1.1. Law – Personal Data Protection Act of the Republic of Estonia, EU Directive 2002/58 on Privacy and Electronic Communications, including all alterations, amendments, revisions of the mentioned documents as well as any other applicable law.
1.2. Zonto Services — materials and facilities that User gains access to by means of the Website and Applications based on Zonto Services Agreement. All issues regarding usage of Zonto Services that are not stipulated by this Policy are governed by Zonto Services Agreement, which is available at https://zonto.world/rules/
1.3. Personal Data means all data in accordance with the definition below that are referred to the User and enable identify the User based on such data, or on such data and other information that the Company has already possess or will possess and which include any expression of opinion about a User or any intention of the Company or any parties concerning the User.
1.4. Processing of Personal Data (“Data Processing”) means operation or set of the operations executed regarding personal data in an automated or another way, including collection, recording, arrangement, storing, adaptation, modification, restoration, synchronization, use, disclosure by transferring, distribution or other submission way, sorting or linking, blocking, cancellation or destruction.
1.5. Sensitive personal data means personal data consisting of information as to political and religious opinions and worldview convictions (excluding data on membership in legally registered private legal entities); data relating to the racial or ethnic origin; the physical or mental health or condition; origin data; biometric data (first of all finger and palm prints, iris image and genetic data ); data on sexual habits, trade union membership; any offence commitment or its victim prior to the public proceeding or sentence of the court or the disposal of such proceedings.
2. GENERAL PROVISIONS
2.1.4. By using Zonto Services, you agree with the following:
2.3. According to the general rules, the Company doesn’t verify the personal data submitted by the User. However, in the cases referred to in by Agreements on Individual Zonto Services, a User is obliged to provide validation of the submitted personal data.
3. USERS’ DATA CONTENT WHICH THE COMPANY OBTAINS AND PROCESSES
3.1. This Policy is applicable to the following personal data types:
3.1.1. Users’ Personal data about themselves that is voluntary published upon registration, including personal data, to which User gives access for the Company through websites or services of the third persons or personal data that Users post during the usage of Zonto Services. To the personal data which is obtained in such a way may include, for example, name, surname, image, phone number and/or email address of a User. Information that is a mandatory for submission within Zonto Services, or individual features is specially marked. The additional information is submitted at the discretion of a User.
3.1.2. Data that is automatically transmitted by Zonto Services within the use by means of software installed on the User’s device including IP-address, individual network number of the device (MAC-address, device ID), electronic serial number (IMEI, MEID), advertising identifier Android (Google AID), data from cookies, information regarding browser, operating system, access time, search requests, device location and movement data.
3.1.3. Data that is additionally submitted by the Users on Company’s request in order to fulfill Company’s obligations towards Users regarding usage of Zonto Services.
3.1.4. Pictures posted by the Users of the Services and brought to the Users’ notices along with Zonto Software including the usage of API services.
3.1.5. Other information about Users, which collection and/or processing is stipulated by Agreements on Individual Zonto Services and/or Code of Service by using Individual Zonto Services.
4. USER’S DATA COLLECTION AND PROCESSING PURPOSES
4.1. The Company collects and processes only that Users’ data, including personal data, which is required in order to fulfill obligations of the Company according provision of Zonto Services.
4.2. The Company may use personal data of the Users for the following purposes:
4.2.1. to identify the party within agreements between the User and the Company or between Users on the condition of mutual use of Zonto Services that involve the transfer of personal data;
4.2.2. to provide services to the Users through the use of Zonto Services and future improvement of Zonto Services, development of new services and facilities;
4.2.3. to react to Users’ requests to the support service, to inform Users about functionalities of Zonto Services, to forward requests on the usage of Zonto Services;
4.2.4. to meet marketing targets, to make statistical and other analyses based on de-identified data.
5. USER’S DATA PROCESSING
5.1. Personal data of the Users are stored and processed according to the current legislation.
5.2. Personal data of the Users are not transmitted to any third persons except in the following situations:
5.2.1. The User directly expressed his/her agreement to such operations.
5.2.2. Data transmission is required to provide functioning of Zonto Services and/or individual features of Zonto Services, and implementation of software developed by partners and other software of Zonto Services.
5.2.3. The transmission is provided by applicable law.
5.2.4. In order to provide security of the rights and legal interests of the Company and/or the third persons in cases when a User violates conditions of the Agreements on Individual Zonto Services or it is necessary to process data to secure vital interests of a User.
5.2.6. While using Zonto Services a User agrees that certain information that the User publishes by means of Zonto Services can be accessible to the other Users on websites directly placed on the domain where Zonto Services are placed and its subdomain as well as through the transmission by various technical facilities, with a link to the original source (by emailing, RSS transmission, API services and etc.), in particular, the information about name, surname that a User has indicated in Personal Account, pictures that a User has added to the Personal Account as well as the link provided by the User to his/her personal pages that is accessible to all other Users of Zonto Services.
5.4. Collection and processing of sensitive personal data are forbidden unless otherwise provided by the applicable law.
6. RIGHTS OF THE USERS
6.1. The Users have right to:
6.1.1. on their own will to change, complete their data in own Personal Account on the Website of the Company or ask Administration to provide clarifications of such data;
6.1.2. to block own data submitted in the Personal Account on the Website of the Company or ask the Administration to block data. At that the delete of the profile can cause unavailability of some Zonto Services;
6.1.3. to delete or ask the Administration to delete personal data of a User if such data is incomplete or inappropriate considering data processing purpose or if the record, disclosure or storing of such data is forbidden or if it has been stored longer than needed.
6.1.4. on request get information from the Company regarding processing personal data and reject processing of the personal data referred to the User in a certain situation at any time where legally permitted.
7. USER DATA SECURITY MEASURES
7.1. The Company takes all reasonable and appropriate, arrangement and technical measures to protect personal data of the Users from unauthorized or random access to them, deletion, alteration, blocking and dissemination as well as other abuses against them. These measures include an internal check of the collection process, storing and processing of data and security measures including appropriate coding and measures to provide for the physical security of data from unauthorized access to the systems where personal data are stored.
7.2. Upon processing of personal data of the Users, the Company acts in accordance with the Law.
8. CONCLUDING PROVISIONS
8.2. Users can get acquainted with the list of partners on Zonto’s website at https://zonto.world/partners
8.3. Users have right to send requests, offers or questions to the Company relating to this Policy to the Zonto support service (email@example.com), or mail to Peterburi tee 47, Tallinn, Estonia, 11415.
8.4. The current version of this Policy is placed on the Company’s website and available on the Internet at https://zonto.world/rules/privacy/.