Effective Date: 07/01/2024

Last Updated: 09/01/2024

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At Zalow, we care about your personal data and respect your privacy. This Privacy Policy explains how and why Zalow collects, stores use and shares personal information when you visit our websites or use our services. Reading it will help you understand your privacy rights and choices.

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In this Privacy Policy we describe the types of information we may collect from you or that you may provide when you visit any pages connected to www.zalow.com (our “Site”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

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This Privacy Policy applies to all personal data provided by you or collected by us. Whether you are a Worker, Company, or visitor at our Sites, you can trust that we have taken technical and organizational measures to protect your data and are committed to protecting it through our compliance with this Privacy Policy.

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“Personal information” in this Privacy Policy means information about you, including your identity, personal and company information, and online behavior. The specific information that is collected is listed at: Information We Collect About You and How We Collect It.

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This Privacy Policy applies to the information we collect:

• on the Zalow Site, and

• in email, text, and other electronic messages between you and Zalow.

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It does not apply to information collected by:

• information collected offline,

• any website not operated by Zalow, or

• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site.

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Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use our Site. By using the Site, you agree to the collection and use of information in accordance with this Privacy Policy. This Policy may change from time to time. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

‍Data Controller

‍Depending on the region in which you are located, the following Zalow companies are responsible for the collection and processing of your personal data in connection with our services. In connection with the processing of your personal data, the data controller is:

‍   Region You Are Located in: United States

   Zalow Entity: Zalow, Inc.

   Address: 4500 S. Lakeshore Drive, Tempe, AZ 85252

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   For all other countries, and all legal notices

   Zalow Entity: Zalow, Inc.

   Address: 4500 S. Lakeshore Drive, Tempe, AZ 85252

 

We process personal data in accordance with applicable laws. We may transfer personal information to other countries, for example, to conduct our business, provide customer service, or process transactions. When transferring personal information, we apply appropriate safeguards. If you have any questions about our Privacy Policy, for data requests, to object to any registration, or our processing of your personal data, email us at info@Zalow.com. We have appointed a Data Protection Officer (“DPO”) to oversee the protection of your personal data. If you have questions for our DPO, contact Zalow’s DPO at info@Zalow.com.

‍Children under the age of 18

‍Our Site is not intended for users under 18 years of age, or the age of majority in your location. We do not knowingly collect personal information from users under 18. If you are under 18, do not use or provide any information on this Site or on or through any of its features. If we learn we have collected or received personal information from a user under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please email us at info@Zalow.com.

‍Your privacy rights and choices

Subject to restrictions, as a data subject you have rights and choices when it comes to how we use your personal information. This may include a right to access, rectify, erase, and restrict the processing and data portability of your personal information. You may be entitled to withdraw your consent and object to our processing of your personal data based on our legitimate interests and to lodge a complaint with a supervisory authority. 

Understanding your rights

‍You have the right to:

• request a copy of the personal information we’ve collected about you;

• correct your data;

• object to your data; and

• ask us to delete the personal information we have collected about you.

If you or an authorized agent want to make a request related to your personal information, email us at info@Zalow.com or submit a request to Customer Support via the chat function within the Platform. If you make a request related to your personal information, we will first verify your identity before we can process your request. If we can’t verify your identity, we are unable to complete your request.

 

We will not deny you services, charge you different prices, or provide you with an extra level of service solely to exercise your privacy rights.

Deleting your personal information

You have the right to:

• delete some information you previously added to the Site by logging in to your account and adjusting your settings and account details;

• request we delete specific information; and

• close your account.

 

If you close your account or request that we delete personal information, we may need to keep some personal information so that we can complete transactions, deliver services, or comply with our legal obligations. Depending on where you live and your account type, you may have different rights and choices for managing your personal information.

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Should you wish to close your account and delete personally identifiable information, please email info@zalow.com for the most current instructions.

 

Choosing how we communicate with you

‍You may be able to choose how we communicate with you, and this may differ depending on the purpose of the message and how it is delivered. Some messages are necessary while others are optional. We use email, text messages, push notifications on your mobile device, and even phone or paper mail depending on the situation and your preferences.

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You can click the unsubscribe link in a marketing email to opt out. You can also change your account’s notification settings or the notification preferences on your device.

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You won’t be able to opt-out of messages that are considered necessary for you to manage your account, such as emails that alert you to changes to your account. You may be able to decide how we send those messages, such as by email, phone, text message, or notifications.

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If you access our Site or use our services without creating or logging into an account, we may still collect personal information including device information, configuration, and location. We may use this information to provide and improve our services, process transactions, prevent and report fraud, and comply with the law.

Information We Collect About You and How We Collect It

We may collect several types of personal information from and about visitors and users of our Site, including information when you register for or use our services, create an account, or make a transaction. Here are the kinds of personal information that we may collect:

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Information that identifies you includes your:

• Name

• Address

• Email address

• Phone number

• IP address

• Device information

• Information collected from cookies and other tracking technologies

Financial information and records:

• Social Security Number

• Government-issued identification

• Bank account details

• Credit and debit card information

• Financial information

• Tax information

• Transaction information when using Zalow services

Personal Characteristics:

• Age

• Date of birth

• National origin

• Citizenship‍

Internet or network activity:

• Your interactions with our Site or services

• Transaction history

Location data:

• IP-based geolocation

Video, audio, visual, biometric, or similar information:

• Call or meeting recordings when you interact with sales or customer service

• Voice identification

• Profile pictures you provide

• Photo IDs or other identification you provide to establish an account or authenticate your identity, which we delete after authentication

Professional, criminal history, employment history, and information

• Business information, contact details

• Work history

• Educational information

• Criminal records or history (only upon your consent)

• Business colleagues and partners

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Identity Verification Services

We utilize Personal Data about your identity, including information provided by you and our service providers, to perform verification services for Stripe or for the Users that you are transacting with, to prevent fraud and enhance security. If you provide a selfie along with an image of your identity document, Stripe may employ biometric technology to compare and calculate whether they match and verify your identity.

 

We use Stripe, Inc. for identity verification service that automates the comparison of your identity document (such as a driver’s license) with your image (such as a selfie). You can separately consent to us using your biometric data to enhance our verification technology, with the option to revoke your consent at any time.

 

Stripe provides a verification and fraud prevention Service that we can use to verify Personal Data about you, such as your authorization to use a particular payment method. During the process, you’d be asked to share with Stripe certain Personal Data (like your government ID and selfie for biometric verification, Personal Data you input, or Personal Data that is apparent from the physical payment method like a credit card image). To protect against fraud and determine if somebody is trying to impersonate you, Stripe may cross-verify this data with information about you that they've collected from Users, Financial Partners, business affiliates, identity verification services, publicly available sources, and other third party service providers and sources.

 

We use Stripe for identity verification, payments, analytics, and other business services. Stripe may collect personal data including via cookies and similar technologies. The personal data Stripe collects may include transactional data and identifying information about devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection, loss prevention, authentication, and analytics related to the performance of its services. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy.

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We may utilize information we have about you for various purposes, such as our 360° Trust Score, fraud or risk detection, assessment, or personalization preferences. This may include information that is about you but does not specifically identify you. We use this information to track and understand the behavior of our Users. This helps us improve the online experience and engagement on our Site. We may associate information from these sources with you and your account to improve the user experience, compliance, and analytic purposes.

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We collect personal information about you from other various sources such as:

• When you use a Zalow service

• Third party merchants

• Payment partners, credit card networks and processors

• Financial institutions

• Credit bureaus

• Service providers that help us manage risk and fraud, help us deliver services to you, and market our services

 

Why we collect personal information

We collect personal information:

• to enable our services

• to operate our business

• to effectively run our Site

• to conduct research and to improve our services

• to improve the overall user experience and our services

• to better understand our users

• to personalize and tailor our services to individual interests when using our Site

• to contact you about your Zalow account and services

• to enhance security

• to customize our Site to support local languages and personalized content

• to protect our users from fraud and risks

• to support Customer Service and Sales teams to interact with you and provide exceptional support

• to comply with regulations, legal and contractual obligations

• to provide you with personalized advertising and marketing communications

• to detect, prevent, mitigate, and investigate fraudulent or illegal activity

• to comply with Ant-money Laundering (“AML”) and Know-Your-Customer (“KYC”) regulations and financial reporting obligations

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We monitor, analyze, and test our ability to securely collect and process personal information.

Purposes and Legal Basis for Data Processing

We process your personal data pursuant to the applicable legal basis. The basis for processing your data varies depending on your location, including:

• Providing the functionality of Zalow and fulfilling your requests

• Providing you with marketing materials and facilitating social sharing

• Analysis of personal data for business reporting and providing personalized services

• Accomplishing our business purposes

• Aggregating and/or anonymizing personal data

• To allow us to disclose your information to the extent permitted by law

• Legal compliance

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We may share your information with third parties, including service providers acting on our behalf, for these purposes. In addition, we may share your personal data among Zalow group companies to fulfill our contract with you under the Terms of Use, and, if applicable, the Payments Terms.

How We Protect Your Information

We work hard to protect your personal information against loss, abuse, unauthorized access, or disclosure. To protect your information we use various physical, technical, and organizational measures including firewalls, encryption, physical access security, and compliance programs. While we take our responsibility to protect your personal information very seriously, it is also your responsibility to ensure you keep your account information secure, private, and up to date. We strongly encourage you to use complex passwords, change them often, and use best practices to protect your account.

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In the event of a data breach or incident, Zalow will promptly notify you and take all measures necessary to mitigate harm and protect your personal information.

How We Share Personal Information About You

We do not sell your personal information. We may share personal information across our services and with other members of the Zalow corporate group. Sometimes we share the personal information we collect with third parties to help us provide services, protect our customers from risk and fraud, market our products, and comply with legal obligations.

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We may share your personal information with:

• Zalow’s companies

• Our service providers that help us process payments, for marketing, research, compliance, audits, corporate governance, communications, and security services

• Card networks and payment processors

• Financial institutions

• Credit reporting and collections agencies

• Courts, governments, regulators, and law enforcement when accompanied by a subpoena or other legal documentation that requires us to respond

• People and companies involved in a transaction, such as other Site users

• Third parties that you connect with, such as financial providers or social media apps. If you connect with third-party apps or websites, it is your responsibility to manage or disconnect your account from that third party

• Third-party tools used to help fight spam and abuse, such as captcha and verification tools

• Other third parties to:

  • Comply with laws

  • Investigate or enforce our Terms of Use, Terms of Service, and other agreements, including for billing and collection purposes

  • Facilitate a merger, purchase, or sale of part or our business

  • Comply with card association rules

  • To prevent physical harm or illegal activity

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety.

 

This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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When interacting on the Site, you may provide information to be published or displayed on public areas of the Site or transmitted to other users of the Site or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

How We Use Cookies and Tracking Technology

We may use cookies and similar tracking technologies to collect personal information when you use our services, visit our Site, or websites that connect to our Site. The information collected with these technologies helps us personalize your experience, measure the effectiveness of our ads, prevent fraud, and enhance the security of our sites and service. If you want to know more about how we use cookies, read our Cookie Policy.

Changes to Our Privacy Policy

We will update this Privacy Policy from time to time. Changes are effective upon posting. You are responsible for ensuring you have read and understood the Privacy Policy and for periodically checking for changes. When this Privacy Policy is updated, your personal information will be handled according to the most current practices as contained in that revised policy. The date of each update is located at the top of the page.

Other Important Information

Additional regional policies and disclosure for residents of certain U.S. states or countries may apply.

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California The California Consumer Act of 2018 (CCPA) permits consumers who are California residents to ask businesses covered under the act about personal information it has collected about the consumer, submit an accessor deletion request, and opt-out of the sale of personal information, if applicable. These provisions do not apply to personal information collected, processed, shared, or disclosed by financial institutions pursuant to federal law. Contact us if you have questions about our Privacy Policy, this consumer notice, or your personal information. If your Zalow account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.

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Colorado If you are a resident of Colorado, you have a right to: (a) confirm whether we process your personal information, (b) access and delete certain personal information, (c) correct inaccuracies in your personal information, taking into account the information's nature processing purpose, (d) opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects, (e) opt-out of personal data processing for targeted advertising and sales, and (f) data portability. If you wish to exercise these rights, please email us at info@Zalow.com.

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Connecticut If you are a resident of Connecticut, you have a right to: (a) confirm whether we process your personal information, (b) access and delete certain personal information, (c) correct inaccuracies in your personal information, taking into account the information's nature processing purpose, (d) opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects, (e) opt-out of personal data processing for targeted advertising and sales, and( f) data portability. If you wish to exercise these rights, please email us at Info@Zalow.com.

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Nevada Nevada provides its residents with a limited right to opt-out of certain personal information sales. If you wish to exercise this sale opt-out rights, please email us at Info@Zalow.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

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Utah If you are a resident of Utah, you have a right to: (a) confirm whether we process your personal information, (b) access and delete certain personal information, (c) opt-out of personal data processing for targeted advertising and sales, and (d) data portability. If you wish to exercise these rights, please email us at Info@Zalow.com.

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Vermont If your Zalow account has a Vermont mailing address, we will not share personal information we collect about you with non-affiliates unless the law allows, or you provide authorization.

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Virginia If you are a resident of Virginia, you have a right to: (a) confirm whether we process your personal information, (b) access and delete certain personal information, (c) correct inaccuracies in your personal information, taking into account the information's nature processing purpose, (d) opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects, (e) opt-out of personal data processing for targeted advertising and sales, and (f) data portability. If you wish to exercise these rights, please email us at Info@Zalow.com.

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For questions about your account, email us at info@Zalow.com or contact Customer Support via the chat function within the Platform.