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OVERVIEW

Who are we?

Zette operates a business that enables users to “unlock” articles and other content on digital properties (for example, a news article that would otherwise be kept behind the paywall of a publisher’s website) so that users can access, read, and otherwise consume such articles and content.
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Except as expressly stated otherwise, the use of information by our affiliates, our Publishers (as defined under “Our Services” below), our service providers, and other third parties is not covered by this Privacy Policy.
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If you have any questions, please see the “Contact Us” section as the bottom of this Privacy Policy.

What is in this Privacy Policy?

This Privacy Policy (i) describes (a) the information Zette collects (1) through its Zette browser extension(s) and other (including application-based) extension(s) and associated Zette technology (collectively, “Zette Extension”) and (2) on its website(s) and its consumer-directed mobile application(s) (collectively with such website(s), “Zette Site” or “our Site”), and (b) the information Zette may receive from third parties, and (ii) explains how we may use this information, including to provide Services to consumers and Publishers.  This Privacy Policy also explain how you can manage your privacy choices and exercise your rights in relation to certain data about you that is collected and used by Zette.

OUR SERVICES

In this Privacy Policy, we refer to our products and services (as now existing and/or as may exist and/or be developed in the future), collectively with the Zette Extension, as our “Services”.
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Our Services are designed to enable users to “unlock” articles and other content on websites and other digital properties that utilize our Services (each owner and/or operator of such a website or digital property, a “Publisher”) in order to access, read, share, and otherwise consume such articles and content.
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Use of our Services is also subject to the Zette Terms of Service, a current copy of which is available here  and which may be updated from time to time.

INFORMATION WE COLLECT OR RECEIVE

Information We Collect Directly from Users‍

Registration Data

We collect an individual’s name, email address, phone number, and postal address when that individual registers for our Services.  We use such names, email addresses, and other information for our operational and commercial purposes, including (i) to provide and improve our Services and (ii) for marketing and/or communications, including to provide updates about our Services.
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We also collect and/or receive an individual’s demographic information (such as age, gender, education, income, and household status (e.g., number of children)), geographic information, and/or interest information (“Demographic and Interest Information”) when an individual registers for our Services or otherwise provides that information directly to Zette (Demographic and Interest Information about our “Registered Users”, collectively with the names, email addresses, and other information of our Registered Users collected during the registration process or as subsequently updated or provided by Registered Users, “Registration Data”). We may use Registration Data to provide and improve our Services, including for research, reporting, and analytics purposes in connection with our Services.

Information We Collect via the Zette Extension

Extension Data

We collect users’ online activity information when they use the Zette Extension, including, but not limited to, information regarding interactions with websites, applications, and content (collectively, “Extension Data”). We may use Extension Data to provide and improve the Zette Extension (to the extent necessary for the user-facing features thereof), including for functionality, performance, validation/authentication (including fraud detection and prevention) and security purposes and for research, reporting, and analytics purposes.  For example, we may use Extension Data to determine what types of websites, applications, and/or content a user may be interested in and how that individual and other individuals use the Zette Extension and interact with the websites, applications, and content of our Publisher clients (collectively, “Publisher Sites”). Extension Data includes:

• Records of the types of websites/applications and pages viewed
  
• Date and time of online activity
• Interactions with websites/applications and pages viewed (e.g., how long an individual remains on a website/application, the number and types of articles read, etc.)
  
• Frequency of visits to a website/application
• Information described as “Online Technical and Activity Information” below
• Inferences drawn from any of the information collected to create a profile reflecting the individual’s preferences, characteristics, and behavior

Additional Information We Collect on the Zette Site

In addition to Registration Data, we may collect the following information on the Zette Site:

• Information (which may include personal data such as name, address, email address, and telephone number) provided by an individual who submits a resume or a job application to us or requests information from us (“Requesting Information”)
  
• Information described as “Online Technical and Activity Information” below activity

We use Requesting Information to provide the requested materials and information, and for research, reporting, analytics, and other operational purposes.

Information We Receive from Third Parties

Zette Activity Data

When you view and interact with the Zette Site, and/or with third-party websites, apps, and other digital properties on which we may advertise (collectively, “Advertising Sites”; together with the Zette Site, “Zette Activity Sites”), we and/or our third-party vendors may collect and/or use (i) information about the interactions that you have with the Zette Site and with our advertising on the Advertising Sites, (ii) information about the Zette Activity Sites, and (iii) information that identifies your browser(s) and device(s) (collectively, “Zette Activity Data”). Zette Activity Data includes “Online Technical and Activity Information”, such as:

Technical Identifiers

These technical identifiers can be used to identify an individual’s browser, mobile advertising environment, and/or device, and typically include:

• Cookie IDs
• Mobile advertising IDs (e.g., Apple IDFAs and Google Advertising IDs)

Additional Technical Information

• Internet protocol address (“IP address”) and data derived from an IP address, such as non-precise geolocation data that indicates the country, region, city, and/or postal code of a deviceCookie IDs
• Type of Internet browser, browser language, and operating system
• Connection type (wired or Wi-Fi), network to which the device is connected, and mobile carrier (if available)
• Longitude/latitude of a (mobile) device; when we have the necessary rights to do so, we may also receive and/or use an individual’s precise geolocation data in the data feed we receive from our third-party vendors in connection with the delivery of digital advertising

For purposes of this Privacy Policy, “device” includes computers, smartphones, tablet computers, e-readers, and other digital devices capable of maintaining an Internet connection, and “mobile device” includes smartphones and tablet computers.
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In order to collect Online Technical and Activity Information, we and our third-party vendors typically use cookies, advertising IDs, pixels, and other technologies.

• A “cookie” is a small alphanumeric text file that is stored in a browser by a website or by a third-party ad server or other third party that allows that website or third party to recognize that browser and to remember Online Technical and Activity Information, Demographic and Interest Information, other Account Data, and other information.
• An “advertising ID” is an alphanumeric identifier made available by a platform or operating system (such as Apple iOS or Google Android) that allows application developers and third parties to recognize a particular device in an application environment and that may be associated with Online Technical and Activity Information, Demographic and Interest Information, other Account Data, and other information.
• A “pixel” is a line of code that is used by a website or other digital property to assign online activities to a device or browser, or more specifically to the applicable cookie or advertising ID

Our third-party vendors may use Online Technical and Activity Information, either by itself or together with Account Data, other Zette Activity Data, and/or other data we have collected or received (but not Extension Data), in order to help us make our advertising more useful and relevant, as well as to provide us with services designed to help us understand and improve the effectiveness of that advertising. We call this type of advertising “Tailored Advertising”, and it may also be called “Personalized Advertising”, “Interest-Based Advertising” or “Online Behavioral Advertising”. Our advertising may be delivered across computers, smartphones, and other devices, and our third-party vendors may associate information relating to browsers, environments, and/or devices that they reasonably believe belong to the same user in order to help us provide more useful and relevant advertising regardless of browser, environment, or device.
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Our third-party vendors, including Google Analytics, may also use Online Technical and Activity Information to help us understand and improve the effectiveness, performance, content, and security of our Site and Services, and for administrative and other security purposes. To learn more about Google’s use of information collected on our Site through Google Analytics, please visit www.google.com/policies/privacy/partners/.
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Please be aware that the Publisher Sites and the Advertising Sites may also use cookies, advertising IDs, pixels, and other technology, and the owners and operators of those Publisher Sites and Advertising Sites may collect your information in accordance with their own privacy policies. Therefore, you should carefully review the privacy policies that apply to the Publisher Sites, the Advertising Sites, and/or to any other sites you access from the Zette Site or when using the Zette Extension.
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Third-Party Payment Processors, Financial Information, and Payment “Tokens”

We use one or more third-party payment processors in connection with its products and services, including the Zette Extension.  If you provide your financial account number (e.g., credit card number or debit card number) in connection with your registration and/or payment for our Services, please be aware that: (i) you are providing such financial account number to the applicable third-party payment processor disclosed at the time of collection (not to Zette); (ii) Zette does not access, store, or otherwise process such financial account number; and (iii) the processing of such financial account number and any and all other data required or otherwise collected by such third-party payment processor (e.g., name, email address, phone number, postal address, commercial information, etc.) is subject to the applicable terms, conditions, and policies of such third-party payment processor (each of which may be modified from time to time by such third-party payment processor).  We may receive from, and provide to, the payment processor a randomly-generated payment “token” in connection with your registration and associated payments.

Data Retention

We will retain your personal information only for as long as reasonably necessary for the purposes set out in this Privacy Policy.  The criteria used to determine the retention periods include (i) how long the personal information is needed to provide our Services and operate our business, (ii) the type of personal information collected, and (iii) whether we are subject to a legal, contractual or similar obligation to retain such information.

Limited Use

Our collection, use, and transfer of data via the Zette Extension (which is currently available for the Google Chrome web browser only) are designed to comply with the Chrome Web Store User Data Policy, including the four elements of the “Limited Use” requirements under such policy as of the Effective Date at the top of this Privacy Policy.

DISCLOSURE OF INFORMATION TO THIRD PARTIES

Types of Data

Registration Data

As part of our provision of our Services, we may provide Registration Data to Publishers. In addition, we may provide Registration Data to third-party service providers that agree to use it only to provide services to us.
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Extension Data

We also may provide Extension Data to third-party service providers that agree to use it only to provide services to us.

Requesting Information

We may provide Requesting Information to third-party service providers that agree to use it only to provide services to us.

Zette Activity Information
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We allow third-party vendors that provide us with advertising (including Tailored Advertising) services and/or marketing services to collect Zette Activity Information, and we may also disclose additional information about you (e.g., Demographic and Interest Information), and information derived from it, to those third-party vendors.

Transfer of Data in the Event of Acquisition

In the event that another company acquires all or a majority of the assets of our business through a consolidation, merger, stock purchase, asset purchase, corporate reorganization, or other transaction, we reserve the right to transfer all information that is in our possession or under our control to the acquiring party.
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Transfers Legally Required; Transfers in connection with Prohibited Activities or for Security Purposes

If and to the extent we reasonably believe we are obligated by law, rule, regulation, or legal process to disclose information to a third party (including law enforcement), then we will do so.  In addition, we may disclose information to a third party (including an auditor or other service provider) in order to investigate, prevent, and/or take action regarding suspected or actual prohibited activities and/or in order to review, evaluate, and/or address the integrity and security of our Site and/or Services.

DATA SECURITY AND DATA RETENTION

Data Security
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Data security is important to Zette, and we implement reasonable and appropriate technical and organizational measures to protect against unauthorized access to, unauthorized or unlawful use of, and unauthorized disclosure of data, with respect to both data at rest and data in transit.  Please keep in mind, however, that despite our efforts to keep data secure, no storage or transmission of information can be guaranteed to be completely secure.

Data Retention

We retain the personal information we collect or receive for as long as reasonably necessary for the purposes described in this Privacy Policy.If and to the extent we reasonably believe we are obligated by law, rule, regulation, or legal process to disclose information to a third party (including law enforcement), then we will do so.  In addition, we may disclose information to a third party (including an auditor or other service provider) in order to investigate, prevent, and/or take action regarding suspected or actual prohibited activities and/or in order to review, evaluate, and/or address the integrity and security of our Site and/or Services.

YOUR CHOICES: RIGHT TO WITHDRAW CONSENT; OPT-OUT; UNSUBSCRIBE

Zette Account Deletion

If you are a Zette Account holder, you may “delete” your Zette Account, either via your Zette Account itself or by emailing us at contact@zette.com and expressly indicating your election to delete your Zette Account.

If you “delete” your Zette account, we will erase, de-identify, or aggregate the personal information/personal data in that account, in compliance with our obligations under applicable laws, rules, and regulations. However, if permitted, we may retain personal information/personal data that we may need, including for security and fraud prevention, to identify and repair errors in our Services, and to comply with legal and regulatory obligations.

Please note that “deleting” your Zette Account is different from “canceling” your Subscription, as described in the Zette Terms of Service.

Tailored Advertising‍

• In browser environments, you may opt-out of Tailored Advertising via our third-party vendors by utilizing any of the following methods:
• • Adjusting your browser settings to refuse or remove cookies, which would result in the cessation of Tailored Advertising via cookies from third-party vendors.  However, by doing so, you may not be able to use certain features on certain websites or take full advantage of all website offerings and Tailored Advertising.  You may refuse or remove cookies by following the directions provided in your browser settings.  Additional information about cookies is available at www.aboutads.info/consumers#cookies.
  • Adjusting the cookie settings at the level of the website owner where you granted consent to that cookie usage; cookie settings options may vary by website owner.
  • “Opting out” of Tailored Advertising via the targeting cookies of third-party vendors, at www.aboutads.info/choices.
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    Please note the following about opting out of targeting cookies:
  • • “Opting out” generally results in a unique targeting cookie being replaced on the applicable browser with a non-unique “opt-out” cookie.
    • An opt-out election applies only to the browser where the choice to opt out was effected.  For example, if you opt out in your Chrome browser on a particular device, that choice will not apply to any other browser you have on that device.  To opt out in another browser, you would need to repeat the opt-out process.
    • In order for the opt-out process to work, your browser must be set to accept third-party cookies.
    • If, after you have opted out, you buy a new device, upgrade or change web browsers or delete an opt-out cookie(s), you would need to perform the opt-out process(es) again.
• In mobile app environments, you may opt out of Tailored Advertising from third-party vendors by going to the privacy setting on your device and selecting “Limit Ad Tracking” via your device settings, which will result in the elimination of Tailored Advertising via the applicable advertising ID from such service providers.  Additional information regarding user choice in application environments is available at www.networkadvertising.org/mobile-choices.

Email and Text Marketing

If you do not want us to contact you or send you information by email, you may unsubscribe from receiving our marketing and promotional emails by following the unsubscribe link in such marketing and promotional emails.  If you do not want us to contact you or send you information by text, you may unsubscribe from receiving our text message marketing and promotions by replying STOP (or CANCEL, UNSUBSCRIBE, END, or QUIT, as applicable) to any such text message.

SPECIFIC LEGAL CONSIDERATIONS

Children’s Privacy
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Neither our Services nor the Zette Site is developed for or directed at children (as defined by applicable law).  We do not knowingly collect information from children on the Zette Site.  If you believe a child has provided us with personal information, or that we may have otherwise collected or received personal information from a child, and you would like to have such information removed, please contact us.

State-Specific Information‍

California‍

California Consumer Privacy Act
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As of the Effective Date at the top of this Privacy Policy, we do not believe that we are a “business” as defined by the California Consumer Privacy Act (“CCPA”).  If, following such Effective Date, we believe that we are a “business”, we will update this Privacy Policy in accordance with our obligations under CCPA.

Direct Marketing
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Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of “personal information” that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year.  To request a list of companies, if any, to which Zette has provided personal information for its own marketing purposes, please contact us by email to contact@zette.com, by phone (1-877-206-1267), or by mail to Off Topic, Inc. (d/b/a Zette), 2261 Market Street #4254, San Francisco, CA 94114, USA, Attn: Privacy.  Please allow 30 days for a response.

Do Not Track
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California law requires us to disclose how we respond to browser “Do Not Track” signals or other choice mechanisms relating to Tailored Advertising.  We have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

European Jurisdictions

Our Services are currently not intended for, and we currently do not offer the Zette Extension to, individuals in the European Economic Area, the United Kingdom, and/or Switzerland (each, a “European Jurisdiction”), although we may collect email addresses of European Jurisdiction data subjects and notify them about when we may offer the Zette Extension to them and provide other information (including marketing information) about our Services. We process such personal data based on the consent of such data subjects, and we believe that we are a “controller” (as defined by applicable law) of such personal data.

If you are a European Jurisdiction data subject, you have the following data protection rights under applicable law:

• Right of Access. You have the right to access your personal data.
• Right to Erase. You have the right to have us erase your personal data.
• Right of Rectification. You have the right to have your personal data rectified/updated if that information is inaccurate or incomplete.
• Right to Object. You have the right to object to our processing of your personal data carried out for our legitimate reasons and/or for direct marketing, including profiling that is related to such direct marketing.
• Right of Restriction. You have the right to request that we restrict the processing of your personal data (i.e., we would need to secure and retain the personal data for your benefit but not otherwise use it).
• Right to Data Portability. You have the right to be provided with a copy of your personal data in a structured, machine-readable and commonly used format (or have this transferred to a third party).
• Right to Withdraw Consent. You also have the right to withdraw your consent at any time where Zette relied on your consent to process your personal data.

If you wish to exercise one of the above-mentioned rights, please send us your request via email to europe@zette.com.
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You also have the right to complain to a data protection authority about our collection and use of your personal data. (If you are a resident of the European Economic Area, you can find your local supervisory authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.)  We would, however, appreciate the opportunity to address your concerns before you engage a data protection authority, and would welcome you directing an inquiry first to us at europe@zette.com.

ADDITIONAL INFORMATION

Third-Party Websites and Other Digital Properties
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The Zette Site may link to third-party websites and/or other digital properties, and the Zette Extension may be used to access and use Publisher Sites. Neither a link from the Zette Site to another website or digital property nor the ability to use the Zette Extension to access a Publisher Site implies our endorsement of that website, digital property, or Publisher Site. We do not control the websites or other digital properties to which we link or the Publisher Sites that are accessible through the Zette Extension, and we are not responsible for any of their content or any of their privacy policies or data protection practices. These websites, other digital properties, and Publisher Sites may use cookies, pixels, and other technology, and collect your information subject to their own privacy policies. Therefore, you should carefully review the privacy policies that apply to any websites and/or other digital properties you access from the Zette Site and/or that apply to any Publisher Sites you access through the Zette Extension.
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Changes to this Privacy Policy

Please note that, because of the changing nature of privacy laws, rules, and regulations, digital technologies, and our business, we may modify this Privacy Policy from time to time. Please review this Privacy Policy periodically to become aware of any changes that may have occurred; we will update the “Effective Date” at the top of this Privacy Policy to help you know when changes have been made.
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Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us by email to contact@zette.com, by phone (1-877-206-1267), or by mail to Off Topic, Inc. (d/b/a Zette), 2261 Market Street #4254, San Francisco, CA 94114, USA, Attn: Privacy.
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