Applicable from: June 12, 2015
For information about our privacy practices related to data from children, please see “Special Note About Children’s Privacy” below.
1. HOW WE COLLECT YOUR DATA
Likely situations when you make personal data available to ZEN include, but are not limited to: (i) by using ZEN’s mobile apps or visiting our websites, (ii) registration for ZEN Services, contests and special events; (iii) accessing ZEN Services using a third party ID, such as social networking sites or gaming services; (iv) subscribing to newsletters; (v) purchasing a product or services through ZEN’s online stores or within the app (or “in-app purchase”); (vi) using “tell a friend,” "email this page," or other similar features; (vii) opening a ZEN Account; (viii) requesting technical support; and (ix) otherwise through use of ZEN Services where personal data is required for use and/or participation.
The data we process on you may include, but is not limited to: email address, device ID, and IP-address.
ZEN may supplement your data with data received from third parties in connection with demographic, advertisement, market and other analytics surveys or services.
2. AD-SERVING TECHNOLOGY
ZEN reserves the right to use and disclose the collected, non-personal data for purposes of advertising by ZEN or ZEN’s partners and contractors. ZEN may employ third party ad-serving technologies that use certain methods to collect information as a result of ad serving through ZEN Services.
ZEN may display to you behaviorally targeted advertising. If you wish to “opt out” of certain targeted advertising, please visit http://www.youradchoices.com and/or www.networkadvertising.org. Please note that the links above may not reach all ZEN’s advertising partners and certain behaviorally targeted advertising may still be displayed to you. If you want to be certain that no behaviorally targeted advertisements are displayed to you, please do not use or access the ZEN Services.
Please note that if you “opt out” it does not mean that you will no longer receive advertising. It just means that the advertising you see displayed will not be customized to you and your interests and may be less relevant to you.
Some services may include the use of in-game advertisements or brand placement. Such ads or sponsorships will be noted as such within the services.
3. LOCATION DATA
To the extent ZEN makes location enabled ZEN Services available and you use such ZEN Services, ZEN may collect and process your location data to provide location related ZEN Services and advertisements. For example, some add-ons or offers may be available at dedicated locations. The location data is processed and stored only for the duration that is required for the provision of the location related ZEN Services.
ZEN may use, depending on the service (1)IP-based location based on the IP address presented by the end-user, (2) fine geo-location data based on coordinates obtained from a mobile device’s GPS radio, or (3) coarse, network-based geo-location data based on proximity of network towers or the location of Wi-Fi networks.
ZEN uses your information to perform its own analytics and to enable analytics provided by third parties. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving products and services, personalizing content, providing advertising, and making recommendations. ZEN may also use third-parties in order to develop and analyze use of the ZEN Services.
If you choose to use ZEN’s “tell a friend” or a similar service about ZEN Services or order a gift certificate for your friend, ZEN may store your friend's name and contact details that you provide to ZEN.
Please note that certain features of the ZEN Services may be able to connect to your social networking sites to obtain additional information about you. In such cases, ZEN may be able to collect certain information from your social networking profile when your social networking site permits it, and when you consent to allow your social networking site to make that information available to ZEN. This information may include, but is not limited to, your name, profile picture, gender, user ID, email address, your country, your language, your time zone, the organizations and links on your profile page, the names and profile pictures of your social networking site “friends” and other information you have included in your social networking site profile. ZEN may associate and/or combine as well as use information collected by ZEN and/or obtained through such social networking sites.
6. DISCLOSURE AND TRANSFER OF PERSONAL DATA
ZEN may use third parties to collect and process personal data on ZEN’s behalf and in according to ZEN’s instructions. ZEN is not liable for the acts and omissions of these third parties, except as provided by mandatory law.
7. DATA RETENTION AND CORRECTNESS
Please note that some data may be further retained if necessary to resolve disputes, enforce ZEN user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of ZEN Services.
8. COOKIES, BEACONS AND TRACKING
The ZEN Services may use “cookies” and other technologies such as pixel tags, local shared objects, hardware-based device identifiers, Operating System-based identifiers, clear GIFs and web beacons. ZEN treats information collected by cookies and similar technologies as non-personal data.
Cookies: A “cookie” is a small file stored by your browser when told to do so by a website. Typically websites place a number of different cookies on an end-user’s machine. Some of the cookies are “1st Party”, from the website itself, and others are “3rd party”, belonging to advertising and analytics entities or social networks. ZEN’s cookies typically do not include personal data and are used to quickly identify your device and to “remember” your browser during subsequent visits for purposes of functionality, preferences, and website performance. You can disable cookies or set your browser to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the ZEN Services.
Flash cookies & HTML5: ZEN may also use Flash cookies (local shared objects) and HTML5 local storage. Flash cookies are small files similar to browser cookies, but which are not stored in the browser and can also be used to remember your settings, to personalize the look and feel of the ZEN Services, or for advertising and analytics. You may prevent Flash cookies from being stored by following the instructions provided by Adobe at http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
Web Beacons and pixel tags: A “web beacon” or a “pixel tag” is an electronic image (often not visible to the end-user) that allows ZEN to count users who have visited certain pages or viewed certain advertisements. Additionally, e-mails and other electronic communications ZEN sends to you may contain pixel tags that enable ZEN to track your usage of the communication, including whether the communication was opened and/or what links were followed, if any.
9. THIRD PARTY TERMS AND CONDITIONS
Please note that your access to and use of the ZEN Services may be subject to certain third party terms and conditions and ZEN is not liable for any such third parties’ use of your personal data.
Please note that in accordance with the valid license agreements concluded by ZEN in some cases ZEN may be obliged to share with its licensors all and any user data (including personal data) that ZEN collects through any of the ZEN Services using the license provided by the licensor in the same form and format as such user data is actually collected.
Certain ZEN Services that ZEN may offer, such as multiplayer gaming, social networking and gaming console services, may use third party services to provide authentication for the ZEN Services with a gaming console ID, social networking ID, or gaming network account. In connection with such use, certain personally identifiable user and/or membership data may be transferred automatically to and from ZEN.
ZEN follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in ZEN’s possession.
You may choose to disclose data about yourself in the course of contributing user generated content to the ZEN Services.
Any data that you disclose in any of these forums, blogs, chats or the like will become public information, and there is no expectation of privacy or confidentiality with respect to that data.
12. SPECIAL NOTE ABOUT CHILDREN’S PRIVACY
ZEN does not knowingly collect personal information from children under 13 years of age. If ZEN learns that ZEN has inadvertently gathered personal data from children under 13 years of age, ZEN will take reasonable measures to promptly delete such personal data from ZEN’s records.
ZEN understands the need to provide extra privacy protections to users who are children. To that end, features and services such as social networking plug-ins, behaviorally targeted advertising, and collection of data for the purpose of building user profiles are not available to users under 13. ZEN also does not allow our third party partners who engage in such practices to access personally identifiable data from users under 13.
ZEN and its partners do collect non-personally identifiable data from children. This includes, for example, collection of IP-based geolocation data to ensure that the product, service or features served comply with applicable laws of that nation.
13. FURTHER INFORMATION
ZEN makes good faith efforts to enable you to review, update or correct your personal data in ZEN’s possession.
ZEN will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request.