This Privacy Policy describes how we – zenara Tech Ltd. (together with its affiliates companies – “zenara”, “zenara”, “zenara.io” “we”, “our” or “us”) collect, store, use and disclose personal data regarding individuals (“you”, or “Users”) who: (i) visit or otherwise interact with our website, available at https://zenara.io/ or any other website, webpage, e-mail, text message, plugin or application under our control (collectively – the “Platform”) (ii) use our proprietary artificial intelligence solution intended to assist individuals in assessing the personalities of people they meet, or any of our related services (collectively with the Platform – the “Services”)

Specifically, this Privacy Policy describes our practices regarding –

  1. Data Collection
  2. Data Uses
  3. Data Location and Retention
  4. Data Sharing
  5. Cookies, Tracking Technologies and Advertising Uses
  6. Communications
  7. Data Security
  8. Data Subject Rights
  9. Children’s Privacy
  10. Controller/Processor
  11. Additional Notices

Privacy is important to us, and we are strongly committed to being transparent and fair in our processing of personal data. Please read this Privacy Policy carefully and make sure that you fully understand and agree to our practices. Remember: you are not legally required to provide us with any Personal Data (defined below), and may do so (or avoid doing so) at your own free will.

If you do not wish to provide us with your Personal Data, or to have it processed by us, please simply do not enter our Platform or use our Services. You may also choose not to provide us with “optional” Personal Data, or to request to delete or opt-out of certain processing activities (see Section 8), but please keep in mind that limiting our processing may also result in us not being able to provide you with the full range of our services or with the best user experience when using our Services.

  1. Data Collection

We collect data regarding our Users. Such data is typically collected and generated through the User’s interaction with our Services, through automatic means, directly from such User or from other third parties. Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data“):

  1. Data automatically collected or generated: When you visit, interact with or use our Services, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of third party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).

    Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such device and the activity (clicks and other interactions) of Users in connection with our Services.

  2. Data received from you: You may provide us with Personal Data such as your name, contact details (such as e-mail, phone and address), account login details (such as username and hashed passwords), workplace and position, profile picture, interests, preferences, and free-form description (collectively, “Account Data“), as well as any other data you choose to provide when you use our Services, create a user account, publish content and interact with others via our platform, or contact us.

    In the event that a User registers to the Services through their existing third-party SNS Account (as defined under our Terms of Service, namely the User’s Facebook, Twitter, Microsoft or Google+ account, or other approved social platforms or networks), or through a “Single Sign-On” (SSO) mechanism implemented by any third party sites, then such third-party social network may provide us with certain information about such User, as is stored in and/or made available by the User through their SNS Account. This includes the User’s name, public profile picture, URL address, SNS Account User ID, e-mail address, date of birth, gender, occupation or work information, education and other information which the User made public. This Personal Data is automatically provided to and stored by zenara when registration to the Services is conducted via the User’s SNS Account.

  3. Data received from Users: Users may provide us with data concerning their friends, colleagues or employees, so we could contact them regarding our Services (e.g. to offer or provide them with our Services). Such data usually refers to such individuals’ name, role, company and work or personal contact details, as relevant, however additional data may be provided at the User's discretion.

  4. Data received from third parties: We may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or services provides, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.

  5. Data Uses

    We use Personal Data as necessary for the performance of our Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing, customer service and support operations, and protecting and securing our Users ourselves and our Services, as well as members of the general public.

    If you reside or are using the Services (i) in a territory governed by privacy laws which determine that “consent” is the only legal basis for the processing of Personal Data (in general, or specifically with respect to the types of Personal Data you choose to share via the Services) or (ii) in the EEA and provide us with Personal Data, the processing of which requires “consent” under applicable law (e.g. ‘special categories’ under the GDPR, or use of cookies under the e-Privacy directive and related local legislation), your acceptance of our Terms of Use and of this Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Privacy Policy. If you wish to revoke such consent, please contact us at [email protected] or follow the instructions in Sections 6 or 8 below (as the case may be).

    Specifically, we use Personal Data for the following purposes:

    1. To facilitate, operate, and provide our Services;
    2. To manage and deliver personalized information and content more effectively;
    3. To authenticate the identity of our Users, and to allow them access to our Services;
    4. To provide our Users with assistance and support;
    5. To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
    6. To contact our Users with general or personalized service-related messages and calls (such as password-retrieval emails or support or billing-related calls) and promotional messages and calls (such as with respect to new features or special offers and opportunities etc.); and to facilitate, sponsor and offer certain events and promotions;
    7. To support and enhance our data security and content compliance measures, including for the purposes of preventing and mitigating the risks of fraud, abuse, error or any illegal or prohibited activity;
    8. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
    9. To comply with any applicable laws and regulations.

  6. Data Location & Retention

    Data Location: Your Personal Data may be maintained, processed and stored by us and our authorized affiliates and Service Providers (defined below) in the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.

    zenara operates from Israel and the United States. Israel is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.

    While privacy laws may vary between jurisdictions, zenara and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

    Data Retention: We typically retain Users’ Personal Data for as long as their account is active, or as long as we consider necessary for the purposes described herein (which may extend even after their account is inactivated).

    We keep Users’ Personal Data for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services.

    We will also retain your Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our internal data retention policy.

    Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at [email protected].