ZEEM SOLUTIONS PRIVACY POLICY

Your privacy is important to us

BACKGROUND

In connection with use of its services, including, without limitation, its website, and data collection and analytic services sourced through means other than its website (collectively the “Services”), ZEEM SOLUTIONS INC ("Company," “us,” “we,” and other similar terms) gathers certain information regarding users who utilize the Services. The gathering of information is always reasonable in relation to our business or the purpose for which the Services exists.  We gather information from, and share information with necessary parties with whom or which we have an ongoing business relationship or may need to come into possession of collected data in order to enable, facilitate, or otherwise enhance your experience with the Services, including such uses described below in this Privacy Policy. We take each user’s data privacy seriously, and at all times endeavor to collect, compile, handle, store, and disseminate user data (whether or not personally identifiable, “Collected Data”) in compliance with applicable law, including, as may be applicable to certain users, under the General Data Protection Regulation (the “GDPR”).This Privacy Policy sets forth the manner by which we undertake due care with respect to: (i) protecting Collected Data in accordance with applicable law and practices which we deem proper and commercially reasonably in relation to each form of Collected Data, (ii) protecting the rights of various parties handling, providing, and sharing or receiving Collected Data, such as users, our employees and contractors, and our business partners, (iii) our transparency with respect to the processing, handling, storage, and dissemination of Collected Data, (iv) our measures in respect to protection from data breach and other unauthorized disseminations of Collected Data, and (v) applicable law, including the GDPR generally, with respect to applicable users.


"PERSONAL DATA" DEFINED

"Personal Data" is defined in the GDPR as Collected Data which can be used to directly or indirectly identify the applicable user. As used herein, Personal Data, includes, without limitation, information such as (i) contact data (such as your first and last name, user name or alias, physical street address, city, state, zip code, phone number and email address), (ii) financial data of any kind or nature, (iii) demographic data (such as your zip code and gender), and (iv) other legal data (such as your social security number and other sensitive information) or any number of attributes, which taken together may lead to the identity of you (such as physical, physiological, genetic, mental, economic, cultural or social characteristics). With respect to use of our website, although an Internet Protocol (IP) address can only be used to determine the location of your device within a large radius (on the scale of miles or kilometers), Personal Data, for the purpose of the GDPR may include your IP address, and moreover, cookies in relation to your use of the Services.  Notwithstanding the fact that we may treat certain Collected Data as not being Personal Data, and cannot be used in order to identify a user (“Non-Identifiable Data”), to the extent that the GDPR applies to you, we will always treat information based upon the GDPR’s characterization of Personal Data. For example, the IP or cookies of a user within the United States may be treated as Non-Identifiable Data, while the same attributed may be treated by the GDPR as Personal Data in certain instances. 


INFORMATION COLLECTION AND TRACKING


Using the Services

You can use certain Services without providing your Personal Data. Unless you specifically provide us with Personal Data, we only collect data which is, by its, nature Non-Identifiable Data (and generally anonymized).  We do not collect additional Personal Data without your permission.

We may aggregate Collected Data from the following sources:

  • Registration information which you provide when registering for our services or products offered through the Services. 

  • Information you provide to us in response to our communications. For example, we may request that you provide your e-mail address so that we may send you notifications, alerts, special offers and newsletters.

  • Information that you provide to us through direct marketing campaigns, solicitations, customer service communications and correspondence and general feedback.

  • Information from sources as legally permissible.

  • To the extent applicable and authorized by you in accordance with applicable law, information about you from third parties in connection with any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.


USE OF INFORMATION

We may use information about you for a number of purposes, including:

  • Making solicitations to you based on your auto and fleet requirements;

  • Making available for use, improving, and developing the Services;

  • Determining whether the Services, our products, and/or our services, as applicable, are available in your country;

  • Otherwise providing you with our services, products, and features you elect to use, and as applicable, purchase; 

  • Displaying your historical transaction or appointment information;

  • Providing, maintaining and improving the Services;

  • Developing new products and services; 

  • Delivering the information and support you request, including technical notices, security alerts, and support and administrative messages including to resolve disputes, collect fees, and provide assistance for problems with the Services or your user account;

  • Improving, personalizing, and facilitating your use of the Services;

  • Measuring, tracking, and analyzing trends and usage in connection with your use or the performance of the Services.

  • Communicating with you regarding the Services.

  • Sending you information we think you may find useful or which you have requested from us about our products and services.

  • Conducting surveys and collecting feedback about the Services.

  • Investigating, detecting, preventing, or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited or illegal activities, or to otherwise help protect your account, including to dispute chargebacks on your behalf.

  • Verifying your identity (e.g., through government-issued identification numbers). 

  • Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process; fulfilling any other purpose disclosed to you in.

  • We may share certain of the Collected Data, including Personal Data, with affiliated and non-affiliated third parties, including without limitation in connection with the following: 

  • We sometimes disclose the Collected Data we collect to our affiliated companies for marketing purposes and to enhance our products or services to better suit your needs. When identifying methods of improving our products or services, or if we think a product or service may be of interest to you, we may extend select special offers of goods or services to you. 

  • We sometimes disclose the Collected Data we collect to companies that operate various services for us, such as marketing, distribution, order fulfillment, administrative services, advertising, or certain product functionalities, or who otherwise provide goods or services which may be of interest to you.  If you provide information to us, you are expressly consenting to receiving telephone calls, emails or text messages, or direct mail, from us, or on our behalf, regarding the products and services offered on the Services.  

  • We may share your Collected Data as permitted by law.

  • We may disclose your Personal Data in special cases when we have reason to believe that disclosing this information is necessary: (a) to identify, contact or bring legal action against someone who may be causing injury to or interfering (either intentionally or unintentionally) with: (i) our legal rights or property, (ii) another visitor or anyone else that could be harmed by such activities; or (b) by operation of law or at the request for cooperation from law enforcement or another governmental agency.

  • In the event we go through a business transition, such as a merger, acquisition by another company, reorganization, a divestiture, a sale of all or a portion of our assets, or in the unlikely event of bankruptcy, your Personal Data and any information you provide to us will likely be among the assets transferred, and you hereby consent to such transfer. 


OFFERING YOU CHOICES - MARKETING OPTIONS

You have choices when it comes to learning about our new offers, products or services, as well as those offered by our partners and affiliates. If you do not wish to receive these offers, you may opt out by emailing our Customer Care department at any time at _info@zeemsolutions.com_______________. Alternatively, each marketing e-mail we send to you will include instructions how to opt-out which you may utilize. Please note that you may still receive information from third parties to whom we have disclosed your information prior to the time you opted-out. You should contact each party in the event that you no longer want to receive information from such party. 


SECURITY

We know it is very important to protect the information you share with us. We take appropriate security measures to help safeguard this information from unauthorized access and disclosure. For example, we restrict access to nonpublic personal information about you to our employees who need to have access to such information in order to provide products or services to you, as well as to authorized third parties (as stated above). We maintain physical, electronic, and procedural safeguards designed to protect your Personal Data. 

You should feel confident using our Services. However, no system can be completely secure. Although we take very significant steps to secure your information, there is always a chance that your information will not always remain secure, or our computers or systems are illegally accessed, and the data on them stolen or altered.  You should always take great care in handling and disclosing your personal information. For example, avoid sending personal information through insecure email.  

Please refer to the Federal Trade Commission's website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft. We assume no liability or responsibility to you or to any third party arising out of any loss, misuse, destruction, or alteration of your information. 


ACCESS TO INFORMATION

You have the right to request access to the information we have on you. You can do this by contacting us at_______info@zeemsolutions.com____________________. We will make sure to provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to verify your identity. We will fulfil your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent access request, we may charge you with an administrative fee.


INFORMATION CORRECTION & DELETION

If you believe that the information we have about you is incorrect, you are welcome to contact us so we can update it and keep your data accurate. Any data governed by the GDPR that is no longer needed for the purposes specified herein will be deleted.  If you are a user with rights under the GDPR, if at any point you wish for Company to delete information about you, you may simply contact us and instruct that we delete certain Personal Data, provided, that, such deletion may affect your use of the Services.


PERSONS UNDER THE AGE OF 18 AND ABILITY TO CONSENT

In order to use the Services and/or its products and/or services, you must be at least 18 years of age. The Services are not intended for use by persons under the age of 18 and we are not knowingly soliciting personal information from such persons or sending them requests for non-public personal information.  If we become aware that we have inadvertently received Personal Data directly from someone under the age of 18, we will delete such information from our records. If you are under the age of 18, you must not use our products or services, including sending us any personal information. 


HOW LONG WE RETAIN YOUR INFORMATION

We generally retain your information as long as we determine is reasonable in compliance with applicable law. However, even after you opt-out of any participation in or use of our Services, we may retain copies of Collected Data for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with the Services, to assist with investigations, to enforce our legal interests, or to take any other actions consistent with applicable law.


US STATE PRIVACY RIGHTS

The laws of certain states within the United States law permit residents of such states to request certain details about our disclosure of your Personal Data to third parties for direct marketing purposes during the immediately preceding calendar year. If you are a resident of any such state (including California) and would like to request this information, please contact us at the address listed below.


NOTIFICATION OF CHANGES

We reserve the right to modify, add, alter or otherwise update this Privacy Policy from time to time, so you are encouraged to review this Privacy Policy from time to time. However, please note that until you elect to opt-out of participation in the Services, the current version of this Privacy Policy will apply. 

 

WHEN THIS PRIVACY POLICY APPLIES

This version of the Privacy Policy is effective from October 8, 2018.

 

ACCEPTANCE OF THESE TERMS

By using the Services, you hereby accept all of the terms set forth in our Privacy Policy. If you do not agree to accept all or any portion of such terms, then you are respectfully asked not to use the Services, and to provide an opt-out notice as described herein. Your continued use of the Services following the posting of such modifications, alterations or updates will signify your acceptance thereof. 


CONTACT US

If you wish to exercise any right afforded to you herein or under applicable law, or if you have any additional questions about our collection and storage of data, please contact us at:

Don Peer

info@zeemsolutions.com


If you have any questions or concerns regarding our notice, or if you believe our notice or applicable laws relating to the protection of your Personal Data have not been respected, you may file a complaint with our office listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.


SPECIAL CONSIDERATIONS UNDER THE GDPR

The below table sets forth how we may process data received by a user entitled to the protections of the GDPR.  

 
ReasonRequirements
Contractual necessity
  • Data processed must be necessary for the Services (or the purchase of products or services, as applicable) and defined in an agreement between a user and the Company
Consent
  • Requires a freely given, specific, informed and unambiguous consent by clear affirmative action, including any consent provided in this Privacy Policy
  • Users have a right to withdraw consent, which must be brought to their attention
  • Must be from a user over the age of consent in the applicable jurisdiction, otherwise given by or authorized by a parent / guardian
  • Explicit consent is required for some processing (e.g., special categories of Personal Data)
Legitimate interests
  • If a business or a third party has legitimate interests which are not overridden by a user’s rights or interests
  • Processing must be paused if an individual objects to it
 

“Data controller” and “data processor” are important concepts in understanding a company's responsibilities under the GDPR. Depending on the scenario, a company may be a data controller, data processor or both, and will have specific responsibilities as a result:  A company is a data controller when it has the responsibility of deciding why and how (the “purposes” and “means”) the Personal Data is processed.   

Under the GDPR, data controllers must adopt compliance measures to cover how data is collected, what it's used for and how long it's retained.  They will also need to make sure people can access the data about them.  Data controllers must ensure data processors meet their contractual commitments to process data safely and legally.  This Privacy Policy sets forth and discussed all matters in relation to our activities, if any, as a data controller. 

A company is a data processor when it processes Personal Data on behalf of a data controller. Under the GDPR, data processors have obligations to process data safely and legally.  This Privacy Policy sets forth and discussed all matters in relation to our activities, if any, as a data processor.  

Any transfer of Personal Data outside of the EEA (European Economic Area) must meet certain legal requirements. To the extent we are in receipt of Personal Data being transferred from inside the EEA to any region outside the EEA, we will at all times comply with applicable restrictions.


To the extent that we operate as a data controller and/or processor, our workplace will at all times be cognizant of applicable restrictions, and comply therewith.