California Resident Privacy Notice

Last Updated: December 28, 2019

Introduction

This California Resident Privacy Notice supplements the information contained in Zenvoy’s (“Zenvoy”, “Zenvoy, LLC”, “our”, “us” or “we”, “community”, “communities”) Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA).

Information We Collect

We collect personal information of consumers. “Personal information” as defined by Cal. Civ. Code Section 1798.80 (e) means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.

We also collect information on consumers’ interaction with our website.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples
Personal information listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)
“Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
A name, signature, address, telephone number, email address, employment, position, employment history, bank account number, credit card number, debit card number or any other financial information
Protected classification characteristics Age (40 years or older), gender
Professional or employment-related information Employment, company name and address, experience, skills and services, bio, networking targets, commercial video and attachments (brochure, cv)
Commercial information Records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.
Geolocation data Physical location or movements.
The following information is required in order to sign up for Zenvoy’s services: Full name, age, position, work experience (years), company name and address, email, skills and services, networking targets.

We obtain the categories of personal information listed above from the following categories of sources:

  • From our clients or their agents for which you have engaged in a business contract.
  • From activity on our website (www.zenvoy.com). For example, from submissions through our website portal or website usage details collected automatically.
  • From service providers.
  • From third parties that interact with us in connection with the services we perform

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • Address you.
  • Create introductions between you and members in your community.
  • Send emails related to our service and product.
  • Display relevant ads.
  • Enable you to log in and perform functions such as editing your profile, preferences and resetting your password.
  • To improve our website and present its contents to you.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • If we transfer the assets of the business whether as a part of a sale of all our assets or part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred.

Note that with the exception of the public profile photo, all information is retained within the walled-garden community.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • California Customer Records personal information categories.
  • Protected class characteristics
  • Professional employment related information.
  • Commercial information
  • Internet or other similar network activity
  • Geolocation data

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Right to Know About Personal Information Collected, Disclosed or Sold.

Personal Information Collected

You have the right to request that we disclose the personal information we collect, use, disclose and sell over the past 12 months. Once we receive and verify your request, we will disclose to you the purpose for which the information was collected, the categories of third parties with who the business shares personal information.

Requests to Delete Personal Information

You have the right to request that we delete any of your personal information that we collected from you and retained. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) within 30 days your personal information from our records, unless an exception applies. (NOTE: There are encrypted backups of data that take 30 days to decay in the backup cycle, after which they are deleted)

Exceptions to Deletion:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Comply with a legal obligation.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for such activities.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided by law.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

In the event of a deletion request, we keep an immutable record of:

  • The date the terms were accepted
  • Any date data was requested
  • The date the person requested deletion, together with the email address(*)

(*) This record is maintained for legal reasons and also to prevent any communications inadvertently being sent to the person requesting the deletion.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights.

You have a right not to receive discriminatory treatment by the business for the exercise of the privacy rights conferred by the CCPA. We will not deny you goods or services or charge different prices or rates for goods or services.

Authorized Agent

You can designate an authorized agent to make a request under the CCPA on your behalf.

Exercising Deletion, Non-Discrimination and Authorized Agent Rights.

To exercise the rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at +1 (888) 936-8698 between 7am-3pm (PST), Monday-Friday.
  • Emailing admin@zenvoy.com.

Only you or your authorized agent may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Response to Verifiable Consumer Requests

We will respond to a verifiable consumer request within 45 days of its receipt, however, if we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Special Rules Regarding Minors

Our service does not address anyone under the age of 18 (“Children”)

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification or parental consent, we take steps to remove that information from our servers.

Changes to Our Privacy Notice

We may update this Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page. You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page.

Contact Information

If you have any questions or comments about this Privacy Notice please contact us at:

Phone: +1 (888) 936-8698 between 7am-3pm (PST), Monday-Friday.
Website: www.zenvoy.com
Email: admin@zenvoy.com
Address: Zenvoy, LLC
11693 San Vicente Blvd, Ste #182
Los Angeles, CA 90049 USA

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