ANZU PRIVACY POLICY

Last updated version: May 18, 2021

In order to ensure transparency and give you more control over your personal data, this privacy policy (“Privacy Policy”) governs how we, Anzu Virtual Reality Ltd. and its affiliates (together, “Anzu” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

(i)            When you browse or visit our website, https://anzu.io/ (“Website”)

(ii)           When you make use of, or interact with, our Website

a.    When you subscribe to our newsletter

b.   When we process your job application

c.    When you contact us (e.g. customer support, need help, get in touch, and submit a request).

(iii)         When you are a Publisher and you create an account, log in and make use of the dashboard environment, market place and/or any other software that we provide (“Services”) for its intended use (e.g., advertising and the execution of empowered marketing campaigns). 

(iv)          When the Anzu SDK is  initiated by the Publisher's game on a User device

(v)           When you attend a marketing events and provide us with Personal Data and/or exchange business cards with us

(vi)          When we use the Personal Data of our service providers and suppliers

(vii)        When we use the Personal Data of the Advertisers

(viii)      When we use the Personal Data of the Publisher and Partner

(ix)          When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

(x)           Any in-person interaction with you.

Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

1.  Introduction

2.  What Information we Collect, Why we Collect it, and How it is Used

3.  Period of Storage of Collected Personal Data

4.  How we Protect your Personal Data

5.  How we Share your Personal Data

6.  Additional Information regarding Transfers of Personal Data

7.  Your Privacy Rights; How to Delete your Account

8.  Use by Children

9.  Interaction with Third Party Products

10.   Log files

11.   Analytics tools

12.   Specific Provisions Applicable Under California Privacy Law

13.   Contact us

 

                          

1.  INTRODUCTION

 

Anzu offers specialized and innovative solutions and concepts for modern advertising and the execution of empowered marketing campaigns (the “Services”). Ad creative files that are parsed, rendered and displayed to Users in places defined by the publisher, such as, in a game or app (the “Ad” or “Advertisement”). For purposes of clarity, the publisher is an entity or individuals that develop computer games (the “Publisher”, “Customer”).

Anzu´s partners are companies that provide advertisements, demand side platforms, advertising networks, or other advertising demand sources that bid on ad inventory through the Anzu´s advertising exchange and serve ads, and those partners will assist Anzu to provide a monetization service and other connected Services, Also, through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, identifiers, page(s) visited, location, time of day) (the “Partner” or “Advertisers”).

 

For more information read the below table in Section 1 and Anzu's Partners and Advertisers list available here.

 

Anzu displays contextual Ads, behavioral Ads and safe-mode Ads. The types of Ads that the User will be allowed to receive and the types of Personal Data that can be used as part of the advertising and reporting processes are decided by the Publisher using the API provided by the Anzu SDK and the settings set by the Publisher in the Anzu dashboard for Publishers. If you are an individual, receiving Ads as a result of our relationship with Customer (the "User(s)"), please note that the Customer is the responsible party for obtaining the required consents and complying with any applicable laws or regulations.

This Privacy Policy is a part of our Terms and Conditions https://anzu.io/terms/, and should be read in conjunction with them. This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and acquire your consent if required by law.

When you interact with our website, we serve as the data controller for the purpose of GDPR. Because we do not yet hit the applicable thresholds, CCPA does not apply to our operations on our website. However, we are happy to offer Non-EU and California Residents rights as set forth in Section 7.2 below.

When we process your information as part of our relationship with our Customers, unless otherwise stated, we serve as the data processor (for the purposes of GDPR) and as the service provider (for the purposes of CCPA). You should contact the publisher in connection with any data subject rights or consumer rights to which you may be entitled under data protection laws and we will work with the Customers to respond to them.

 

2.  WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

 

Data we collect

 

Why is the Personal Data collected and for what purposes?

Legal basis (GDPR only, if applicable)

Third parties with whom we share your Personal Data

 

Consequences of not providing the Personal Data

When you browse or visit our Website

We automatically collect: Internet and other electronic network information, such as cookies, analytic tools and log files

For more information, please read our cookies policy

 

             For the Website to function properly

             To analyze and improve the Website based on your usage of it.

             For debugging purposes and to resolve technical problems

             To improve user experience

             To engage in internet-based advertising

Consent

Legitimate interest (e.g., to improve your user experience)

3rd party platforms such as for the following purposes:

·        Upress (Website Hosting)

·        Google Analytics (analytic tool)

Cannot collect and store the information.

Cannot improve your user experience.

Certain Website features may not be available

Cannot make re-targeting

When you make use of, or interact with, our Website

When you subscribe to our newsletter

We collect from you: Personal identifiers, including:

             Email address

             Full name

 

             To add you to our mailing list and keep you updated of new services, features and functionalities as well as updates about Anzu

             To send you marketing communications

             To track your interactions with the email (email opens)

Consent

3rd party platforms such as for the following purposes:

·        Google Analytics (Analytic tool)

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipedrive (CRM provider)

·        MailChimp (email delivery provider)

·        Upress (Website Hosting)

Cannot add you to our mailing list and keep you updated

Cannot send you marketing communications

When we process your job application

We collect from you: Personal identifiers, educational history, employment history, and internet and other electronic network activity information, including:

             Full name

             Email address

             Phone number

             CV and cover letter

             IP address

             Geolocation

             Usage pattern

             Any other information you decide to provide/supply us with

 

             To process your job application

             To assess the candidate

 

 

 

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. to process job applications)

3rd party platforms such as for the following purposes:

·        Google Analytics (Analytic tool)

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipdrive (CRM provider)

·        MailChimp (email delivery provider)

·        Upress (Website Hosting)

Cannot process your job application

Cannot assess your suitability as a candidate

 

When you contact us (e.g. customer support, help, get in touch, submit a request)

We collect from you: Personal identifiers and internet and other electronic network information, including:

             Full name

             Email  address

             Title

             Company name

             Reason for inquiry

             Comments

             IP address

             Geolocation

             Usage pattern

             Any other information you decide to provide/supply us with

 

 

             To process and answer questions

             To provide support (e.g., to solve problems, bugs or issues) and handle your complaints and/or feedback

             To customize your experience

NOTE: We do ask that you do not provide us with any personal information (other than the information required in the form, which we need to respond to your queries) for such purposes.

 

 

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g., respond to a query sent by you)

·        3rd party platforms such as for the following purposes: Google Analytics (Analytic tool)

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipedrive (CRM provider)

·        MailChimp (email delivery provider)

·        Upress (Website Hosting)

·        Slack (communication)

·        Whatsapp (communication)

Cannot assist you and respond your query

Cannot provide support and handle your complaints and/or feedback

Cannot customize your experience

We collect from you: Personal identifiers, including:

             Full name

             Email address

             To send you marketing communications

Consent

3rd party platforms such as for the following purposes:

·        Google Analytics (Analytic tool)

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipdrive (CRM provider)

·        MailChimp (email delivery provider)

·        Upress (Website Hosting)

Cannot send you marketing communications

When you are a Publisher and you create an account, log in and make use of the Anzu Services for its intended use

We collect from you: Personal identifiers and internet and other electronic network information, including:

             Admin full name

             Admin email address

             Admin phone number

             Full name, email, phone number and permission settings for regular users of Anzu´s dashboard

             Company name

             IP address

             Geolocation

             Usage pattern

             Any other information you decide to provide/supply us with

             To allow you to create an account and log in

             To allow you to create regular users

             To perform/execute the agreement

             To grant you access to the Services

             To allow you to make use of our Services

 

For avoidance of doubt, all of the purposes stated before for regular users, also apply to the Admin users in addition to the mentioned hereby.  

Processing is necessary for the performance of a contract to which our customer is a party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to allow you to create an account)

3rd party platforms such as for the following purposes:

·        Amazon (Cloud)

·        Hotjar (Analytic tool)

·        Google Cloud (Cloud)

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipedrive (CRM provider)

·        MailChimp (email delivery provider)

Cannot allow you to create an account and log in

Cannot allow you to create regular users

Cannot perform/execute the agreement

Cannot grant you access to the Services

Cannot allow you to make use of our Services

We collect from you: Personal identifiers,  internet and other electronic network information, and inferences,  including:

             Full Name of the user

             Email address of the user

             Phone number of the user

             IP address

             Geolocation based on IP address

             Usage pattern

             Browser user agent -

             Campaign data

             advertising activity events - Event analytics data

             Financial key performance indicators

             Log information / usage pattern

             Any other information you decide to provide/supply us with

 

 

 

             To provide you the Services

             To fulfill your requests for our services and for related activities (e.g., account management, support and to provide other Services related to your relationship with Anzu)

             To allow you to manage your ad placement inventory, to review reports/analytics,   list new apps, update ad placement configuration, create campaigns for internal promotions, manage black/white lists, review ads shown to users, and setting bid floor prices

             To serve and optimize advertisements

             To generate advertisements tracking reports

             To analyze performance, improve your user experience and resolve technical problems

             To improve the Service

             To calculate and pay revenue share according to your contract with us

             To communicate with you (service-related communications)

 

 

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g., to provide you with the services)

3rd party platforms such as for the following purposes:

·        Amazon (Cloud)

·        Hotjar (Analytic tool)

·        Google Cloud (Cloud)

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipedrive (CRM provider)

·        MailChimp (email delivery provider)

Cannot  provide you the Services

Cannot fulfill your requests for our services and for related activities

Cannot allow you to manage your ad placement inventory, to review reports/analytics, list new apps, update ad placement configuration, create campaigns for internal promotions, manage black/white lists, review ads shown to users, and setting bid floor prices.

Cannot serve and optimize advertisements

Cannot generate advertisements tracking reports

Cannot analyze performance, improve your user experience and resolve technical problems

Cannot improve the Service

Cannot calculate payment and send it

Cannot communicate with you (service-related communications)

We collect from you: Personal identifiers, including:

             Full name

             Email address

 

             To send you marketing communications (including, surveys)

Consent

3rd party platforms such as for the following purposes:

Google G-suit

Mixmax email tool

Pipdrive CRM SaaS provider

MailChimp mass email delivery provider

SurveyMonkey (survey provider)

Cannot send you marketing communications

When the Anzu SDK is initiated by the Publisher's game on a User device

We automatically collect: Internet and other electronic network information, including:

       IP address

       User agent

       Estimated location data from IP

       To understand which type of Ads we should display to the User (e.g., Consent under GDPR, COPPA) once activated Anzu's services by the Publisher

Important note: In some cases we chop the IP address to store it in a manner not identifiable and we do not share it with the Advertisers (e.g., GDPR user that did not provide consent to the Customer, or a COPPA User)

Compliance with a legal obligation (e.g. to understand which type of Ad we will need to display you).

Legitimate interest (e.g., to  understand which type of Ads we should display to you)

 

3rd party platforms such as for the following purposes:

·        Amazon AWS (cloud)

·        Google Cloud (cloud)

 

 

 

Cannot understand which type of Ads we should display you, per Publisher´s request

 

Cannot chop the IP address to store it in a manner not identifiable

 

When we serve a User an Ad on the Publisher’s game or application

BEHAVIORAL ADVERTISEMENT

We automatically collect: Internet and other electronic network activity information, including:

       IP address

       Advertising identifier (e.g., IDFA, Google Ad ID) or other device identifier

       Limit ad tracking status

       The user's  estimated  location data estimated by IP address that includes: country, city, zip, metro code, lat, lon

       The detected language of the user's device

       Basic device information (desktop/mobile, manufacturer, model, operating system, operating system version, user agent, lmt flag, location type, screen width and height in pixels)

       Connection type, ISP and carrier name

       The device precise GPS data of latitude  and longitude (in case permitted by the publisher)

       Randomly generated Anzu user ID per game/app

       Analytics data (session start, session end, click and etc)

       Any other Personal Data that the Publisher decided to share

 

In most cases we receive this information automatically through our SDK. In some cases we receive this information from management platforms.

 

       To serve the User personalized Ads

       To store and/or access information on a device

       To select and serve personalized ads  when the User makes use of the Publisher´s game or application

       Measure ad performance,  monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features

       To apply market research to generate audience insights

       To match and combine offline data sources

       To develop, update, fix and improve our products and Services

 

NOTE: If you are a User (as defined above), note that in most cases we act as a data processor and, therefore, our Customer is the data controller in relation to these activities. You should contact the Customer for any privacy-related questions.

 

In limited contexts where we are/act as a separate data controller:

·        In order for Anzu to process your Personal Data in the context of our Services, you normally will have already consented to data processing (please note that when Anzu does not have a relationship directly with you, the Publisher will ask you to consent and complying with any applicable laws or regulations for Anzu to collect your information and serve you with the Ads).

·        Performance of a contract with the Publisher

·        Legitimate interest (processing per publishers’ instructions, performance of the relevant instruction or contract)

3rd party platforms such as for the following purposes:

·        Amazon AWS (cloud)

·        Google Cloud (cloud)

·        Advertisers -  advertisers that sign an IO with Anzu and buy ads directly from Anzu on Anzu platform or indirectly through Anzu advertising demand partners

·        Advertising Demand Partners - vendors that buy Anzu ad inventory or facilitate this process for advertisers that want to buy Anzu inventory

·        Data Partners - vendors that get data from Anzu and provide additional data that help advertising demand partners to choose the best ad for each user

·        Fraud and Measurement Partners - vendors that get data from Anzu to show the effectiveness and value of Anzu advertising activities

·        Anzu processors and sub processors - vendors that help Anzu provision, operate, perform and improve Anzu services including  Advertisers, ad exchanges, DSPs, fraud detection vendoers, brand safety providers, brand lift study vendors, data management platforms

Cannot serve the User personalized Ads when the User makes use of the Publisher´s game or application

Cannot  store and/or access information on a device

Cannot  select and serve personalized ads  when the User makes use of the Publisher´s game or application

Cannot measure ad performance, monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features

Cannot apply market research to generate audience insights

Cannot match and combine offline data sources with the Personal Data that Anzu receives from the User

Cannot develop, update, fix and improve our products and Services

 

CONTEXTUAL ADVERTISEMENT

We automatically collect: Internet and other electronic network activity information, including:

       IP address

       Limit ad tracking status

       The user's estimated location data estimated by the IP address that includes: country, city, zip, metro code, latitude, longitude

       The detected language of the user's device

       Basic device information (desktop/mobile, manufacturer, model, operating system, operating system version, user agent, limited tracking flag, location type, screen width and height in pixels)

       Connection type, ISP and carrier name

       Randomly generated Anzu user ID per game/app

       Analytics data (session start, session end, click and etc…)

       Any other Personal Data that the Publisher decided to share with us

 

       To serve the User contextual when the User makes use of the Publisher´s game or application

       To measure ad performance,  monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features

       To apply market research to generate audience insights

       To match and combine offline data sources

       To develop, update, fix and improve our products and Services

 

NOTE: If you are a User (as defined above), note that in most cases we act as a data processor and, therefore, our Customer is the data controller in relation to these activities. You should contact the Customer for any privacy-related questions.

 

In limited contexts where we are/act as a separate data controller:

·        In order for Anzu to process your Personal Data in the context of our Services, you normally will have already consented to data processing (please note that when Anzu does not have a relationship directly with you, the Publisher will ask you to consent and complying with any applicable laws or regulations for Anzu to collect your information and serve you with the Ads).

·        Performance of a contract with the Publisher

·        Legitimate interest (processing per publishers’ instructions, performance of the relevant instruction or contract)

·        Amazon AWS (cloud)

·        Google Cloud (cloud)

·        Advertisers -  advertisers that sign an IO with Anzu and buy ads directly from Anzu on Anzu platform or indirectly through Anzu advertising demand partners

·        Advertising Demand Partners - vendors that buy Anzu ad inventory or facilitate this process for advertisers that want to buy Anzu inventory

·        Data Partners - vendors that get data from Anzu and provide additional data that help advertising demand partners to choose the best ad for each user

·        Fraud and Measurement Partners - vendors that get data from Anzu to show the effectiveness and value of Anzu advertising activities[

·        Anzu processors and sub processors - vendors that help Anzu provision, operate, perform and improve Anzu services

Cannot serve the User contextual Ads when the User makes use of the Publisher´s game or application

Cannot measure ad performance, monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features

Cannot apply market research to generate audience insights

Cannot match and combine offline data sources with the Personal Data that Anzu receives from the User

Cannot develop, update, fix and improve our products and Services

 

SAFE-MODE

We automatically collect: Internet and other electronic network activity information, including:

       IP address with the lowest 8 bits removed for IPv4 and lowest 32 bits removed for IPv6

       Limit ad tracking status

       The user's estimated location data estimated by the truncated IP address that includes: country, city

       The detected language of the user's device

       Basic device information (desktop/mobile, manufacturer, model, operating system, operating system version, user agent,  limited tracking flag, location type, screen width and height in pixels)

       Connection type, ISP and carrier name

       Randomly generated Anzu user ID per game/app

       Analytics data (e.g., session start, session end, click)

 

       To serve the User contextual Ads when the User makes use of the Publisher´s game or application

       To measure ad performance,  monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features

       To apply market research to generate audience insights

       To match and combine offline data sources

       To develop, update, fix and improve our products and Services

 

 N/A

3rd party platforms such as for the following purposes:

·        Amazon AWS (cloud)

·        Google Cloud (cloud)

·        Advertisers -  advertisers that sign an IO with Anzu and buy ads directly from Anzu on Anzu platform or indirectly through Anzu advertising demand partners

·        Advertising Demand Partners - vendors that buy Anzu ad inventory or facilitate this process for advertisers that want to buy Anzu inventory

·        Fraud and Measurement Partners - vendors that get data from Anzu to show the effectiveness and value of Anzu advertising activities

Cannot serve the User advertisement  (contextual Ads – without having access to Personal Data) when the User makes use of the Publisher´s game or application

Cannot  measure ad performance, monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features

Cannot  match and combine offline data sources  

Cannot develop, update, fix and improve our products and Services

 When you attend a marketing event and provide us with Personal Data and/or exchange business cards with us

We collect from you: Personal identifiers, including:

       Full name

       Email address

       Company name

       Job position

       Phone numbers

       Any other data you decide to provide/supply us with

       To establish a business connection

       To send marketing communications

 

Consent

Legitimate interest (e.g. send you more information about Anzu)

 

 

3rd party platforms such as for the following purposes:

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipdrive (CRM provider)

·        MailChimp (email delivery provider)

Cannot establish a business connection

Cannot send marketing communications

When we use the Personal Data of our service providers and suppliers

We collect from them: Personal identifiers, including:

       Full name

       Email address

       Company name

       Job position

       Phone numbers

       Any other data you decide to provide/supply us with 

       To contact our service providers

       To perform the applicable agreement

       To communicate with you (e.g., service-related communications)

 

 

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. perform the contract, send contract-related communications)

3rd party platforms such as for the following purposes:

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipdrive (CRM provider)

·        MailChimp (email delivery provider)

Cannot communicate with you

Cannot perform the applicable agreement

 

Personal identifiers, including:

       Full name

       Email address

 

       To send you marketing communications, updates, upgrades, surveys and other relevant information

Consent

3rd party platforms such as for the following purposes:

·        Google G-suite (email and business software tools)

·        Mixmax (email tool)

·        Pipdrive (CRM provider)

·        MailChimp (email delivery provider)

·        SurveyMonkey (survey provider)

Cannot send you marketing communications

When we use the Personal Data of the Advertiser

We collect from them: Personal identifiers and customer records information, including:

       Full name

       Email address

       Company name company incorporation number and other details about the company

       Job position

       Phone numbers

       Payment information (i.e. bank account number and/or credit card details)

       Any other data you decide to provide/supply us with

       To contact our Advertiser

       To perform the applicable agreement

 

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. perform the contract, send contract-related communications)

 

3rd party platforms such as for the following purposes:

·        Amazon (Cloud)

·        Google Analytics (Analytic tool)

·        Google Cloud (Cloud)

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipdrive (CRM provider)

·        MailChimp (email delivery provider)

Cannot communicate with you

Cannot perform the applicable agreement

 

Personal identifiers, including:

       Full name

       Email address

 

       To send you marketing communications, updates, upgrades, surveys and other relevant information

Consent

3rd party platforms such as for the following purposes:

·        Google G-suit (email and business software tools)

·        Mixmax  (email tool)

·        Pipdrive(CRM provider)

·        MailChimp(email delivery provider)

·        SurveyMonkey (survey provider)

Cannot send you marketing communications

When we use the Personal Data of the Publisher and Partner

We collect from them: Personal identifiers, including:

       Full name

       Email address

       Company name

       Company details, including address

       Job position

       Phone number

       Company incorporation number

       Billing information

       Any other data you decide to provide/supply us with

       To provide our products and services

       To perform the applicable agreement

       To communicate with the Publisher

       To calculate the billing activities

 

Processing is necessary for the performance of a contract to which our customer is a party.

Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).

Legitimate interest (e.g. send you contract-related communications)

3rd party platforms such as for the following purposes:

·        Amazon (Cloud)

·        Google Analytics (Analytic tool)

·        Google Cloud (Cloud)

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipdrive (CRM provider)

·        MailChimp (email delivery provider)

Cannot provide the services and/or our products

Cannot perform the agreement

Cannot communicate with you

Cannot calculate the billing activities

 

Personal identifiers, including:

       Full name

       Email address

       To send you marketing communications (including surveys)

Consent

·        3rd party platforms such as for the following purposes: Google G-suite (email and business software tools)

·        Mixmax (email tool)

·        Pipedrive (CRM provider)

·        MailChimp (email delivery provider)

·        SurveyMonkey (survey provider)

Cannot send you marketing communications

When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

Personal identifiers, including:

       Full name

       Social media handle

       Any other data you decide to provide/supply

 

 

       To reply and/or respond to your request or question

       To establish a business connection and/or to send you more information about Anzu (when requested by you)

Consent

Legitimate interest (e.g. send you more information about Anzu)

3rd party platforms such as for the following purposes:

·        Google G-suit (email and business software tools)

·        Mixmax (email tool)

·        Pipedrive (CRM provider)

·        MailChimp (email delivery provider)

Cannot reply or respond to your request

 

 


 

 

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Our legal basis in these cases is for compliance with a legal obligation (e.g., fraud detection, security and/or debug). Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

 

3.  PERIOD OF STORAGE OF COLLECTED PERSONAL DATA

3.1.    Personal Data. Your Personal Data will be stored until we: (i) no longer need the information and proactively delete it; or (ii) you send a valid deletion request.  Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

3.2.    Retention of your Personal Data. In addition to the retention periods mentioned in this section, 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. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

3.3.    Website cookies. Regarding retention of cookies, you can read more in our cookie policy.

 

4.  HOW WE PROTECT YOUR PERSONAL DATA. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, no security measure of modality of data transmission is 100% secure. . 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.

 

5.   HOW WE SHARE YOUR PERSONAL DATA. In addition to the recipients described in Section 1, we may share your Personal Data as follows:

5.1.    To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

5.2.    If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.

5.3.    Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and

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

5.5.    Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

5.6.    To the extent necessary to third parties, such as legal advisors, law enforcement, or governmental agencies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, prevent harm, for risk management purposes, or to comply with a legal obligation.

5.7.    With service providers that assist us in providing the Website and the Services.

5.8.    For a business purpose. In the preceding twelve (12) months, Anzu has disclosed your Personal Data for a business purpose with the following categories of third parties:

5.8.1.  We have disclosed your internet or other electronic network information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair Website errors.

5.8.2.  We have disclosed your internet or other electronic network information collected by cookies to our IT support to update, improve, and maintain the Website.

5.8.3.  We have disclosed your internet and other electronic network information, personal identifiers, and customer records information with service providers that perform services on our behalf. These service providers include our website provider, communications vendors, CRM provider

 

5.9.    In the preceding twelve (12) months, Anzu has shared your internet or other electronic network activity information collected via cookies and other tracking technologies with data analytics providers and advertising partners. To opt-out of this sharing, visit our cookie management platform using the cookie settings button in the anzu website footer.

5.10. If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to [email protected].

 

6.  ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

 

6.1.    Storage: AWS with servers located in the US, and Google with servers located in the US.

6.2.    Internal transfers: Transfers within the Anzu group will be covered by an internal processing agreement entered into by members of the Anzu 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.  

6.3.    External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your Personal Data. When Anzu engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. Anzu also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.

 

7.  YOUR PRIVACY RIGHTS; HOW TO DELETE YOUR ACCOUNT

7.1.    EU Residents: If our processing of your Personal Data is subject to the General Data Protection Regulation (GDPR) , you are entitled to the following rights (which may be subject to certain exemptions or derogations):

o      You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

o      You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;

o      You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;

o      You have the right to object, to or to request restriction, of the processing;

o      You have 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;

o      You have the right to object to profiling;

o      You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

o      You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;

o      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 or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

 

You can exercise your rights by contacting us at [email protected]. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

 

7.2.    Non-EU and California Residents: Even though we do not meet the applicable thresholds for the California Consumer Privacy Act (CCPA), we are happy to offer Non-EU and California Residents to the following rights:

o   You have the right to request what Personal Data we have collected, used, disclosed, and sold about you within the preceding twelve months. You may only make a request for access twice within a twelve-month period.

o   You have the right to request the deletion of your Personal Data that we collect or maintain, subject to certain exceptions.

o   You have the right to opt-out of the sale of your Personal Data to third parties. Anzu does not have actual knowledge that it sells Personal Data of minors under the age of sixteen (16) years.

o   You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CCPA.

7.2.1.  You can do this using a web form in this link or email us at [email protected]. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

7.2.2.  Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Data. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

7.2.3.  If neither GDPR nor CCPA applies to you, you can still request deletion of your data or opt out of sharing by clicking the privacy options link or emailing us at [email protected].

7.3.    Nevada Residents: If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your Personal Data. 

7.4.    Deleting your account: Should you ever decide to delete your account, you may do so by emailing: [email protected]. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account.

                                                                                                

8.  USE BY CHILDREN  

 

8.1.    Sensitive personal information: We ask that you do not send us, and do not share any sensitive Personal Information (for example, government-issued IDs, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).

8.2.    Website: We do not offer our products or services specifically intended for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].  

8.3.    Services: The Ads could be displayed to children protected by specific laws, including, COPPA and GDPR. Our services are not directed to minors and we and/or our Publisher do not promote or market its services to minors, except in very limited circumstances, in such cases with the applicable parental permission and with technological services that safeguard such collection in limited circumstances. For more, information please refer to Section 1 ("safe-mode (no personal data is involved)"). When Anzu controls the Personal Data of such children, Anzu delegates Anzu's obligations regarding consent to the Publisher. For any privacy/related question and or to obtain more information you should contact the Publisher. If you believe that we might have any such information, please contact us at [email protected].

 

9.  INTERACTION WITH THIRD PARTY PRODUCTS AND PARTNERS. We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

 

10.               LOG FILES. We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

 

11.               ANALYTIC TOOLS. Anzu uses in its Website the following tools.

          Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

         Hotjar. The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.

         We reserve the right to remove or add new analytic tools.

You may stop or restrict the placement of technologies on your device or remove them by adjusting your preferences as your browser or device permits.  The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs.  You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.   To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store.  Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

 

12.               DO NOT TRACK. We do not support Do Not Track (DNT). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

13.               CONTACT US. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at: [email protected] TO THE MAXIMUM EXTENT PERMIITED BY LAW, YOU UNDERSTAND AND AGREE THAT ANZU’S LIABILITY FROM ANY DISPUTE OVER PRIVACY OR THIS PRIVACY POLICY WILL BE LIMITED AS SET FORTH IN THE TERMS AND CONDITIONS OF OUR APPLICABLE WEBSITE TERMS AND CONDITIONS.