GDPR Privacy Policy

Last Updated: May 30, 2023

GDPR PROVISIONS

Please note that this privacy policy shall apply to processing operations of Personal Data related to General Data Protection Regulation (GDPR) protected individuals. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being. The Privacy Policy provisions are qualified as follows for such protected individuals.

    WHAT PERSONAL DATA WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

    Consequences of not providing the data Period of Storage Third Parties with whom we Share your Data Why is the data collected and for what purposes? Data We Collect Use Case
    Legal Basis: It is either: (i) necessary to provide our Services to you, or (ii) following a User’s request, prior to entering into an agreement with us.
    You may not be able to use our Services. For as long as you access content through our Services. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days. Internal storage only We collect this Personal Data in order to:

    1. enable you to register and use our Services;
    2. for the purposes of delivering the products and services that you have requested;
    3. managing your account; and
    4. if applicable, providing you with customer support.
    		 name, address, email address, and telephone number.
    On a voluntary basis, you may also provide us with Personal Data about your interests, your gender, age, date of birth, language preference, and other demographic information    		 Accessing content made available by our Services through the Websites, streams or Apps.
    Dialing in to use our Services.
    You may not be able to share certain content through your social media account. For as long as you access content through our Services. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days. 3d party OAuth providers: Google , Facebook, Twitter if users choose to login with external credentials (for email) Twilio for SMS authentication We collect this data in order to enable you to connect and log in to the Services through your social network accounts, upload information and enable certain features of our Services name, surname, email address, profile picture, cover photo, username, friend list, and any other information you have made public on the applicable social network. Logging in to our Services using your social network credentials (applicable when using our Services via our App).
    We will not be able to respond to your enquiry. For as long as reasonably necessary to respond to your enquiry. Intercom When you commence direct communication with us, we will use the data in order to respond to your enquiry(ies), and if needed, for any further follow-up. Name and email address.
    You may also provide, on a voluntary basis, your phone number and company name.    		 General communication with us (e.g., through our Contact Us web page), including sending you service-related announcements (e.g., through Push Notifications and audio messages).
    Legal Basis: Consent
    We may not be able to send you information on new products or services which we think you may find valuable. For as long as you access content through our Services. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days. SendGrid (email distribution service) wilio (SMS) When you sign up to receive newsletters or other communications related to our Services, we will use the data in order to stay in touch with you. name, address, email address, and telephone number and any other information you choose to share with us Signing up to receive from us newsletters (or other communications) regarding new services or products that we think you may find valuable
    We may not be able to improve our Services to you. For as long as you access content through our Services. For as long as you remain subscribed. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days. Advertising partners: Display advertising: Active: Admob, Facebook / Meta, Monetize More, Instreamatic, Primis, Google Ad Manager (DFP/GAM) No longer used: Inmobi, Mobfox, Mopub, Aerserv, VRTCAL, via DFP: Antipodes, Tappx, Click Dealer Audio advertising: Adzwizz, Triton, Instreammatic, WideWorbit, Targetspot, Audio.Ad, AdTonos, EmpireStreaming In order to help us better understand how our Services are being used by you, how to promote the Services, and for the delivery of targeted advertising necessary for providing the Services free of charge. IP address, Mobile device ID. Marketing and Lead Targeting
    Certain features of our Services may not function properly without the aid of web cookies. For as long as you access content through our Services. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days. Internal storage only We use cookies, web beacons and other tracking technologies to keep track of services you have used and activities you have performed on our Website, radio stations you have listened to and listening and call-in habits, and several other functionalities, further described here. Cookies, web beacons and other tracking technologies Tracking your use of the Services.
    You will not be able to participate in any of polls, contents our surveys For as long as reasonably necessary to process the results of the poll, contest, etc. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days. Internal storage only Anonymized/Aggregate data shared with marketing/advertising partners When you agree to participate polls, contests, surveys or other features of ours, we will use the data in order to help us improve our Service. name, address, email address, telephone number and any other information you choose to share with us (e.g., information about your interests and activities, your gender, age, date of birth, language preference etc.) Participating in polls, contests, surveys or other features of our Services.

    SECURITY

    We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

    RETENTION OF YOUR PERSONAL DATA

    In addition to the retention periods mentioned in the table above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

    ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

    We ensure transfers within the Company group will be covered by an agreement entered into by members of the Company group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.

    Where we transfer your Personal Data outside of the Company, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.

    Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

    YOUR RIGHTS

    The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR. Please note that some of these rights may also apply under other jurisdictions as well:

    • You have a right to access information held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
    • You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.
    • You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
    • The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
    • The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
    • You have the right to object to profiling;
    • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority.
    • The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your Personal Data, in particular if the processing is required to meet our legal and regulatory obligations.
    • You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

    You can exercise your rights by contacting us using the contact information in the Privacy Policy or on our website https://zeno.fm/privacy.pdf