UPM – Privacy Policy

ZINFI Technologies, Inc. (We) are committed to protecting and respecting your privacy.

This policy (together with our terms of use at www.zinfi.com/upm-terms-of-use/ (Terms of Use and Privacy Policy) and any other documents referred to on it) sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. This Privacy Policy applies to the personal information and data collected by ZINFI when you interact with our products and services and any other sites or services that link to this Privacy Policy. This includes when you:

• use our product (ZINFI Unified Partner Management – UPM) and services.

ZINFI’s Unified Partner Management solutions enable organizations selling via the channel to integrate the full spectrum of channel partner management activities—from recruitment, onboarding, training, and certification to lead management, co-branded demand generation, sales performance, success, and fulfillment and renewal management. Powered by the efficacy and superior experience of ZINFI’s UPM solutions, any organization can build a high-performing channel and realize increased partner sales return on investment. Contact details of ZINFI Customers, Customer’s Partners, Customer and Partner Users, Customer’s customers, and Partners’ customers are stored in the ZINFI UPM Platform to provide proper access to and support for the ZINFI UPM SaaS application.

This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your, your Partners, your customers, and your Partners’ Customers’ Personal Data. This Privacy Policy also describes your choices and rights concerning your Personal Data, including your rights of access and correction of your Personal Data. For this Privacy Policy, "Personal Data" refers to any information relating to an identified or identifiable individual. If you do not agree with this Privacy Policy, you should not use our products, services, or any other sites or services that link to this Privacy Policy. Using our Product, you accept and consent to the practices described in this Privacy Policy.

ZINFI UPM customers may collect and manage Personal Data when using our product and services, or what we may refer to as the Subscription Service. "Subscription Service" is defined in the ZINFI Customer Terms of Service and means all our web-based applications, tools, and platforms that you have subscribed to under an Order Form or that we otherwise make available to you and are developed, operated, and maintained by us. When you use the Subscription Service, ZINFI processes Personal Data as a processor under the direction of our customers. As Data Controllers, our customers are responsible for complying with any regulations or laws requiring notice and disclosure and obtaining consent before collecting their Partners’/Customers’ Personal Data using the Subscription Service.

We update this Privacy Policy occasionally and encourage you to review it periodically. We will post any changes on this page. If the changes are material, we will provide a more prominent notice by sending you an email notification or, if you subscribe to our ZINFI product and services, through the Notification app in your ZINFI account. Terms not otherwise defined in this Privacy Policy will have the meaning outlined in the ZINFI Customer Terms of Service.

This privacy policy does not apply to any products or services any third party provides directly to you. These products and services are governed by their privacy policies.

For the purpose of the Data Protection Act 1998 (Act), the Data Controller for our Customer is ZINFI Technologies, Inc. of 6200 Stoneridge Mall Road, Suite 300, Pleasanton, CA94588, USA.

ZINFI’s Product – UPM (Unified Partner Management) would act as a Data Controller for the OEM/Client Administrator and OEM Users/Employees and would utilize only business contact details such as Name, business email, and business phone numbers, which would be primarily collected, processed, and housed. ZINFI’s UPM would act as a Data Processor and would not have access to and would only process the client’s partners, partner’s clients, or client’s end clients’ data. Business contact details such as Name, email, and phone numbers would be primarily processed and housed.

Information we collect from you

We will collect and process the following data about you:

• Information you give us. This is information about you and your Partners that you give us by filling in ZINFI UPM forms for our Product or by corresponding with us by phone, e-mail, or otherwise. It includes information you provide when you register to use our Product, subscribe to our service(s), participate in discussion boards or other social media functions related to the Channel Partner Management Ecosystem, report a problem with or via our Portal, and contact our customer service or support number(s) by phone. Your information includes your name, business address, business e-mail address, business phone number, and financial information.
• Information we collect about you. About each of your visits to our ZINFI UPM system and successful login, we will automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, the information by which the accessing device can be identified and tracked, your login information, browser type and version, time zone setting, browser plug-in types and versions and operating system and platform.
• information about your visit and product(s) usage, including the full Uniform Resource Locators (URL), clickstream to, through, and from our UPM System (including date and time), products you viewed or searched for, system page response times, download errors, length of visits to certain pages, system page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the system page and any phone number used to call our customer service or support number(s).
• Information we collect when you use the ZINFI UPM Mobile App. When you access the ZINFI UPM Subscription Service via our mobile applications, we automatically collect information such as your device model and version, operating system, or device identifiers. 
• Information we collect when you use Third-Party Integrations. You may connect third-party integrations to your ZINFI UPM account, which may ask for specific permissions to access data or send information to your ZINFI account. It is your responsibility to review any third-party integrations you authorize. We may collect information about the integrations you use in your ZINFI account.

Any permission(s) granted by you grant these third parties access to your data, which may include (but is not limited to) granting third-party applications access to view, store, and modify your ZINFI account data. We are not responsible for the practices of third-party integrations, so please carefully review the permissions you grant to third-party applications.

• Sub-processors. A sub-processor is a third-party data processor engaged by ZINFI—the Data Processor who has or will have access to or process personal data from customers to provide UPM services. The list of sub-processors includes third-party vendors that support various aspects of our services to our customers, such as cloud services, customer support, reporting, and mailing services. To refer to ZINFI’s list of sub-processors, use the following link – ZINFI List of Sub-processors.

Information We Process on Behalf of Customers When They Use the Subscription Service

Our product, the ZINFI UPM Subscription Service, allows our customers to create and share marketing, sales, and customer service content. When customers use our product, they may collect Personal Data such as first and last name, email address, physical address, phone number, or other information about you. Under our Customer Terms of Service, we call the information our customers submit or collect via the product ‘Customer Data’.

We do not control the content of our customers’ web pages or the types of Personal Data our customers may choose to collect or manage using the ZINFI UPM Subscription Service. We store our customers’ information on our service providers’ servers but process it as a processor under our customers’ instructions and in accordance with our Customer Terms of Service, which prohibit us from using the information except as necessary to provide and improve the Subscription Service and as required by law.

Our customers control and are responsible for correcting, deleting, or updating the information they process using the Subscription Service and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to ZINFI for processing purposes.

How We Use Personal Data

To Communicate with You About the Product and Services

We use the account information you provide to ZINFI when signing up for the Subscription Service and Trends services to send you transactional emails or in-app notifications about billing, account management, and other administrative matters. We may also send you updates regarding our Customer Terms of Service or other legal agreements and communicate with you about security incidents via email or in-app notification.

We use your information to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs.

To Provide the ZINFI UPM Subscription Service

We use your account information and customer data to provide ZINFI products and services. For example, we use your email address to create your user account when signing up for the product. We also use this information to authenticate you when you log in and to provide customer support.

To Improve and Develop Our Product and Services

We collect usage data about how you or your users interact with our ZINFI products and services. We use this data to develop and improve our products and services. For example, we use usage data to assess trends and usage across the product to help us determine what new features or integrations our users may be interested in.

To Secure and Protect our Product and ZINFI Users

We use your account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We use your information to verify user accounts and new product sign-ups and to detect and prevent product abuse. This includes enforcing our Acceptable Use Policy. 

We use log files to provide general statistics regarding your use of the ZINFI Web Portal, including how you use our Portal, what country you are logging in from (for analytics, export control, and regulatory purposes), and to help improve the navigation experience. Your IP addresses are also collected and logged for security and debugging purposes, such as tracking access patterns and investigating security events and incidents. For these purposes, we link this automatically-collected data to other personal data you provide, such as name, business email address, business address, and business phone number.

To Market and Promote the Subscription Service

We use the information you provide to ZINFI to market and promote our products, services, and other offerings. For example, we use the information, like your email or physical address, to send you information or ZINFI content that we think may interest you by post, email, or other means and send you marketing communications relating to our business.

You may opt out of receiving this promotional content by following the instructions in each communication we send or by contacting us at security@zinfitech.com. If you unsubscribe from our marketing lists, we will continue to contact you regarding administrative matters and respond to your requests.

We may also reach out to you via telephone to ask about other ZINFI products or services you may be interested in. If you have a call scheduled with a ZINFI representative, we may record and transcribe the call. You will be notified prior to the call that the call is being recorded, and you will be offered an opportunity to opt-out of having the call recorded.

Where required by law, we will only send marketing communications with your consent. Otherwise, we will market and advertise our products and services on the basis of our legitimate business interests.

We receive information from third-party service providers and other sources, such as third-party providers of business information and publicly available sources. We may receive and use this information from these service providers and other sources in combination with other information we collect through other means described in this Privacy Policy to provide you with updates and an improved Subscription Service, like personalized communications, event promotion, and tailoring the ZINFI UPM product to improve user experience.

Legal Basis for Processing Personal Data

Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will generally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you.

Suppose we ask you to provide personal data to comply with a legal requirement or to sign a contract. In that case, we will make this clear at the relevant time and advise you whether providing your Personal Data is mandatory (as well as of the possible consequences if you do not provide your Personal Data). Similarly, suppose we collect and use your personal data based on our legitimate interests (or those of any third party). In that case, we will inform you soon about those legitimate interests.

How We Transfer Personal Data Internationally

International Transfers within the ZINFI Group

To facilitate our global operations, we may transfer information to other ZINFI Affiliates where we have operations for the purposes described in this policy. Please see the ZINFI List of Sub-processors for a list of ZINFI Affiliates and their locations.

This Privacy Policy will apply even if we transfer Personal Data to other countries. We have taken appropriate safeguards to ensure that your personal data will remain protected wherever it is transferred. When we share the Personal Data of individuals in the European Economic Area ("EEA"), Switzerland, or the United Kingdom ("UK") within and among ZINFI’s Affiliates, we rely upon the Standard Contractual Clauses (approved by the European Commission and Swiss authorities) and UK Addendum to the Standard Contractual Clauses (approved by the UK authorities) where required, as well as additional safeguards where appropriate (such as commercial industry-standard secure encryption methods to protect customer data at rest and in transit, TLS for ZINFI hosted Systems, web application firewall protection, and other appropriate contractual and organizational measures), as described more in detail here.

International Transfers to Third Parties

Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share the Personal Data of individuals in the EEA, Switzerland, or the UK with third parties, we use a variety of legal mechanisms to safeguard the transfer, including the European Commission-approved Data Privacy Framework Standard Contractual Clauses, as well as additional safeguards where appropriate. We use the DPA and the standard contractual clauses for transfers to or from. Please get in touch with us if you need more information about the legal mechanisms we rely on to transfer personal data outside the EEA, Switzerland, Canada, and the UK.

Data Privacy Framework Notice

ZINFI complies with the EU-GDPR (https://www.zinfi.com/gdpr-compliance/), CCPA (https://www.zinfi.com/ccpa-compliance/), EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce (collectively “the Data Privacy Framework”).

You have the right to request access to the Personal Data that we hold about you and request that we correct, amend or delete your Personal Data if it is inaccurate or processed in violation of the DPA (Data Processing Addendum) Principles. We will allow you to opt out where Personal Data we control about you is to be disclosed to an independent third party or used for a purpose materially different from those set out in this Privacy Policy. If you want to exercise any of your rights, please contact us using the details below.

In compliance with the Data Privacy Framework and Data Processing Addendum, ZINFI commits to refer unresolved complaints concerning our handling of personal data received in reliance on the Data Privacy Framework to an alternative dispute resolution provider. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please mail legal@zinfitech.com to file a complaint.

Please note that under certain circumstances, we may be required to disclose your Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

How We Store and Secure Personal Data

Data Storage and Security

We use various security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. All Personal Data is protected using appropriate physical, technical, and organizational measures. For more information on security at ZINFI, please email security@zinfitech.com.

Frequency of the transfer

(e.g., whether the data is transferred one-off or continuously).

Data is transferred continuously as per the business case requirement.

Retention of Personal Data

Data is normally retained for 3 months from contract termination. Until then, we will securely store your information and isolate it from any further use until deletion is possible. We retain the Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes, and enforce our agreements).

When we have no ongoing legitimate business need to process your Personal Data, we securely delete or anonymize the information. If this is not possible, we securely store your Personal Data and isolate it from any further processing until deletion is possible.

Suppose you have elected to receive marketing communications from us. In that case, we retain information about your marketing preferences for a reasonable period from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your ZINFI account. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.

The data our customers process in connection with the ZINFI UPM Subscription Service is retained according to the ZINFI Customer Terms of Service and Customer Data Processing Agreement.

Cookies

Our ZINFI System uses cookies to distinguish you from other users of our ZINFI UPM Platform. This helps us provide you with a good experience when you browse our ZINFI UPM System/Platform and allows us to improve our Platform. For detailed information on the cookies, we use and the purposes for which we use them, see our Cookie Policy.

Your Privacy Rights and Choices

Personal Data Requests 

You have the following data protection rights:

• Access, Correction, or Deletion. You can request access, correction, updates, or deletion of your Personal Data.
• Objection. You can object to our processing of your Personal Data, ask us to restrict the processing of your Personal Data, or request portability of your Personal Data.
• Withdraw Consent. If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
• Complaint. You have the right to complain to a data protection authority about our collection and use of your Personal Data. Contact details for data protection authorities are legal@zinfitech.com.

We do not sell personal information.

Please note that to protect personal information, we may verify your identity using a method appropriate to your request. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of our actions. In some instances, your rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

If you are a customer, prospect, or otherwise interact with a ZINFI customer who uses our subscription service and would like to access, correct, amend, or delete the data controlled by the customer, please get in touch with the relevant customer directly. ZINFI acts as a processor for our customers and will work with our customers to fulfill these requests when applicable.

To Unsubscribe from Our Communications

You may unsubscribe from our marketing communications through one of the following methods:

by clicking on the "unsubscribe" link at the bottom of our e-mails.

updating your communication preferences.

for ZINFI by contacting us at legal@zinfitech.com.

Customers cannot opt out of receiving transactional emails related to their ZINFI UPM Account with us or the ZINFI UPM Subscription Service.

To Unsubscribe from Our Customers’ Communications

Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from them. Individuals who interact with a ZINFI customer can unsubscribe from their marketing communications by clicking on the "unsubscribe" link located at the bottom of their emails or by contacting them directly.

Changes to our Privacy Policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, emailed to you. Please check back frequently for any updates or changes to our Privacy Policy.

Contact

Questions, comments, and requests regarding this privacy policy are welcome and should be addressed at legal@zinfitech.com.