Zenapse Privacy Policy

Last modified and effective as of: January 20th, 2025

We have recently updated our Privacy Notice. Please review it carefully to understand how Zenapse processes personal information about you.

Introduction

Zenapse is a software as a service platform for dynamic marketing and customer experience optimization powered by emotional intelligence and the world's first Large Emotion Model (LEM). The platform helps CMOs, CDOs, and CX leaders achieve superior results through human-centric insights, market intelligence, and ethical AI. With a low-code, high-impact solution, Zenapse optimizes marketing strategies to enhance customer acquisition, engagement, and retention.

This Privacy Policy (this "Policy") describes the data protection practices of Zenapse Inc. (collectively with its subsidiaries, "Zenapse," "we," "us," and "our") with respect to the operation of our websites, including Zenapse.com and all other websites and services operated by us that link to this Policy (the "Websites"), as well as our software available at zenapse.com, zenimpact.com, zenimpact.io (the "Platform", together with the Websites, the "Services"), which are owned and operated by Zenapse.

This Policy (together with our Terms of Use and any other documents referenced therein or herein) describes the personal information that we may collect from or about you in the course of providing our Services, and how that information may be used or disclosed by us. This Policy also describes your privacy rights and the choices available to you regarding our use and retention of your personal data. This Policy applies to personal data that Zenapse processes as a controller: it does not apply to information that we may process solely as a service provider to our business customers. It also does not apply to personal information collected on any other company, affiliate, or third-party site, or by any third-party application that may link to or be accessible from our Services.

What Personal Information Does Zenapse Collect and Where Does it Come From?

Zenapse collects and processes personal information from and about Website visitors, business customers using the Zenapse Platform, and individuals who visit a website, use an app, or interact with a device or content where Zenapse Services are in use. Depending on whether you are a business customer, Website visitor, or an individual interacting with sites or content operated by our business customers, we may collect some or all of the following:

• Direct Identifiers: such as your name, email address, phone numbers, and other information that identifies you directly. Please note that Zenapse does not process Direct Identifiers about consumers unless you provide that information directly, for example to exercise one of the privacy choices we offer. Nor does Zenapse use Direct Identifiers about consumers to deliver its Services to our business customers.
• Pseudonymous Identifiers: ncluding device identifiers such as cookies, mobile advertising IDs, advertising IDs, IP Addresses, hashed email addresses or phone numbers, and other alpha-numeric identifiers. Pseudonymous IDs do not, by themselves, identify a particular person, and Zenapse takes steps to ensure that Pseudonymous IDs are not linked to an individual consumer's name or other Direct Identifiers.
• Business Information: which includes information about the businesses that use or might be interested in using Zenapse Services when that information is associated with a specific, identified individual such as an employee.
• Online Activity Information: including information about how you use our Websites and Platform as well as information about what you see and how you interact with content on a site, app, or service operated by our business customers.
• Attribute Data: which includes information about your interests, preferences, demographics, and other inferences that we derive from the personal information described above.
• Customer Commercial Data: which belongs to our business customers and may relate to your interactions with those customers. This information is subject to our customer's privacy policies and is processed by Zenapse on behalf and at the direction of those customers.

Please click here to review a detailed chart showing the categories of personal data processed by Zenapse, and the categories of sources of that data.

Why Does Zenapse Process this Personal Information?

Zenapse processes personal information for a variety of purposes, including:

• To operate our business, manage our contractual relationships, and communicate with and authenticate our business customers;
• Subject to the privacy choices described below, to recognize Pseudonymous IDs over time and across different sites in order to provide and enhance our Services;
• To identify and communicate with businesses that might be interested in using our Services;
• To enhance our understanding of what motivates individual consumers in order to help our customers personalize and optimize the content, including marketing content, they show to individuals interacting with their websites, apps, and advertisements;
• To respond to requests from individuals wishing to access, correct, or delete their personal information or to opt-out of personal data processing by Zenapse;
• To enforce our terms and conditions, prevent, detect, and respond to fraud, security threats, other criminal behavior, and to protect our rights and property and the rights and property of others;
• To comply with applicable law and respond to lawful requests and legal process;
• As needed in an emergency to prevent personal harm; and
• As necessary and appropriate in the context of any corporate transaction including a merger or sale of the company.

Please click here to review a detailed chart showing why we use each category of personal data processed by Zenapse.

With Whom Does Zenapse Disclose, Sell, or Share My Personal Data?

Zenapse may share all of the categories of personal data described above for legitimate business purposes, including with:

• Third parties who provide services to Zenapse, including contractors, service providers, lawyers, auditors, and other professional consultants, who are in each case subject to contracts and/or ethical duties that limit their use of that data to that which is necessary to provide services to us;
• Government authorities, law enforcement, and others as required or permitted by applicable law;
• Others as needed to: prevent, detect, respond to, mitigate, and prosecute malicious, fraudulent, and other criminal activities; protect our rights and property and the rights and property of others; and to prevent personal harm; and
• Prospective or actual purchasers of our company, business, or assets.

In addition, Zenapse may share certain categories of personal data with our business customers, service providers, and advertising partners for commercial purposes in connection with marketing and providing Zenapse Services.

Please click here to review a detailed chart listing (i) the categories of entities to whom Zenapse discloses personal information for a business purpose, and (ii) the categories of entities with whom Zenapse shares personal data for commercial purposes.

How Long Does Zenapse Retain Personal Information?

Zenapse retains personal data only for as long as reasonably necessary to fulfill the purposes we collected it for, including the purposes of providing our Services, satisfying our legal, regulatory, tax, accounting, and reporting requirements, protecting against fraud and abuse, investigating and resolving security incidents, and resolving disputes. To determine the retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, and whether we can accomplish our purposes without the data.

In some cases, you can decide how long we keep your data. For example:

• We retain your profile information, privacy settings, and account-related information until you choose to remove it and/or update it;
• We honor requests to delete personal data, subject to receipt of a verifiable request and specific exceptions recognized in applicable law. For more information on this, please review the “Your Privacy Choices” section below.

Tracking Technologies

When you access our Websites, use our Platform, or interact with third party sites, apps, or devices where Zenapse Services are deployed, we automatically collect information using tracking technologies such as cookies, tracking pixels, web beacons, and JavaScript.

• On the Zenapse Websites, we and our partners use tracking technologies to analyze trends, administer the website, monitor how visitors navigate around the Services, and gather information about our user base as a whole.
• Third parties may collect information about your online activities over time and across different websites or online services when you use our Websites.
• Zenapse also uses tracking technologies to deliver our Services on third party sites, apps, and devices.

For more information about the cookies we use, visit our Cookie Policy. Zenapse offers you various opportunities to control our use of non-essential tracking technologies, as described below and in the Privacy Choice Portal.

Zenapse is a member of the Network Advertising Initiative and honors requests to opt-out of the receipt of targeted advertising submitted through the NAI's Consumer Opt-Out tool available here: https://optout.networkadvertising.org

Your Privacy Choices

Zenapse offers a variety of tools for you to understand and exercise reasonable choices about the personal data we process. Depending on where you live, you may have the right to exercise some or all of the choices we offer to all, in each case subject to a verifiable consumer request and various exemptions under applicable law.

• Right to access. You have the right to ask Zenapse to confirm whether we are collecting or using your personal data and access such personal data. Depending on your state of residence, there may be limits on how often you can request this information. Requests exceeding these limits may incur a service fee or may be denied, in our sole discretion.
• Right to access categories of information (California only). California residents have the right to request that we disclose the following information to you about our collection and use of your personal data over the past 12 months: (1) the categories of personal data we collected about you; (2) the categories of sources for the personal data we collected about you; (3) our business or commercial purpose for collecting or selling that personal data; (4) the categories of third parties with whom we share that personal data; (5) a list of categories of personal data disclosed for a business purpose and the categories of recipients, if any; and (6) a list of categories of personal data sold and/or shared and the categories of recipients, if any.
• Right to data portability. You may have the right to ask for a copy of your personal data in a portable, and where technically feasible, readily usable format that allows you to transmit the data to another entity. For Utah residents, we are not required to provide you with personal information that we did not collect directly from you.
• Right to correct. Depending on your state of residence, you may have the right to ask us to correct inaccurate personal information that Zenapse processes as a controller.
• Right to delete. You may have the right to request that we delete your personal data, subject to certain exceptions. Depending on your state of residence, we may not be required to delete personal information that we did not collect directly from you. You should note that in many situations we must keep some your personal data to comply with our legal obligations, resolve disputes, enforce our agreements, or for another legitimate business purposes.
• Right to opt out of targeted advertising. You have the right to opt out of targeted advertising involving the processing of your personal information by Zenapse. In addition to the methods of exercising this right described below, you can opt out of targeted advertising by clicking on this “Do Not Sell or Share My Personal Information” link.
• Right to opt out of the sale of personal data. You may have the right to opt out of the sale or sharing of your personal information for commercial purposes. In addition to the methods of exercising this right described below, you can opt out of the sale of personal data by clicking on this “Do Not Sell or Share My Personal Information” link.

Please note that these choices apply to personal data that Zenapse processes as a data controller, and not to personal data that Zenapse processes exclusively as a service provider to one of our business customers.

To exercise the rights described above, please submit a verifiable consumer request to us by using our online Privacy Choice Portal or email privacy@zenapse.com, or sending a letter to 55 Post Road, W, Flr e, Westport, CT, 06880. Please note that we may have to verify your identity to make sure you are exercising rights related to your own personal information. Depending on your request, we may also request information about your residency and/or ask you to provide a signed declaration confirming your identity. When submitting a request, please provide sufficient detail so we can properly understand, evaluate, and respond to it.

In some circumstances, you may appoint an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you gave the authorized agent permission to submit a request on your behalf. In such cases, you must verify your identity directly with us and provide a copy of the signed permission you have given to the authorized agent to submit the request on your behalf.

You may appeal our decision regarding an exercise of your consumer rights by emailing us at privacy@zenapse.com, or sending a letter to 55 Post Road, W, Flr e, Westport, CT, 06880. Please include your name, your state of residence, and a brief description of your appeal. Upon receipt, we will respond in writing within 45 days, informing you of our response to the appeal and explaining the reasons for our decision. Where required by law, we will also provide you a method through which you can submit a complaint to your state attorney general.

Zenapse is a member of the Network Advertising Initiative and honors requests to opt-out of the receipt of targeted advertising submitted through the NAI's Consumer Opt-Out tools available here: https://optout.networkadvertising.org.

We do not discriminate or retaliate against you in any manner prohibited by applicable law for exercising your privacy rights and/or the choices we offer.

Additional Information for Residents of California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia.

If you live in one of these jurisdictions, the choices described above - including rights related to access, correction, and deletion of your personal data, rights to opt out of targeted advertising and/or sale of your personal data - may be exercised as a matter of legal right, subject to a verifiable consumer request and specific exceptions under applicable law. These rights and how to exercise them are explained in detail in the “Your Privacy Choices” section above.

Security

We maintain physical, electronic and procedural safeguards to help guard your personal information. We restrict access to personal information to those persons who need to know that information to provide products or services to you and any persons you have authorized to have access to such information. While we strive to protect your personal information, we cannot guaranty the security of any information you transmit to us.

Cross-Border Transfers

The Zenapse Services and the servers used to process personal information are operated in the United States and intended for use in the United States. If you are located outside of the United States and visit Zenapse Websites or websites, apps, devices, or otherwise interact with content where Zenapse Services are deployed, please be aware that your personal information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Services, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

Minors

Our Services are not intended for children under 18 years of age and minors may not provide any personal information on or through our Services. We do not knowingly collect personal information from anyone under 18. If you are under 18, please do not send any information about yourself to us, including your name, address, phone number(s) and email address. In the event that we learn that we have collected personal information from a person under the age of 18, we will delete that information. If you believe that we might have any information from or about a person under the age of 18, please contact us at privacy@zenapse.com.

Third Party Content and Links

From time to time our Websites may contain links to third party websites, which are governed by the privacy policies of those sites, and not the Zenapse Privacy Policy. We are not responsible for any data collected or used by these third-party sites, and we encourage you to review the privacy policy on any website you visit.

Changes to Our Privacy Policy

We may update this Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Websites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

To ask questions or send comments about this Policy and our privacy practices, you may email privacy@zenapse.com or send mail to: 55 Post Rd, W, Flr 2, Westport, CT, 06880.