ZFFR Digital, LLC Privacy Policy

 ZFFR Digital, LLC has created this statement (this “Privacy Policy”) to provide you with information about ZFFR DIGITAL, LLC ’s policies and practices regarding our handling of personal information that we collect: (1) when you use, access, download, install or otherwise interact with any of our web sites, mobile applications, emails, applications, games, products or services (including any we make available via third-party platforms or sites, such as social media platforms); (2) when you participate in our loyalty programs, competitions, promotions or surveys; (3) when you interact with us, including customer services ((1) – (3), collectively, “Services”); or (4) when we receive information from third parties.  We strongly urge you to review this Privacy Policy in its entirety. Your use of the Services constitutes acceptance of this Privacy Policy and any other applicable terms.

For those who reside in California, please see the end of this Privacy Policy for additional information regarding our practices.

Our Collection of Your Information

We may collect the following categories of personal information related to you:

  • identifiers, such as your name, e-mail address, phone number, and postal address;

  • demographics, such as your gender, income level, or age;

  • online activity information, such as your Internet Protocol (“IP”) address or browsing history;

  • location information that you provide or that we collect via your device, subject to your settings;

  • inferences regarding preferences or other characteristics;

  • audiovisual information, such as CCTV, recordings of interactions with call centers, and identification pictures for verifying age or identity.

We collect such information from a variety of sources, including:

From You: We collect information that you submit to us. For example, when you register to receive information or Services, or use the Services, we will collect any information you voluntarily provide. We may request additional information to support your use of the Services, such as a profile picture, username, password or identification. We also collect any information that you voluntarily enter into any postings, comments or forums within the Services, including any messages you send to other users of the Services. If you send an e-mail to us, we will collect your e-mail address and the full content of your e-mail, including attached files and other information you choose to provide to us.

From Your Devices: When you use or interact with our online Services, we may collect information about the devices you use to access the Services, including hardware model, operating system and version, IP address and other unique device identifiers, mobile network information and information about the device’s interaction with our Services.  We also collect information about how you use our Services, including your access times, browser types and language.  To collect this information, we use cookies, web beacons and other similar technologies. To learn more about how we automatically receive and record information when you interact with the online Services, please see the “Cookies and Similar Technologies” section below.

This Privacy Policy covers only how we use information collected via cookies; it does not cover the use of such information by third parties.

We may collect different types of information about your location, including general information, such as the city, state and/or zip code associated with your IP address, and, if you consent, more specific location information that is provided through GPS functionality on mobile devices used to access the Services. We may use such location information to customize the Services, including advertising that is presented to you. For example, if you provide a ZIP code that indicates that you live in New York, the Services may be customized with New York-specific information, features and advertisements. In order to create such customizations, your location information may be passed along to our agents, vendors or advertisers.

Social Media Platforms and Other Third Parties: We may obtain information about you or your use of the Services from third parties, such as our web hosting providers, analytics providers, advertisers, social media platforms and other consumers. You may give us permission to access your information from services offered by third parties, including social media platforms. The information we obtain from such third-party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies, so be sure to check those policies and to adjust your settings to meet your preferences. When you access the Services through social media networks and other third-party platforms, you are authorizing ZFFR DIGITAL, LLC  to collect, store and use such information and content in accordance with this Privacy Policy. Please keep in mind that any information provided to us by a third party may also be subject to that third party’s privacy policy.  When other customers buy you a gift, they may provide us with your name, email address or other personal information.

Our Use and Disclosure of Your Information

As a general matter we seek to use information we collect to enhance the experience of our customers and operate our business. We and our partners and authorized service providers may use this information in a number of ways, including:

  • to furnish you with products or services you have requested;

  • to administer competitions and promotions that we may offer;

  • to verify identity or enforce age restrictions related to our Services;

  • to send you communications regarding products, services, advertising, upcoming events, special offers or promotions from ZFFR Digital, LLC or our partners;

  • to learn about your interests and those of other consumers;

  • to assist us and our partners in marketing and advertising our products and services and those of other businesses;

  • to improve the content and functionality of our Services;

  • to learn about how you interact with and use the Services, including by linking your activity across the devices you may use;

  • to customize the content of communications and advertisements you receive from us and our trusted partners;

  • to exercise and defend our legal rights;

  • to report incidents regarding the health or safety of our customers or employees;

  • as required by law, such as to comply with a subpoena or similar legal process;

  • when we believe in good faith that use and/or disclosure is necessary to protect our rights or the rights of you or others, protect your safety or the safety of others, investigate fraud, infringement or misuse, or respond to a government request; and

  • if ZFFR Digital, LLC is involved in a merger, acquisition or sale of all or a portion of its assets.

We may disclose information in the following circumstances:

With your consent: We may share or disclose your information if you ask or authorize us to do so.

Among group companies: We may share your information with our affiliated and subsidiary companies and joint venture partners for the purposes of processing, analyzing or storing your information or otherwise as needed to provide the Services to you or achieve other purposes for which we collect information, in each case consistent with the terms of this Privacy Policy.

With service providers: We engage service providers to perform a variety of services and functions for us, such as storing data, transmitting emails, delivering ads or marketing communications, hosting events, and managing digital content. We may share your information with such service providers subject to confidentiality obligations consistent with this Privacy Policy and on the condition that the service providers use your information only on our behalf and pursuant to our instructions.

To comply with legal requirements and to protect you, us, and others: Notwithstanding anything to the contrary in this Privacy Policy, we reserve the right to retain and disclose your information at our discretion if we believe in good faith that such retention and disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas, warrants or similar process served on us; (b) protect and defend our rights or property, you, or third parties; or (c) ensure the safety and security of our Services, systems and customers and of third parties.

In connection with a business transfer: In the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization or sale of all or a portion of our assets, your information may be sold or transferred as part of that transaction. You acknowledge that such transfers may occur and are permitted by this Privacy Policy and that the new entity may continue to process your information as set forth in this Privacy Policy.

For operational purposes:  We may share personal information with our professional advisers (for example: lawyers, accountants and insurance brokers), payment processors, and other third parties that support our business operations.

If the information has been aggregated, de-identified or otherwise does not identify you personally: We may share or disclose information that has been aggregated or de-identified or otherwise does not identify you or information that you choose to make public, such as your public user profile information. This Privacy Policy does not limit our use or disclosure of de-identified information (i.e., information from which your name and any other personally identifying information has been removed) in any way, and we reserve the right to use and disclose such information to our partners, advertisers and other third parties at our discretion.

If you do not agree or do not consent to the disclosure of your information in any manner described above, you should not use the Services or interact with us.

We disclose the following categories of personal information for the operational business purposes discussed above:

  • identifiers;

  • demographics;

  • online activity information;

  • location information;

  • inferences regarding preferences or other characteristics; and

  • audiovisual information.

We disclose certain personal information in exchange for services, insights or other valuable consideration.  California law treats such sharing as a “sale” even if no money is exchanged. These disclosures may involve:

  • identifiers;

  • demographics;

  • online activity information;

  • location information; and

  • inferences regarding preferences or other characteristics.

Text Messaging

By opting in to receive text messages on your mobile device, you consent to telemarketing text messages at the applicable phone number, including Short Message Service (SMS) messages. By opting in, you accept and agree to be bound by this Privacy Policy and the ZFFR Digital, LLC SMS Terms and Conditions, which can be viewed here.

Children's Guidelines

ZFFR Digital, LLC does not target the online Services to children under 13 years old. If you are under the age of 13 you may use our online Services only with the consent and under the supervision of a parent or guardian. Please note that our online Services may contain links to content providers that collect information from children under the age of 13. We have no control over such content providers and are not responsible for the privacy practices or the content of other web sites or applications. Because the Internet offers open access to a wide range of information, it is important that parents supervise content, e-mail and chat sessions. If you become aware that your child has provided us with information without your consent, please contact us at privacy@zffrdigital.com.

Cookies and Similar Technologies

Our online Services use cookies (including HTTP cookies and flash cookies), web beacons, and pixel tags for many purposes, including to keep track of your favorite locations, deliver content specific to your interests, save your password so you do not have to re-enter it each time you visit our Services, learn about how you interact with the Services, and deliver targeted advertising. Cookies are lines of text that are transmitted to your web browser when you click on a Service. They provide a way for a server to recall a previous request or previous registration so that information does not have to be re-entered. Your browser stores the information on your hard drive and when you return to that Service later, the cookie is transmitted back only to the servers that originally sent it to you. A cookie does not collect or keep your name or other information that directly identifies you, such as phone number or address; however, we may link the information obtained through cookies to other personally identifying information to give us a better understanding of your preferences and provide a more meaningful experience to you through our Services. You can configure your browser to alert you when a site is attempting to send you a cookie. You can decline the collection of cookies in most browsers. If you set your browser to decline cookies, some features of the Services may not work properly. Consult your browser's “Help” function for more information. To learn more about cookies, visit http://allaboutcookies.org/.

We may use authorized third-party service providers to provide us with analytical data about your use of the Services. We may deploy devices, such as cookies, that enable those third parties to collect and aggregate usage information and report it back to us. We and our partners may also use third-party vendors, such as Google Display Advertising, to support our marketing efforts and those of our partners. ZFFR Digital, LLC, our partners, and these third-party vendors use first-party cookies (such as the Google Analytics cookie), third-party cookies (such as the DoubleClick cookie), and other web beacons and pixel tags together to inform, optimize, and serve ads across the internet. For more information on Google Analytics, visit https://www.google.com/policies/privacy/partners/. We and our partners may combine the information we collect with other information about you to show you potentially relevant and useful ads. You can learn more about targeted advertising and control the ads you see at http://www.aboutads.info/ and http://optout.networkadvertising.org. Please note that if you opt out of targeted advertising, you may still see other non-targeted ads on our Services and across the web. Additionally, we may still use cookies to optimize our Services and for security purposes. Advertisers, partners and other third parties that serve ads on our Services may also use their own cookies. These cookies collect their own information independent of ZFFR Digital, LLC 's activities. You can disable this cookie capability as described above.

We do not respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how in this Privacy Policy. Visit the following website, www.allaboutdnt.com, for more information on this developing area.

Third-Party Services

The Services may link to or utilize other web sites, mobile applications, applications, games, promotions, loyalty programs, products or services that are related to the Services (such as payment processing services and social networking sites) or that we believe you might find useful and informative. Please be aware, however, that ZFFR Digital, LLC does not endorse or recommend any such web sites, mobile applications, applications, games, promotions, loyalty programs, products or services, and ZFFR Digital, LLC is not responsible for the privacy practices or content of any of the foregoing. We encourage you to review all applicable terms of use and privacy policies before accessing or using any of the foregoing. Remember, the statements in this Privacy Policy apply solely to information collected by ZFFR Digital, LLC.

Security

We maintain safeguards to protect against the loss, misuse and alteration of any user information under our control. Please be aware that the transmission of information over the Internet is not inherently secure, and although we endeavor to provide reasonable security measures, no security systems can prevent all potential security breaches.

Your Choices

You have the choice to opt out of receiving marketing communications from us. You may opt out by e-mailing our customer service department at privacy@zffrdigital.com. Please note that it may take us a few days (but no longer than 10 business days) to update our systems, and during this period you may still receive marketing communications from us. You can also opt out of receiving text messages at any time by texting STOP to {short code} from your mobile device. If you request to opt out of receiving text messages, we may send you a one-time opt-out confirmation text message.  If you would like to update the personal information you have provided to us, please contact us at privacy@zffrdigital.com.  If you would like to contact us regarding this Privacy Policy, please write us at ZFFR Digital, LLC, 192 Lovell Rd Watertown, MA. 02472.

If you are a resident of California, please review the “Additional Information for California Residents” section below for additional information.

Additional Information for California Residents

California law grants its residents certain rights regarding the collection and use of their personal information. Subject to certain limitations, California residents have the right to:

  • Know about the processing of personal information collected in the prior 12 months, including the categories and specific pieces of personal information collected, the purposes for which the personal information is collected and shared, and the categories of parties that may receive personal information.

  • Request the deletion of any personal information we have collected about you. Note that we may retain personal information as permitted by law.

  • Opt out of certain disclosures of personal information for valuable consideration. You may exercise this right here: Do Not Sell My Personal Information.

We will not discriminate against you for exercising the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information. 

If you are a California resident and would like to exercise your rights, please submit your request by emailing us at privacy@zffrdigital.com. Please note that we may require additional information from you in order to honor your request, and there may be circumstances where we will not be able to honor your request. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or for other permitted purposes.

California residents may also request and obtain from us once a year, free of charge, a list of the third parties to which we have disclosed certain “personal information” in the prior calendar year for the third parties’ direct marketing purposes, as well as the type of “personal information” disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to privacy@zffrdigital.com.

Policy Modifications

We reserve the right to change the terms of this Privacy Policy from time to time. We will post any changes here, so please check back periodically. Your use of the Services after any change has been posted constitutes acceptance of the change, though we reserve the right to separately contact you regarding material changes.