PRIVACY STATEMENT

Effective Date: April 11th, 2019

Zunesis respects your privacy on the Internet. As part of our company operations, we gather certain types of information about our contacts, and we would like to explain the types of information we assemble, what we do with it and how to correct or change your information. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at privacy@zunesis.com.

This privacy policy applies to all information collected through our website zunesis.com, and/or any related services, sales, marketing or events.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us. It will notify you of the following:

1. Definitions used in this Policy;
2. Data Protection Principles;
3. Data Subject’s rights;
4. What information we collect;
5. With whom it is shared;
6. How it can be corrected;
7. How it is secured;
8. How policy changes will be communicated; and
9. How to address concerns over misuse of personal data.

SECTION 1 -Definitions

• Personal Data – any information relating to an identified or identifiable natural person.
• Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
• Data Subject – a natural person whose Personal Data is being Processed.
• We/us (either capitalized or not) – Zunesis, Inc.
• Website – The website that you are currently using, www.zunesis.com, and any subdomains of this site unless expressly excluded by their own terms and conditions.

SECTION 2 – Data Protection Principles

We promise to follow the following data protection principles:

1. Processing is lawful, fair, transparent. Our processing activities have lawful grounds. We always consider your rights before processing personal data. We will provide you information regarding processing upon request.
2. Processing is limited to the purpose. Our processing activities fit the purpose for which personal data was gathered.
3. Processing is done with minimal data. We only gather and process the minimal amount of personal data required for any purpose.
4. Processing is limited with a time period. We will not store your personal data for longer than needed.
5. We will do our best to ensure the accuracy of data.
6. We will do our best to ensure the integrity and confidentiality of data.

SECTION 3 – Data Subject’s Rights

The Data Subject has the following rights:

1. Right to information – You have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
2. Right to access – You have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
3. Right to rectification – You have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
4. Right to erasure – In certain circumstances you can request for your Personal Data to be erased from our records.
5. Right to restrict processing – Where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
6. Right to object to processing – In certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
7. Right to object to automated Processing – You have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
8. Right to data portability – You have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
9. Right to lodge a complaint – In the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
10. Right to withdraw consent – You have the right withdraw any given consent for Processing of your Personal Data.

Californial Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once per year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

SECTION 4 – Information Collection, Use, and Sharing

We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contact from you. We will never sell or rent this information to anyone. We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request, e.g., to inquire about our products and services.

As part of the process in downloading Zunesis information and in enrolling in any Zunesis giveaway, you will be asked to provide an e-mail address and other contact information, as appropriate. This information may or may not be necessary, depending upon the action being taken. In some instances Zunesis may require an e-mail address for enrollment into a promotional agenda. In all other instances, an opt-out option will be offered.

We process your Personal Data in order to fulfill obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than 13 months.

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
• Legitimate Interests: We may process your data when it is reasonable necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order ora subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

SECTION 5 – Consent

We use your Personal Data on legitimate grounds and/or with your Consent. When you provide us with personal information to contact you, we imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, such as marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

You have the right to request copies of any information we hold about you at any time. You also have the right to request that we modify, update or delete any such information. If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at privacy@zunesis.com.

SECTION 6 – Disclosure

We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.

SECTION 7 – Third-Party Services

Zunesis will not sell or release identifiable visitor information to any third party without your permission and will limit disclosure of information to the following, where we believe in good faith that it is required to do so in response to a Subpoena or other legal process; where reasonably required to do so in order to maintain, update or otherwise implement Zunesis data security measures, equipment, technical operations, etc.; or where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce Strategic Development Partner’s rights.

Zunesis makes all efforts to protect the confidentiality of all visitors and will never knowingly allow access to this information by any third party. We have made a significant investment in our server, database, backup and firewall technologies to protect information assets. These technologies have been installed as part of a complex security architecture and protocol.

When you click on links on our website, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements. Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy.

SECTION 8 – Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our website is at your own risk. You should only access the services within a secure environment.

Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.

If you have an account with us, note that you have to keep your username and password secret.

SECTION 9 – Cookies

In addition to information provided by visitors to our web site, Zunesis monitors incoming and outgoing web traffic data for diagnosis of server problems for web administration purposes and uses this data to collect general demographic information about all visitors to our site. This information allows us to ensure that we provide the most desired information to our visitors. As an important part of providing quality service, Zunesis uses cookies to store and track information.

A cookie is a small amount of data that is sent to your browser from a Web server and stored on your computer’s hard drive. By modifying your browser preferences, you have the choice to accept all cookies, or be notified when a cookie is set, or to reject all cookies. Zunesis will access only those cookies that we have generated.

We use cookies for the following purposes:

1. Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
2. Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalized features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
3. Analytics cookies – these cookies are used to track the use and performance of our website and services

Some of our business partners may use cookies on our site (e.g., advertisers). However, we have no access to or control over these cookies.

You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.

Our website uses Google Analytics, a service which transmits website traffic data to Google servers. Google Analytics does not identify with individual users or associate your IP Address with any other information or data stored by Google. We use data and information provided by Google Analytics to help us understand website traffic and web page usage.

You can opt out of Google Analytics using this browser add-on: https://tools.google.com/dlpage/gaoptout/

You can opt out of data collection services for the purposes of interest based advertising using the DAA opt-out program (http://www.aboutads.info/choices/) or the NAI opt-out program (http://www.networkadvertising.org/choices/)
For EU/EAA users, you can use the following opt-out program (http://www.networkadvertising.org/choices/)

SECTION 10 – Age of Consent

The privacy of children online is of the utmost importance to us. Zunesis Solutions’ Web site is a general audience site and is not directed to, or intended for, children under the age of 16. In the event that you suspect Zunesis has any information about a visitor under the age of 16, please contact us immediately at privacy@zunesis.com so all information can be deleted from our records.

SECTION 11 – Notification of Changes

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

SECTION 12 – Terminating, Reviewing and Modifying Visitor Information

You may choose at any time to terminate, review or modify all information stored by Zunesis by contacting us at privacy@zunesis.com

SECTION 13 - Policy Changes

Zunesis reserves the right to change this policy at any time. Please check this page periodically for changes. Your continued participation in Zunesis offers following the posting of changes to these terms will mean that you accept those changes. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any party.

If you have any questions about this privacy statement, or feel that your privacy has been compromised, please contact us at privacy@zunesis.com

Last modification was made April 11th, 2019.

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