Welcome to Zero-True! Zero-True is provided by ML Consulting LLC (collectively referred to herein as “we,” “us,” “our,” or “Zero-True”). We respect your privacy and the importance of the information you entrust to us. With this in mind, we provide you this privacy policy (the “Policy”) to help you understand the kinds of information we may gather about you when you use our online and/or mobile services, website, and software provided by or in connection with the service (collectively the “Services”), how we may use and disclose the information, and how you can control, correct and/or update the information. By accessing or using the Services, you are accepting the policies and practices described in this Policy. Each time you visit or use the Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy. This Policy shall be read in conjunction with our Terms of Service and all the relevant provisions of the Terms of Service (including but not limited to indemnification, limitation of liability, governing law and dispute resolution) shall mutatis mutandis apply to this Policy and be deemed to be incorporated herein by reference. Any capitalized terms not defined herein shall have the meaning as set forth in the Terms of Service. Please note that this Policy does not apply to your use of third-party sites, services, or applications you may access through the Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.
We collect information you provide directly to us when using the Services. For example, we collect information when you download our mobile application(s), register for our Services, sign up for an Account, complete a form, participate in any interactive features of the Services, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, mailing and billing address and payment information, and any other information you choose to provide. For purposes of registering and using the Services, we collect certain information that can identify you, such as your name and contact information (email, address and phone number) (“Personal Information”). We will never sell, rent, or trade your Personal Information or use Personal Information other than as needed to provide the Services requested by you. If you choose not to provide information that is necessary to provide the Services, you may not be able to use certain aspects or all of the Services. Zero-True discloses Personal Information only to those of its employees, contractors and affiliated organizations that (i) need to know the information in order to process it on yours and our behalf, and (ii) that have agreed in writing to non-disclosure restrictions at least as strong as those herein. We also may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your account. Depending on the nature of your inquiry or activities on the Services, we may also ask for other information relevant to your use of the Services.
You acknowledge and agree that communications, including phone calls or “chat” services, with Zero-True or our third-party agents may be monitored, recorded and retained by Zero-True. You consent to the monitoring and recording of all conversations between you and Zero-True and you release us from and against any and all claims, liabilities and losses that may result from any such monitored and/or recorded conversations.
When you access or use the Services, we automatically collect information about you, including the following:Log Information:
We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Services. Publicly available tools can sometimes provide the approximate location for IP addresses.Device Information: We collect information about the computer or mobile device you use to access the Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored in device memory that help us to improve the Services and your experience, see which areas and features of the Services are popular, and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in the Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.
We also may collect other types of information in the following ways when you use the Services:Details of how you used and interacted with the Services, such as your search queries and how you responded to certain questions. Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.Our server logs automatically collect information, such as your IP address, your browser type and language, and the date and time of your visit, which helps us track your movements around the Services and understand trends.Information We Collect From Other SourcesWe may also obtain information from other sources and combine that with information we collect through the Services. For example, we may collect information about you from third parties who provide services on our behalf, such as maintaining and monitoring usage of the Services and processing payment transactions. We also may receive information about you from the third parties with whom you interact through the Services.
We may use information about you for various purposes, including the following:
Provide, maintain, improve and deliver the products and Services you request, process transactions, and send you related information;Verify your identity and, if applicable, authorization for you to use the Services;Facilitate use of the Services;Process payment for Services;Analyze and draw trends from the aggregated statistics of user activity;Provide personalized recommendations and maintain general and personalized content;Manage your account and your preferences;To prevent or address service, security, technical issues at your request in connection with customer support matters;Respond to your comments, questions, and requests;Send you technical notices and other administrative messages;Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;Monitor and analyze trends, usage, and activities in connection with security-related initiatives and the Services;Conduct research, analysis, and surveys;Personalize and improve the Services and provide content or features that match user profiles or interests;Enforce our Terms;Link or combine with information we get from others in connection with the Services; andCarry out any other purpose for which the information was collected.This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable user of the Services. In other words, information about how you use the Services may be collected and combined with information about how others use the same Services, but no personally identifiable information will be included in the resulting data.
We may share or transfer information about you as follows or as otherwise described in this Privacy Policy:
With third party affiliates, contractors, and other service providers in connection with providing the Services;With affiliates, contractors, and other service providers who need access to such information to carry out work on our behalf;In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;If we believe your actions are inconsistent with the spirit or language of our Terms of Service or policies, or to protect the rights, property, and safety of you, us, or others and to enforce the provisions of our Terms of Service or policies, in cases of fraud or disputes, and/or to prevent harm to you or others;In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company;With your consent or at your direction, including if we notify you through the Services that certain information you provide will be shared in a particular manner and you provide this information.We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. This includes but is not limited to sharing information related to the research we conduct with various research and security organizations, including academic institutions or publications, as well as publishing our research online on our website or through third party social media sites.
We do not directly process any payments and do not store Your debit/credit card information. As detailed further in the Terms of Services, we use a third-party Payment Processor to bill You for our services. Secured socket layer technology is used for processing payment transactions with the Payment Processor. Payment processing shall be subject to the terms and conditions and privacy policy of the Payment Processor. For these third party service providers, we recommend that You read their privacy policies in order to understand the manner in which Your User Information and Your credit/debit card details will be handled by these providers.
We may allow others to provide analytics services in connection with the Services, such as Google Analytics, and others. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Services, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. We and others may use this information to, among other things, analyze and track data, determine the popularity of certain content, personalize the user experience, and better understand your activity.
To learn more about Google Analytics, please visit https://policies.google.com/privacy.SECURITY
We work hard to protect your information and take appropriate commercially reasonable physical, electronic, and other security measures to help safeguard personal information from loss, unauthorized access, alteration, or disclosure regardless of how or where it is stored. Our security practices include: encrypting many of our services using SSL; verification for account access; and frequent review of information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. However, no internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail.
Zero-True reserves the right to change, modify, add, or remove portions of this Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt out of such differing uses. Your continued use of the Services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Policy, as amended. We encourage you to review this Policy regularly.
The Services are intended for users who are eighteen (18) years of age and older. If you are under the age of 13, you are not permitted to submit any Personal Information to us. If you believe we might have any information from or about a child under 13, please contact us at support@zero-true.com.
We will retain your Personal Information for the period of time that is necessary to fulfil the original purposes for which it has been collected. Please keep in mind that, in certain cases, a longer retention period may be required or permitted by law or to allow us to pursue our business interests, conduct audits, comply with our legal obligations, enforce our agreements or resolve any dispute.
The criteria used to determine our retention periods include:
Time needed to provide you with our Services. Whether your account with us is active. You may contact us to make your account inactive at any time.
Legal, contractual, or similar obligations to retain your data, such as mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of contract or litigation. Please note that we are not responsible for storing any information that you provide to us or for any content or information that we provide to you. You are solely responsible for retaining backup files of any information and content that you provide or receive in connection with the Services.
TRANSFER OF PERSONAL INFORMATION; INTERNATIONAL VISITORS
The Services are provided from the United States. If you are located outside of the United States, any information you provide to us may be transferred out of your country and into the United States. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. Personally identifiable information collected through the Services may be stored and processed in the United States or, if and as applicable for international Users, any other country in which Zero-True or its affiliates, subsidiaries or service providers maintain facilities. If your Personal Information is transferred to a country other than your home country, we will take measures to protect it with appropriate contract clauses or other applicable safeguards.
If you are an international visitor, you acknowledge that by providing your Personal Information, you are: (a) permitting the transfer of your Personal Information to the United States which may not have the same data protection laws as the country in which you reside; and (b) permitting the use of your Personal Information in accordance with this Privacy Policy.
Subject to local law, you may also have certain rights regarding information that we have collected and that is related to you. For example, if you are located in the European Union with rights under the General Data Protection Regulation (“GDPR”), you have the right to withdraw previously provided consent for our processing of your “personal data” as such term is defined under the GDPR, by contacting us at support@zero-true.com. Such individuals also have the following rights:
Right to access – In accordance with Article 15 of the GDPR, this right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being processed and provides access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data has been or will be disclosed and the purposes of the processing.
Right to rectify – In accordance with Article 16 of the GDPR, this right allows individuals to rectify any inaccurate personal data about him or her.Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances in accordance with Article 18 of the GDPR.Right to be forgotten – This right is also known as the “right to erasure.” In accordance with Article 17 of the GDPR, it is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
Right of data portability – In accordance with Article 20 of the GDPR, this right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
Right to object to processing – In accordance with Article 21 of the GDPR, this right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
Right to withdraw your consent – You shall have the right to withdraw your consent at any time with regard to the processing of the User Information in accordance with Article 7 para. 3 GDPR.
Right to lodge a complaint – You may lodge a complaint with the supervisory authority in accordance with Article 77 para. 1 of the GDPR, if you feel that the processing of the data relating to you infringes the GDPR.Right to effective judicial remedy – You shall have the right to an effective judicial remedy where You consider that Your rights under the GDPR have been infringed as a result of the processing of Your personal data and the same is in non-compliance with the GDPR.
Legal Bases for Processing: We rely on the following legal basis to process your personal data: (i) it may be necessary for us to use and disclose your personal data for the performance and fulfillment of the contract between us and to provide you with our Services; (ii) if you specifically consent to certain uses of your personal data, we may use your personal data in a manner consistent with that consent; and (iii) we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary. To exercise any of the above rights, or if you have any questions or comments about the Policy or our privacy practices, please contact us at support@zero-true.com.
Your Information
We use reasonable processes to ensure compliance with this privacy policy and periodically verify that the policy is accurate. We encourage you to raise any concerns by contacting us at support@zero-true.com, and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information. Unless legal restrictions apply, you have the right to access the information we hold about you free of charge. You may update, correct or delete your information at any time by contacting us at support@zero-true.com. You can help us maintain the accuracy of your information by notifying us of any changes. To avoid delays in obtaining your information, please provide sufficient detail to permit us to identify you and the specific information that you are requesting. We will respond to your request within 30 days of receipt, unless we inform you that it will take longer, as permitted by law under certain circumstances. Please note that there may be instances where access may be restricted as permitted or required by law. We will advise you of the reasons for restricting access subject to any legal or regulatory limitations. In addition, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period. Please note that we are not responsible for storing any information that you provide to us or a third party or for any content or information that we or a third party provide to you. You are solely responsible for retaining backup files of any information and content that you provide or receive in connection with the Services.
Promotional Communications
By providing Personal Information to us, you expressly consent to receive messaging and information from us. You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at support@zero-true.com. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.
Please note that we do not respond to or honor ‘do not track’ (a/k/a DNT) signals or similar mechanisms transmitted by web browsers. If you have consented to have your Personal Information shared with any third party and you no longer wish to have your Personal Information shared with such parties, then you may opt-out of such disclosures by sending an email to support@Zero-True.com. However, we are not responsible for removing your Personal Information from the lists of any third party who has previously been provided with your information in accordance with this privacy policy or your separate consent.
Please note that there might be a brief delay between when you submit your request to ‘opt-out’ and when it is processed and reflected in our systems; accordingly, you may continue to receive communications from us for a limited time after you unsubscribe. We appreciate your patience.
Non-Discrimination
We will not discriminate against you because you elect to exercise any of the rights related to your Personal Information, including but not limited to:
Denying you products or Services; Charging you different prices or rates for Services, including through the use of discounts or other benefits or imposing penalties on you; Providing a different level or quality of Services to you; or Suggesting that you will receive a different price or rate for Services or a different level or quality of Services.
HOW TO CONTACT US
If you have any questions about this Policy, or our information practices, please contact us by email at support@zero-true.com.
LAST UPDATED: May 17, 2023
STATE ADDENDUM TO THE ZERO-TRUE PRIVACY POLICY
ADDENDUM DATE: May 17, 2023
This State Addendum to the Zero-True Privacy Policy (“Addendum”) supplements the terms of Zero-True’s Privacy Policy and applies to individuals who are residents of California, Colorado, Connecticut, Virginia, and Utah, as specified below. It describes the rights you may have, depending on the state of your residence, with regard to your personal information, which apply when new or updated laws take effect in these states. Except as may be required by applicable state law, this Addendum does not apply to any employees, owners, directors, officers, or contractors of Zero-True or its affiliates.
California Privacy PolicyThe section relates solely to residents of the State of California, and for purposes of this section, “you” means residents of the State of California. This section will provide you with information about our information practices and your privacy rights under the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA) and applicable regulations (collectively referred to as “CPRA”). Any terms defined in the CPRA have the same meaning when used in this section.
Personal Information we collectZero-True collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“CPRA Covered Personal Information” or “personal information”). CPRA Covered Personal Information does not include personal information that has been de-identified or aggregated, or that is publicly available information from government records.
In particular, we have collected the following categories of CPRA Covered Personal Information from consumers (as that term is defined in the CPRA) within the last twelve (12) months:
Category Examples Collected A. Personal Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YesB. Personal and financial information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YesC. Protected classification characteristics under California or federal law. Age (40 years or older), race, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status. NoD. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NoE. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NoF. Internet or other similar network activity. Browsing history, search history, information on your interaction with a Site, application, or advertisement. YesG. Geolocation data. Physical location or movements. NoH. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NoI. Professional or employment related information Occupation, title, employer information, current or past job history or performance evaluations. NoJ. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NoJ. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NoL. Sensitive Personal Information Social security, driver’s license, state identification or passport numbers; Account log-in, financial account, debit or credit card number in combination with any required security or access code, password or credentials allowing access to an Account; precise geolocation data; racial or ethnic origin, religious or philosophical beliefs or union membership, content of mail, email and text messages unless business is the intended recipient; genetic data; processing of biometric information for the purposes of uniquely identifying a consumer; personal information collected and analyzed concerning your health. Yes Categories of sources from which we collect personal informationYou have the right to know the categories of sources from which we collect your personal information. We make this information available to you in the INFORMATION WE MAY COLLECT section of our Privacy Policy.
Our processing of your personal informationYou have the right to know how we process and use your personal information. We make this information available to you in the USE OF INFORMATION section of our Privacy Policy.
Disclosure of Personal Information
You have the right to know if we share your personal information with any third parties and the categories of those third parties. We make this information available to you in the SHARING OF INFORMATION section of our Privacy Notice.
No Sales or Sharing of Personal Information
We do not sell personal information for monetary or other consideration, and we do not share your personal information for cross-context behavioral advertising (as defined in the CPRA). We have also not sold or shared the personal information of consumers under 16 years of age.
Use of Sensitive Personal InformationWe do not use or disclose sensitive personal information for purposes other than those specified in section 7027, subsection (m) of the CPRA regulations and we do not collect or process sensitive personal information for purposes of inferring characteristics about you.
Your CPRA Consumer Rights Where we are acting as a business (as opposed to a service provider as those terms are defined in the CPRA), you have the following rights: Right to Access. You have the right to request that we disclose the categories of personal information we collected about you, the categories of sources for the personal information we collected about you, our business or commercial purpose for collecting your personal information, the categories of third parties with whom we share your personal information; and the specific pieces of personal information we collected about you.Right to data portability. You have the right to obtain a copy of your data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to a third party.Right to delete. You may have the right to request that we delete your personal information where we act as a business. This right is subject to several exceptions and we may deny your deletion request if retaining the information is necessary for us or our service providers to:Complete the transaction for which we collected the personal information and take actions reasonably anticipated within the context of our ongoing business relationship with you or our client;Detect bugs or errors in our Services, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;Comply with a legal obligation; orMake other internal and lawful uses of that information as permitted by law or that are compatible with the context in which we collected it.Right to correct. We take reasonable steps to ensure that information we hold about you is accurate and complete. However, you have the right to request that we correct any inaccurate personal information that we have about you.Right to non-discrimination and no retaliation. We will not discriminate or retaliate against you for exercising any of your rights under the CCPA, including we will not deny you goods or services, charge you different prices for goods or services, provide you a different level or quality of goods or services, or suggest that you will receive a different price for goods or services or a different level of quality of goods and services.Exercising Your Rights You may exercise your rights to know, delete and correct as described above by submitting a verifiable request to us by either:
Emailing us at support@zero-true.com;
or
Calling us at 607-793-3309
Verification Process
We are only required to fulfill verifiable requests. Only you, you as a parent or a legal guardian on behalf of a minor child, or your authorized agent may make a verifiable request related to personal information. If you submit your request through an authorized agent, we may require you to provide your agent with written permission to do so and verify your identity. We may deny any request by an authorized agent that does not submit proof that the agent has been authorized by you to act on your behalf.
For requests for access to categories of personal information, we will verify your request to a “reasonable degree of certainty.” This may include matching at least two data points that you would need to provide with data points we maintain about you and that we have determined to be reliable for the purposes ofFor requests for specific pieces of personal information (portability request), we will verify your request to a “reasonably high degree of certainty.” This may include matching at least three data points that you would need to provide with the data points we maintain about you and that we have determined to be reliable for the purposes of verification. We will also require you to submit a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.For requests to delete, we will verify your request to a “reasonable degree” or a “reasonably high degree of certainty” depending on the sensitivity of the personal information and the risk of harm to the consumer posed by unauthorized deletion.We will use the personal information you provide in a request only for purposes of verifying your identity or authority to make the request.
Response Timing and Format
We will respond to a verifiable request within forty-five (45) days of its receipt, and will notify you within those forty-five (45) days if we require more time to respond and the reasons for the additional time. If you have an Account with us, we will deliver our written response to that Account. If you do not have an Account with us, we will deliver our written response by mail or electronically, at your option. (Note that the law prohibits us from disclosing at any time a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an Account password, security questions and answers, or any unique biometric data.) If we cannot comply with a request or a portion of the request, we will include the reasons in our response. If we deny your request on the basis that it is impossible or would involve a disproportionate effort, we will explain our reasons, such as the data is not in a searchable or readily accessible format, is maintained for only legal or compliance purposes, or is not sold or used for any commercial purpose and our inability to disclose it, delete or correct it would not impact you in any material manner.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
*Please note that in certain cases we may collect your personal information as a service provider (as opposed to a business, as those terms are defined in the CPRA) pursuant to a contract we have with a commercial client (the CPRA business) to provide a service. In such a case, we are required to collect and process your information only based on the instructions received from the business. Should you direct your requests to exercise your rights to us, we may be required to share your request with the business, who is the party responsible under the CPRA for receiving, verifying and responding to your requests, or we may direct you to make your request directly to the business.
CPRA exemptionsThis section (California Privacy Policy) does not apply to the following data which is exempt from the CPRA, including but not limited to: medical information governed by the California Confidentiality of Medical Information Act (CMIA); protected health information collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), or personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).
Other California Privacy RightsCalifornia’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services who are California residents to request certain information regarding our disclosure of personal information to affiliates and other third parties for their direct marketing purposes. To make such a request, please send an email to support@zero-true.com.
II. Notice of Colorado, Connecticut, Virginia and Utah Privacy Rights
The section relates solely to residents of the States of Colorado, Connecticut, Virginia and Utah, and provides you with information about your privacy rights under the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CDPA), the Virginia Consumer Data Protection Act (VCDPA) and the Utah Consumer Privacy Act (UCPA).
This section shall be effective for the residents of those States on the dates set forth below:
Effective January 1, 2023, for residents of the State of VirginiaEffective July 1, 2023, for residents of the States of Colorado and ConnecticutEffective December 31, 2023, for residents of the State of UtahFor purposes of this section, “residents”, “consumers” or “you” means individuals of those states who are acting in their individual or household context. This section does not apply to individuals acting in their commercial or employment context.
Personal Information we collectYou have a right to know the categories and types of personal information we collect about you. We make this information available to you in the INFORMATION WE MAY COLLECT section of our Privacy Policy.
Categories of sources from which we collect personal informationYou have the right to know the categories of sources from which we collect your personal information. We make this information available to you in the INFORMATION WE MAY COLLECT section of our Privacy Policy.
Our processing of your personal informationYou have the right to know how we process and use your personal information. We make this information available to you in the USE OF INFORMATION section of our Privacy Policy.
*For residents of the State of Virginia, to the extent that we maintain de-identified data, we take reasonable measures to ensure that de-identified data cannot be associated with a natural person, we publicly commit to maintaining and using de-identified data without attempting to re-identify the data, and we contractually obligate any recipient of the data to comply with the same obligations.
Disclosure of Personal InformationYou have the right to know if we share your personal information with any third parties. We make this information available to you in the SHARING OF INFORMATION section of our Privacy Policy.
No Sale of Data or Use of Data for Targeted AdvertisingWe do not sell your personal information and we do not use your data for targeted advertising (as that term is defined by your applicable state law). We may send you advertising in response to your request for information or feedback or based on your activities with our Services, including your search queries and visits to our Services. However, we will not send you targeted advertising based on your activities across non-affiliated websites, applications or platforms to predict your preferences or interests.
Your RightsWhere we act as the Controller of your personal information (as opposed to a Processor as those terms are defined in your applicable State law), you have the right to submit a request to us for the following:Right to access. You have the right to know if we process your personal information and have access to such information and certain details of how we use it.Right to correct. We take reasonable steps to ensure that information we hold about you is accurate and complete. However, you have the right to request that we correct any inaccurate personal information that we have about you.Right to delete. You may have the right to request that we delete your personal information where we act as a controller. This right is subject to several exceptions and we may deny your deletion request if retaining the information is necessary for us or our processors to:Complete the transaction for which we collected the personal information and take actions reasonably anticipated within the context of our ongoing business relationship with you or our client;Detect bugs or errors in our Services, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;Comply with a legal obligation; orMake other internal and lawful uses of that information as permitted by law or that are compatible with the context in which we collected it.Right to restriction of processing (opt-out). You have the right to opt-out of processing your personal information for purposes of profiling in furtherance of any automated processing of your data that produce legal or similarly significant effects concerning you. (This right only applies to residents of the States of Colorado, Connecticut and Virginia.)Right to data portability. You have the right to obtain a copy of your data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to a third party.Right to non-discrimination and no retaliation. We will not discriminate or retaliate against you for exercising any of your rights, including but not limited to, by denying you goods or services, charging you different prices for goods or services, or providing you a different level or quality of goods or services.Right to restrict the processing of sensitive informationUnless we are processing your sensitive information pursuant to any of the legal exemptions listed in Section 8 (Exemptions) below or as otherwise allowed by law:For residents of the States of Connecticut, Virginia and Colorado, we will not process your sensitive information without first obtaining your consent; andFor residents of the State of Utah, we will not process your sensitive personal information without providing you with notice and an opportunity to opt out.Exercising Your RightsYou may exercise your rights to know, delete and correct as described above by submitting a verifiable request to us by either:
Emailing us at support@zero-true.com;
or
Authentication Process
We will only fulfill request when we can verify your identify and confirm that you are authority to make such a request. Only you, you as the parent or legal guardian on behalf of your minor child, or your authorized agent, guardian or conservator may make a request related to personal information. If an authorized agent, legal guardian or conservator submits the request, we may require your written permission to do so and may require additional information to authenticate your identity. We may deny a request by an authorized agent, legal guardian or conservator who does not submit proof of authorization to act on your behalf. We will only use the personal information you provide in a request to verify your identity or authority to make the request.
We will respond to an authenticated request within forty- five (45) days of its receipt, and will notify you within those forty-five (45) days if we require more time to respond and the reasons for the additional time. If you have an Account with us, we will deliver our written response to that Account. If you do not have an Account with us, we will deliver our written response by mail or electronically, at your option. If we cannot comply with a request or a portion of the request, we will include the reasons in our response.
*For residents of the States of Colorado, Connecticut and Utah, you may make one request within a twelve-month period at no charge.
*For residents of the State of Virginia, you may make a request up to two (2) times within a twelve (12) month period at no charge. We reserve the right to charge a fee to process or respond to any request that we consider excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You have the right to appeal our decision within a reasonable period of time after receipt of our response. You may appeal our decision by sending us an email at support@Zero-True.com. We will respond to your appeal within 60 days of receipt (45 days of receipt for residents of Colorado) and will inform you of any decisions and the reasons for such decisions.
Please note that in certain cases we may collect your personal information as a processor (as opposed to a controller, as those terms are defined in your applicable state privacy law) pursuant to a contract we have with a commercial client (the controller) to provide a service. In such a case, we are required to collect and process your information only based on the instructions received from the controller. Should you direct your requests to exercise your rights to us, we may be required to share your request with the controller, who is the party responsible under your applicable state privacy law for receiving, authenticating and responding to your requests.
This section (Notice of Colorado, Connecticut, Virginia and Utah Privacy Rights) does not apply to certain entities and data that are exempt from your applicable state privacy law, including but not limited to the following: covered entities, business associates and protected health information governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH); financial institutions and personal information subject to the Gramm-Leach-Bliley Act (GLBA); and personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Family Educational Rights and Privacy Act, the Farm Credit Act and the Driver’s Privacy Protection Act of 1994 (DPPA).