This Privacy Statement explains our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information, by Zendy.
Table of Contents
- Privacy Statement
- Contacting us
- Collection of Information
- Use of Information
- Disclosure of Information
- Access to Account and Profiles
- Your Choices
- Your Information and Rights
- Other Websites, Platforms and Applications
- Changes to This Privacy Statement
- Cookies and Internet Advertising
- How Does Zendy use Web Beacons and other Technologies?
If you have general questions about your account or need to contact Customer Support for assistance, please send us an email at email@example.com. For questions specifically about this Privacy Statement, or our use of your personal information, cookies or similar technologies, please contact our Data Protection Officer by email at firstname.lastname@example.org.
The data controller of your personal information is EduTrain GmbH. Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.
Collection of Information
We receive and store information about you such as:
Information you provide to us: We collect information you provide to us which includes:
- your name, email address, address or postal code, payment method(s), and telephone number. In certain countries, we collect a government identification number for purposes such as billing and tax compliance. We collect this information in a number of ways, including when you enter it while using our service, interact with our Customer Support, orparticipate in surveys or marketing promotions;
- information when you choose to provide reviews or ratings, set your preferences, account details, or otherwise provide information to us through our service or elsewhere
Information we collect automatically: We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service (such as mobile devices, tablets, Smart TVs, etc.). This information includes:
- your activity on the Zendy service, such as title selections, download history and search queries;
- your interactions with our email, push and text messaging;
- details of your interactions with Customer Support, such as the date, time and reason for contacting us, transcripts of chat conversations, and if you call us, your phone number and call recordings;
- device IDs or other unique identifiers;
- advertising identifiers, such as those on mobile devices, tablets, and other devices that include such identifiers;
- device and software characteristics (such as type and configuration), connection information, tatistics on page views, referring source (for example, referral URLs), IP address (which may tell us your general location), browser and standard web server log information;
Information from other sources: We also obtain information from other sources. We protect this information according to the practices described in this Privacy Statement, plus any additional restrictions imposed by the source of the data. These sources vary over time, but could include:
- service providers that help us determine a location based on your IP address in order to customise our service and for other uses consistent with this Privacy Statement;
- select partners that make our service available on their device or with which we offer co-branded services or engage in joint marketing activities;
- payment service providers who provide us with updated payment method information based on their relationship with you;
- online and offline data providers, from which we obtain demographic, interest based and online advertising related data;
- publicly-available sources such as open government databases.
Use of Information
We use information to provide, analyse, administer, enhance and personalise our services and marketing efforts, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we may use information to:
- determine your general geographic location, provide localised content, provide you with customised and personalised recommendations for content we think will be of interest to you, determine your Internet service provider, and help us quickly and efficiently respond to inquiries and requests;
- prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforcing our terms (such as determining free trial eligibility);
- analyse and understand our audience, improve our service (including our user interface experiences) and optimise content selection, recommendation algorithms and delivery;
- communicate with you concerning our service (for example by email, push notifications, text messaging, and online messaging channels), so that we can send you news about Zendy, details about new features and content available on Zendy, and special offers, promotional announcements, and consumer surveys, and to assist you with operational requests such as password reset requests.
Our legal basis for collecting and using the personal information described in this Privacy Statement will depend on the personal information concerned and the specific context in which we collect and use it. We will normally collect personal information from you where we need the personal information to perform a contract with you (for example, to provide our services to you), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, our direct marketing activities in accordance with your preferences), or where we have your consent to do so (for example, for you to participate in certain consumer insights activities like specific surveys and focus groups). In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, to prevent payment fraud or confirm your identity). For questions about our use of your personal information (including legal bases and transfer mechanisms we rely on), cookies or similar technologies, please contact our Data Protection Officer by email at email@example.com.
Disclosure of Information
We may disclose your information for certain purposes and to third parties, as described below:
- We share your information among the Zendy associated companies as needed for: data processing and storage; providing you with access to our services; providing customer support; making decisions about service improvements; content development; and for other purposes described in the Use of Information section of this Privacy Statement.
- Service Providers: We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, infrastructure and IT services, to personalise and optimise our service, to process credit card transactions or other payment methods, to provide customer support, to collect debts, to analyse and enhance data (including data about users’ interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorise them to use or disclose your personal information except in connection with providing their services
- Promotional offers: We may offer joint promotions that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.
- Business transfers: In connection with any reorganisation, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Statement.
Whenever in the course of sharing information we transfer personal information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Statement and as permitted by the applicable laws on data protection
You may also choose to disclose your information in the following ways:
- while using the Zendy service you will have opportunities to post reviews or other information publicly, and third parties could use the information you disclose;
- certain portions of our service may contain a tool which gives you the option to share information by email, text message and social or other sharing applications, using the clients and applications on your device;
- social plugins and similar technologies allow you to share information.
Access to Account and Profiles
For ease of access to your account, you open a session when you log in to the website. This uses technology that enables us to provide direct account access and to help administer the Zendy service without requiring any password or other user identification to be re-entered when your browser revisits the service within a given time frame.
To remove access to your Zendy account, actively log out from Zendy on each device. Where possible, users of public or shared devices should log out at the completion of each visit. If you sell or return a computer or Zendy ready device, you should log out and deactivate the device before doing so. If you do not maintain the security of your password or device, or fail to log out or deactivate your device, subsequent users may be able to access your account, including your personal information.
If you share or otherwise allow others to have access to your account, they will be able to see your information (including in some cases personal information) such as your search history, reviews and account information (including your email address).
Email and Text Messages. If you no longer want to receive certain communications from us via email or text message, simply click the “unsubscribe” link in the email or reply STOP (or as otherwise instructed) to the text message. Please note that you cannot unsubscribe from service-related correspondence from us, such as messages relating to your account transactions.
Push Notifications. You may choose to receive mobile push notifications from Zendy. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device’s settings functionality to turn them off.
Interest-Based Ads. Interest-based ads are online ads that are tailored to your likely interests based on your use of various apps and websites across the Internet. If you are using a browser, then cookies and web beacons can be used to collect information to help determine your likely interests. If you are using a mobile device, tablet, or other device that includes an advertising identifier, then that identifier can be used to help determine your likely interests.
Your Information and Rights
You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you.
You can most easily do this by logging in to your account on our website, where you have the ability to access and update information about your account, including your contact information, your Zendy payment information, and various related information about your account. You may also request that we delete personal information that we hold about you.
To make requests, or if you have any other question regarding our privacy practices, please contact our Data Protection Officer at firstname.lastname@example.org. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please also see the “Your Choices” section of this Privacy Statement for additional choices regarding your information.
You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information; if we have collected and process your personal information with your consent, then you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; you have the right to complain to a data protection authority about our collection and use of your personal information. Our main establishment within the European Union is in Germany.
We may retain information as required or permitted by applicable laws and regulations, including to honour your choices, for our billing or records purposes and to fulfil the purposes described in this Privacy Statement. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.
We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorised access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.
Other Websites, Platforms and Applications
You must be at least 16 years of age to use the Zendy service. In certain jurisdictions, the required age may be older, in which case, you must satisfy that age in order to become a member. While individuals under the age of 16 may utilise the service, they may do so only with the involvement, supervision, and approval of a parent or legal guardian
Changes to This Privacy Statement
We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the Zendy service, after any such updates take effect, will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Statement, you may cancel your use of the Zendy service. To see when this Privacy Statement was last updated, please see the “Last Updated” section below.
Cookies and Internet Advertising
- What are cookies? Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. They are widely used to make websites work, or to work more efficiently, as well as to provide reporting information and assist with service or advertising personalisation.Cookies are not the only types of technology that enable this functionality; we also use other, similar types of technologies. See below for more information and examples.
- What are advertising identifiers? Advertising identifiers are similar to cookies and are found on many mobile devices and tablets (for example, the “Identifier for Advertisers” (or IDFA) on Apple iOS devices and the “Google Advertising ID” on Android devices), and certain streaming media devices. Like cookies, advertising identifiers are used to make online advertising more relevant.
- Performance and functionality cookies: These cookies are not essential, but help us to personalize and enhance your online experience with Zendy. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (for example, during member sign up). We also use these cookies to collect information (such as popular pages, conversion rates, viewing patterns, click-through and other information) about our visitors’ use of the Zendy service so that we can enhance and personalise our website and service and conduct market research. Deletion of these types of cookies may result in limited functionality of our service.
- Advertising cookies and advertising identifiers: These cookies and advertising identifiers use information about your use of this and other websites and apps, your response to ads and emails, and to deliver ads that are more relevant to you. These types of ads are called “interestbased advertising.” Many of the advertising cookies associated with our service belong to our Service Providers.
- How can I exercise choice regarding cookies and advertising identifiers?
To opt out of interest-based ads from Zendy in connection with an advertising identifier on a mobile device, tablet, or streaming media devices, please configure the appropriate setting on your device (usually found under “privacy” or “ads” in your device’s settings). You may still see Zendy ads on your device, but they will not be tailored to your likely interests. At this time, we do not respond to Web browser “do not track” signals.
- How Does Zendy use Web Beacons and other Technologies? Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. We and our Service Providers may use them for similar purposes as cookies, such as to understand and enhance the use of our service, improve site performance, monitor visitor traffic and actions on our site, and understand interactions with our marketing (including email and online ads on third party sites). Because web beacons often work in conjunction with cookies, in many cases, declining cookies will impair the effectiveness of web beacons associated with those cookies. We use other technologies that are similar to cookies, such as browser storage and plugins (e.g., HTML5, IndexedDB, and WebSQL). Like cookies, some of these technologies may store small amounts of data on your device. We may use these and various other technologies for similar purposes as cookies, such as to enforce our terms, prevent fraud, and analyse the use of our service. There are a number of ways to exercise choice regarding these technologies. For example, many popular browsers provide the ability to clear browser storage, commonly in the settings or preferences area; see your browser’s help function or support area to learn more. Other technologies, such as Silverlight storage, may be cleared from within the application.
Last Updated: December 4, 2019