2. Types of Data WeCollect
We may collect and storethe following Personal Data:
Information You Provide to Us.
· Contact information, such as name, user ID, e-mail address, and phone number
Information necessary for us to remit payments tosellers, such as financial account transactional information based on youractivities on the Site as a seller (such as item and content you generate orthat relates to your account); community discussions, chats, disputeresolution, correspondence through our Site, and correspondence sent to us;information we ask you to submit to authenticate yourself or if we believe youare violating site policies (for example, we may ask you to send us an ID orbill to verify your address, or to answer additional questions online to helpverify your identity or ownership of an item you list);
· Marketing information, such your preferences forreceiving marketing communications and details about how you engage withmarketing communications; and
· Other personal information you choose to submit to us.
Information We CollectAbout Buyers From or on Behalf of Our Sellers
We may collectinformation about buyers from or on behalf of our sellers. The sellersdetermine the scope of the information we collect on their behalf, that theytransfer to us, or that we otherwise collect, and the information we receivemay vary by seller. Typically, the information we collect about individuals fromor on behalf of our sellers includes:
transactional information based on youractivities on the Site as a buyer (such as item and content you purchase)
payment information, such as credit card number
your contact information (such as your name, userID, email-address, and shipping, billing and other information you provide topurchase an item or receive delivery of an item
other personal information that our sellers mayprovide about you.
Information Automatically Collected.
When you access the Site,we, our service providers, and our business partners may automatically loginformation about you, your computer or mobile device, and activity on ourSite. The information that may be collected automatically includes yourcomputer or mobile device operating system type and version number,manufacturer and model, device identifier (such as the Google Advertising ID orApple ID for Advertising), browser type, screen resolution, IP address, thewebsite you visited before browsing to our Site, general location informationsuch as city, state or geographic area; and information about your use of andactions on our Sites, such as pages you viewed, how long you spent on a page,navigation paths between pages, information about your activity on a page,access times, and length of access. Our service providers and business partnersmay collect this type of information over time and across third-party websites.This information is collected using cookies and similar technologies. Pleaserefer to the Cookies and Similar Technologies section for more details.
Social Media Networks andother Third Party Platforms.
We may offer singlesign-on services that allow you to use third party login credentials to signinto Service. With your permission, ZILKKO may also collect profile informationcontained in your third-party profile. ZILKKO may also, for your use, enable youto import information about who you are connected to, as well as enable you toshare information with those third-party sites. If you wish to discontinue suchsharing, please refer to the settings on the third-party service or yourpreference page on ZILKKO.
Sensitive Personal Information.
We ask that you not sendus, and you not disclose, any sensitive personal information (e.g., socialsecurity numbers, information related to racial or ethnic origin, political opinions,religion or other beliefs, health, biometrics or genetic characteristics,criminal background or trade union membership) on the Sites, or otherwise tous.
3. Cookies and SimilarTechnologies
What are cookies?
Cookies are small datafiles stored on your computer or mobile device by a website. Our Sites may useboth session cookies (which expire once you close your web browser) andpersistent cookies (which stay on your computer or mobile device until youdelete them) to provide you with a more personal and interactive experience onour Site.
We use two broadcategories of cookies: (1) first party cookies, served directly by us to yourcomputer or mobile device, which we use to recognize your computer or mobile devicewhen it revisits our Sites; and (2) third party cookies, which are served byservice providers or business partners on our Sites, and can be used by suchservice providers or business partners to recognize your computer or mobiledevice when it visits other websites.
Cookies we use
Our Site uses thefollowing types of cookies for the purposes set out below:
· Essential Cookies - These cookies are essentialto provide you with services available through our Site and to enable you touse some of its features. Without these cookies, the services that you haveasked for cannot be provided, and we only use these cookies to provide you withthose services.
· Functionality Cookies - These cookies allow ourSites to remember choices you make when you use our Sites. The purpose of thesecookies is to provide you with a more personal experience and to avoid youhaving to re-select your preferences every time you visit our Site.
· Analytics and Performance Cookies - These cookiescollect information about traffic to our Sites and about how individuals useour Sites. The information gathered may include the types of informationdescribed above in the section titled “Information automatically collected.” Weuse this information to help operate our Site more efficiently, to gather broaddemographic information, monitor the level of activity on our Site, and improvethe Site. We use Google Analytics, Optimizely, and New Relic for this purpose.These parties use their own cookies. You can find out more information aboutGoogle Analytics cookies here:https://developers.google.com/analytics/resources/concepts/gaConceptsCookies,and about how Google protects your data here:www.google.com/analytics/learn/privacy.html. You can prevent the use of GoogleAnalytics relating to your use of our Site by downloading and installing thebrowser plugin available here: tools.google.com/dlpage/gaoptout?hl=en-GB. Youcan find out more about New Relic’s services here: https://newrelic.com/, andits privacy practices here: https://newrelic.com/termsandconditions/privacy.
· Social Media Cookies -These cookies are used when you share information using a social media sharingbutton or “like” (or similar) button on our Site or you link your account orengage with our content on or through a social networking website such asFacebook or Twitter. The social network will record that you have done this. Social networks use their own cookies.
· Targeted and advertising cookies - These cookiestrack your browsing habits to enable us and third-party advertising networks todeliver ads that may be of interest to you. These cookies use information aboutyour browsing history to group you with other users who have similar interestsor browsing behavior. Based on the cookies that the third-party advertisingnetwork sets on our Site and other sites, advertisers can displayadvertisements that may be relevant to your interests on our Site and while youare on third party websites. You can choose to disable cookies, as describedbelow, or to opt out of the use of your browsing behaviour for purposes oftargeted advertising. For opt out instructions, please review the “Targetedonline advertising” portion of the “Your Choices” section of this PrivacyPolicy."
You can typically removeor reject cookies via your browser settings. In order to do this, follow theinstructions provided by your browser (usually located within the “settings,”“help” “tools” or “edit” menus). Many browsers are set to accept cookies untilyou change your settings.
For further informationabout cookies, including how to see what cookies have been set on your computeror mobile device and how to manage and delete them, visitwww.allaboutcookies.org.
If you do not accept ourcookies, you may experience some inconvenience in your use of our Site. Forexample, we may not be able to recognize your computer or mobile device and youmay need to log in every time you visit our Site.
In addition to cookies,our Sites may use other technologies, such as Flash technology, pixel tags, andsoftware development kits (or SDKs) to collect information automatically.
We may use Flash cookies(which are also known as Flash Local Shared Object (“LSOs”)) on our Site tocollect and store information about your use of our Site. Unlike other cookies,Flash cookies cannot be removed or rejected via your browser settings. If youdo not want Flash cookies stored on your computer or mobile device, you canadjust the settings of your Flash player to block Flash LSO storage using thetools contained in the Website Storage Settings Panel at this website. You canalso control Flash LSOs by going to the Global Storage Settings Panel at thiswebsite and following the instructions. Please note that setting the Flash Playerto restrict or limit acceptance of Flash LSOs may reduce or impede thefunctionality of some Flash applications, including, potentially, Flashapplications used in connection with our Site.
We may also use pixeltags (which are also known as web beacons and clear GIFs) on our Site and inour HTML formatted emails to track the actions of users on our Site andinteractions with our emails. Unlike cookies, which are stored on the harddrive of your computer or mobile device by a website, pixel tags are embeddedinvisibly on webpages or within HTML formatted emails. Pixel tags are used todemonstrate that a webpage was accessed or that certain content was viewed,typically to measure the success of our marketing campaigns or engagement withour emails and to compile statistics about usage of the Site, so that we canmanage our content more effectively.
Software Development Kits
Our mobile applicationsmay use software development kits (“SDKs”) provided by third parties. SDKsenable us to provide features and functionality developed by third-partydevelopers, including to provide us with analytics, social media integration,and advertising. The SDKs we use may enable third parties to collectinformation about the users of our mobile applications. The types of SDKs we use include:
Analytics SDKs. These SDKs are used to collectinformation about use of our mobile applications. The information gathered mayinclude the types of information described above in the section titled“Information automatically collected.” We use this information to help operateour mobile applications more efficiently, to gather broad demographicinformation, monitor the level of activity on and within the application,diagnose errors, and improve the mobile application.
Social Media SDKs. These SDKs help you tointeract with social networks you are signed into while using our mobileapplication, such as by sharing content with the social network and otherfeatures you use with the social network. Social networks may also work withour apps for analytics or advertising purposes, as discussed above.
We maintain a list ofSDKs used in our App here: http://help.ZILKKO.com/326594-what-sdks-are-used-in-your-mobile-applications.
4. Use of Your PersonalData
To provide our Sites andServices.
· facilitate the creation of and secure youraccount on our network;
· identify you as a User in the system;
· send you a welcome e-mail to verify ownership ofthe e-mail address provided when your account was created;
· respond to your inquiries related to employmentopportunities or other requests;
· provide the Service and customer support yourequest;
· resolve disputes, collect fees, and troubleshootproblems;
· prevent, detect, and investigate potentiallyprohibited or illegal activities, and enforce our User Agreement;
· customize, measure and improve our Service andcontent;
· tell you about our Service, service updates, andpromotional offers based on your communication preferences;
· compare information for accuracy, and verify itwith third parties; and
· and other uses as described when we collect theinformation.
To communicate with you
If you requestinformation from us (such as signing up for our newsletter), register on theSites, or participate in our contests or promotions, we may send you ZILKKO-relatedmarketing communications as permitted by law. You will have the ability to optout of such communications.
Use of Personal DataAbout Buyers on Behalf of Our Sellers.
We use personalinformation we collect about buyers from or on behalf of our sellers to provideservices only as directed or authorized by the seller. We do not use thisinformation for our own purposes. Typically, our clients direct or authorize usto use personal information collected on their behalf to enable ecommerce andpayments functionality on our clients’ websites, to manage the delivery ofelectronic goods, and to deliver communications from the sellers to theirbuyers.
To comply with law.
We use your personalinformation as we believe necessary or appropriate to comply with applicablelaws, lawful requests and legal process, such as to respond to subpoenas orrequests from government authorities.
For compliance, fraud prevention and safety
We use your personalinformation as we believe necessary or appropriate to (a) enforce the terms andconditions that govern the Sites; (b) protect our rights, privacy, safety orproperty, and/or that of you or others; and (c) protect, investigate and deteragainst fraudulent, harmful, unauthorized, unethical or illegal activity.
With your consent.
We will request yourconsent to use your personal information where required by law, such as wherewe would like to send you certain marketing messages. If we request yourconsent to use your personal information, you have the right to withdraw yourconsent any time in the manner indicated when we requested the consent or bycontacting us. If you have consented to receive marketing communications fromour third-party partners, you may withdraw your consent by contacting thosepartners directly.
To create anonymous data.
We may create AnonymousData records from Personal Data by excluding information that make the datapersonally identifiable to you. We use this Anonymous Data to analyze requestand usage patterns so that we may enhance the content of our Service andimprove site navigation. We reserve the right to use Anonymous Data for anypurpose and disclose Anonymous Data to third parties in our sole discretion.
5. Our Disclosure of YourPersonal Data
We may disclose PersonalData to respond to legal requirements, enforce our policies, respond to claimsthat a listing or other content violates the rights of others, or protectanyone's rights, property, or safety. Such information will be disclosed inaccordance with applicable laws and regulations.
We may also share yourPersonal Data with:
· Service providers under contract who help withour business operations (such as fraud investigations, bill collection,affiliate and rewards programs).
· Our sellers, when you make a purchase with themusing our Services.
· Other third parties to whom you explicitly ask usto send your information (or about whom you are otherwise explicitly notifiedand consent to when using a specific service).
· Professional advisors, such as lawyers, bankers,auditors and insurers, where necessary in the course of the professional servicesthat they render to us.
· Law enforcement, governmental agencies, orauthorized third-parties, in response to a verified request relating to acriminal investigation or alleged illegal activity or any other activity thatmay expose us, you, or any other ZILKKO User to legal liability. In suchevents, we will disclose information relevant to the investigation, such asname, city, state, ZIP code, telephone number, e-mail address, User ID history,IP address, fraud complaints, bidding and listing history, and anything else wemay deem relevant to the investigation.
6. Account Protection
Your password is the keyto your account. Use unique numbers, letters and special characters, and do notdisclose your ZILKKO password to anyone. If you do share your password or yourPersonal Data with others, remember that you are responsible for all actionstaken in the name of your account. If you lose control of your password, youmay lose substantial control over your Personal Data and may be subject tolegally binding actions taken on your behalf. Therefore, if your password hasbeen compromised for any reason, you should immediately notify ZILKKO andchange your password.
7. Your Choices
Accessing, Reviewing andChanging Your Personal Data
You may change any ofyour Personal Data in your account by editing your profile within your accountor by sending an e-mail to us at the e-mail address set forth below. You mayrequest deletion of your Personal Data by us, but please note that we may berequired to keep this information and not delete it (or to keep thisinformation for a certain time, in which case we will comply with your deletionrequest only after we have fulfilled such requirements). Upon your request, wewill close your account and remove your Personal Data from view as soon asreasonably possible, based on your account activity and in accordance withapplicable law. We do retain Personal Data from closed accounts to comply withlaw, prevent fraud, collect any fees owed, resolve disputes, troubleshootproblems, assist with any investigations, enforce our User Agreement, and takeother actions otherwise permitted by law.
You may opt out ofmarketing-related emails by clicking on a link at the bottom of our marketingemails, or by contacting us at firstname.lastname@example.org. You may continue to receiveservice-related and other non-marketing emails.
Some of the businesspartners that collect information about users’ activities on our Sites may bemembers of organizations or programs that provide choices to individualsregarding the use of their browsing behavior or mobile application usage forpurposes of targeted advertising.
Users may opt out ofreceiving targeted advertising on websites through members of the NetworkAdvertising Initiative by clicking here:www.networkadvertising.org/choices, or the Digital Advertising Alliance byclicking here: www.aboutads.info/choices. European users may opt out ofreceiving targeted advertising on websites through members of the EuropeanInteractive Digital Advertising Alliance by clicking here:https://www.youronlinechoices.eu/, selecting the user’s country, and thenclicking “Choices” (or similarly titled link). Mobile app users may opt out ofreceiving targeted advertising in mobile apps through participating members ofthe Digital Advertising Alliance by installing the AppChoices mobile app,available here: https://www.youradchoices.com/appchoices, and selectingthe user’s choices. Please note that we also may work with companies that offertheir own opt-out mechanisms and may not participate in the opt-out mechanismsthat we linked above.
If you choose to opt-outof targeted advertisements, you will still see advertisements online but theymay not be relevant to you. Even if you do choose to opt out, not all companiesthat serve online behavioural advertising are included in this list, and so youmay still receive some cookies and tailored advertisements from companies thatare not listed.
In addition, your mobiledevice settings may provide to limit our, or our partners’, ability to engagein ad tracking or targeted advertising using the Google Advertising ID or AppleID for Advertising associated with your mobile device.
Do Not Track Signals
Some Internet browsersmay be configured to send "Do Not Track" signals to the onlineservices that you visit. We currently do not currently respond to do not tracksignals. To find out more about "Do Not Track," please visithttp://www.allaboutdnt.com.
Choosing not to shareyour personal information
Where we are required bylaw to collect your personal information, or where we need your personalinformation in order to provide our services to you, if you do not provide thisinformation when requested (or you later ask to delete it), we may not be ableto provide you with our services. We will tell you what information you mustprovide to receive the services by designating it as required in or on the Sitesor through other appropriate means.
Your information isstored on our servers located in the United States. We use a variety ofsecurity technologies and procedures to help protect your Personal Data fromunauthorized access, use or disclosure. However, as you probably know, thirdparties may unlawfully intercept or access transmissions or privatecommunications, and other Users may abuse or misuse your Personal Data thatthey collect from the Site. Therefore, we do not promise, and you should notexpect, that your Personal Data or private communications will always remainprivate.
ZILKKO is headquarteredin the United States and has service providers in other countries, and yourpersonal information may be transferred to the United States or other locationsoutside of your state, province, country or other governmental jurisdictionwhere privacy laws may not be as protective as those in your jurisdiction.
European Union usersshould read the important information provided here about transfer of personalinformation outside of the European Economic Area:https://www.dataprivacymonitor.com/cybersecurity/cross-border-data-transfers-cutting-through-the-complexity/.
10. Third Parties
12. Contact Us
13. AdditionalInformation for European Union Users
For purposes of Europeandata protection legislation, ZILKKO, Inc. is the controller of personalinformation that we collect for our own business purposes. See the Contact Ussection above for contact details.
ZILKKO acts as aprocessor to sellers through the Services, as described throughout this PrivacyPolicy. When we act as a processor to a seller, the relevant seller is the datacontroller of your personal information processed in connection with the saleor delivery of goods to you.
Legal bases forprocessing
We use your personalinformation only as permitted by law. We are required to inform you of thelegal bases of our processing of your personal information, which are describedin the table below. If you have questions about the legal basis of how weprocess your personal information, contact us at email@example.com.
· To provide our Sites and Services - Processing isnecessary to perform the contract governing our provision of the Services or totake steps that you request prior to signing up for the Services.
· To communicate with you,
To create anonymousdata
, For compliance, fraud prevention and safety - These processingactivities constitute our legitimate interests. We make sure we consider andbalance any potential impact on you (both positive and negative) and yourrights before we process your personal information for our legitimateinterests. We do not use your personal information for activities where ourinterests are overridden by the impact on you (unless we have your consent orare otherwise required or permitted to by law).
· To comply with law - Processing is necessary tocomply with our legal obligations
· With your consent - Processing is based on yourconsent. Where we rely on your consent you have the right to withdraw itanytime in the manner indicated in the Service or by contacting us at firstname.lastname@example.org.
· Use of Personal Data on Behalf of Our Sellers -We use personal data to comply with the instructions of the data controller,our sellers and, to the extent necessary, to perform the contract governing ourprovision of the Services or to take steps that you request prior to signing upfor the Services.
Use for new purposes
We will only retain yourpersonal information for as long as necessary to fulfil the purposes for whichwe collected it, including for the purposes of satisfying any legal,accounting, or reporting requirements.
To determine the appropriateretention period for personal information, we consider the amount, nature, andsensitivity of the personal information, the potential risk of harm fromunauthorized use or disclosure of your personal information, the purposes forwhich we process your personal information and whether we can achieve thosepurposes through other means, and the applicable legal requirements.
When we no longer requirethe personal information we have otherwise collected about you, we willdissociate such information from the information attached to your content. Insome circumstances we may anonymize your personal information (so that it canno longer be associated with you), in which case we may use this informationindefinitely without further notice to you.
European data protectionlaws give European Union users certain rights regarding their personalinformation. If you are located within the European Union, you may ask us totake the following actions in relation to your personal information that wehold in the capacity of a data controller:
· Opt-out. Stop sending you direct marketingcommunications. You may continue to receive service-related and othernon-marketing emails.
· Access. Provide you with information about ourprocessing of your personal information and give you access to your personalinformation.
· Correct. Update or correct inaccuracies in yourpersonal information.
· Delete. Delete your personal information.
· Transfer. Transfer a machine-readable copy ofyour personal information to you or a third party of your choice.
· Restrict. Restrict the processing of yourpersonal information.
· Object. Object to our reliance on our legitimateinterests as the basis of our processing of your personal information.
You can submit theserequests by email to email@example.com or our postal address provided above.We may request specific information from you to help us confirm your identityand process your request. Applicable law may require or permit us to declineyour request. If we decline your request, we will tell you why, subject tolegal restrictions. If you would like to submit a complaint about our use ofyour personal information or response to your requests regarding your personalinformation, you may contact us as described above or submit a complaint to thedata protection regulator in your jurisdiction. You can find your dataprotection regulator here.
To the extent we act as aprocessor on behalf of a seller, individuals should contact the relevant sellerto exercise the rights and choices described in this section.
Whenever we transfer yourpersonal information out of the EEA to countries not deemed by the EuropeanCommission to provide an adequate level of personal information protection, thetransfer will be based:
· Pursuant to the recipient’s compliance withstandard contractual clauses, EU-US Privacy Shield, or Binding Corporate Rules
· Pursuant to the consent of the individual to whomthe personal information pertains
· As otherwise permitted by applicable EEArequirements.
Please contact us if youwant further information on the specific mechanism used by us when transferringyour personal information out of the EEA.