history etc.) or we have collected or generated from other sources as described below.
Right to object
If a User wishes to change their preferences for direct marketing, they may exercise such option at any time they wish by following the instructions to unsubscribe in the received email.
You are free to opt out of our newsletters at any time. You can do this by clicking on a link for that purpose at the bottom of our e-mail with the newsletters.
You may at any time refuse to receive information from us by sending an email to email@example.com , or by visiting and adjusting your personal account settings.
8. OTHER USES OF YOUR PERSONAL DATA
9. SOURCES OF PERSONAL DATA
We collect and receive your Personal data from yourself (including your device) as well as from the following sources:
10. RETENTION AND DELETION
We generally retain your personal information for as long as is necessary to provide our services and to comply with our legal obligations. Where your personal information is no longer required we will ensure it is securely deleted.
If you would like to stop us using your personal information, you shall request that we erase your personal information and close your Zyro Account.
After de-activation of Account, we will still retain the following data for the purposes of compliance with applicable legal requirements (such as tax, accounting, legal reporting, AML, other), for as long as we are legally required by virtue of such legal requirements:
Please also note that we may further retain some of your personal information in such cases (i.e., after closure of your Zyro Account):
11. DATA TRANSFERS AND USE OF THIRD-PARTY SERVICES
While collecting and processing your Personal Data, we may perform data transfers to various third parties.
11.1. With your consent
We will share your Personal Data with companies, organizations or individuals outside our group of companies when we have your consent to do so.
11.2. Where do we process your personal data?
We may share non-personally identifiable information publicly as well as with our partners - publishers, advertisers. For example, we may share information publicly to show trends about the general use of our platform.
If we are involved in a merger, reorganization, acquisition or sale, we will continue to ensure the confidentiality of any Personal Data and give all affected Users appropriate notices.
Some of our servers are located outside EU or European Economic Area (EEA), such as US, Brazil, Singapore, Indonesia,therefore, depending on your choice or the Services, your personal data as well as personal data of your users might be transferred to processors, sub-processors or other data recipients established in such third countries. We will ensure that the said personal data will be transferred only if there is a sufficient basis for this under the GDPR and other applicable legal acts.
EU-U.S. Privacy Shield. When providing hosting and other services, your personal data as well as personal data of your users might be transferred to data recipients established in third countries and participating in the EU-U.S. Privacy Shield Framework.
Standard contractual clauses for data transfers outside the EU or EEA. Your personal data as well as personal data of your users might be transferred to processors, sub-processors or other data recipients established in third countries (i.e., data centers and servers, located outside EU or EEA, please see more here: https://www.hostinger.com/technology#gref). For such transfers to be compatible with the requirements of GDPR, we have concluded with the data processors and/or sub-processor relevant agreements on such data transfers outside EU or EEA, which comply with the European Commission approved standard contractual clauses for data transfers from data controllers in the EU to data processors and/or controllers established outside the EU or European Economic Area (EEA). For more see: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en . For the said purposes and to the extent relevant we have deemed that the said agreements were concluded on your behalf and under your instructions, as the case may be, all in line with Art. 46 of GDPR.
Other grounds for data transfers outside the EU or European Economic Area (EEA). Your personal data as well as personal data of your users might be transferred to data recipients established in third countries on other legal grounds compatible with the requirements of GDPR (Art. 45-49).
Transfer, disclosure of data to competent authorities. In certain situations, Zyro may be asked to disclose personal data in response to lawful requests by public authorities, other competent authorities, including when it is required to meet national security or law enforcement requirements, and will do so where permitted by local data protection laws.
11.3. Data Localisation Obligations
If you reside in a jurisdiction that imposes "data localisation" or "data residency" obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so.
You acknowledge that while doing so, we may continue to collect, store and use your Personal Information elsewhere.
11.4. Targeting, advertising
11.5. Social Media Features
Our Services include certain Social Media features and widgets, single sign on features, such as the "Facebook Connect" or "Google Sign-in", the "Facebook Like" button, the "Share this" button or other interactive mini-programs ("Social Media Features"). These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties' Social Media Features are governed by their respective policies.
11.6. Our Legal Obligation to Use or Disclose Personal Data
We will reveal your Personal Data to state and public authorities without your prior permission only when we are legally required to provide information, including taking legal action to defend our rights, as well as the cases, where we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, enforce applicable Terms of Services, including investigation of potential violations, detect, prevent or otherwise address fraud, security or technical issues.
We may share your personal data in manners other than as described above, pursuant to your explicit consent, or if we are legally obligated to do so.
Zyro has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third-Party Services for further enhancing the security of our Services and protection of our Visitors' and Users' privacy.
Regardless of the measures and efforts taken by Zyro, we cannot and do not guarantee the absolute protection and security of your Personal Information, or any other User Content you upload, publish or otherwise share with Zyro or anyone else.
We therefore encourage you to set strong passwords for your User Account and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm.
If you have any questions regarding the security of our Services, you are welcome to contact us at firstname.lastname@example.org .
13. YOUR RIGHTS
You are entitled to a range of rights regarding the protection of your Personal Data, which are subject to limitations, restrictions and conditions as laid down in GDPR and applicable law. Those rights are:
Some of the rights as above are easy to exercise: i.e., you may at any time access and edit, update or amend your details, opt out of receiving communications from us and our partners by visiting and adjusting your personal account settings, or by e-mail: email@example.com .
When you object to processing of Personal Data when processing is carried out on the basis of legitimate interest, we will carefully consider such a request, which may result in your Account closure or de-activation.
Users have the right to lodge a complaint with the national Data Protection Agency in their country of residence in the event where their rights may have been infringed. However, we recommend attempting to reach a peaceful resolution of the possible dispute by contacting us first.
14. ACCEPTANCE OF THIS POLICY
We assume that all Users of Zyro Platform have carefully read this document and agree to its contents. If someone does not agree with this Policy, they should refrain from using our website, and mobile applications. We reserve the right to change our Policy at any time and inform by using the way as indicated in Section 17. Continued use of Zyro website and mobile applications implies acceptance of the revised Policy.
This Policy is an integral part of Zyro Terms and Conditions.
We will ask for your consent before using information for a purpose other than those set out in this Policy.
16. APPLICATION OF POLICY
Our Policy applies to all of the services offered by us and our affiliates, including Zyro Inc,, UAB, private limited liability company, organized under the laws of the Republic of Lithuania, code 305222050, legal address at Jonavos st. 60C, LT-44192 Kaunas, Lithuania, but excludes services that have separate privacy policies that do not incorporate this Policy.
Our Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include our services or other sites linked from our services.
Our Policy may change from time to time. We will post any Policy changes on our website and, if the changes are significant, we may consider providing a more explicit notice (including, for certain services, email notification of Policy changes).