1. General Introduction
1.1 We are committed to ensuring that we manage your data professionally and in accordance with all applicable data protection laws. We comply with the European Data Protection Regulation (EU 2016/679 GDPR – General Data Protection Regulation) and the local laws applicable in the United States where we operate. This Policy aims to provide you with transparency about (i) the types of personal data we gather (ii)why we are processing it and how we use such information, (iii) whether we will share it with any third party, (iv) whether it is processed outside the European Economic Entity (EEA), (v) how we will keep it safe and (vi) your rights in relation to your data.
1.3 This Policy also sets out how we may use your personal data where it is publicly available on the world wide web.
2. About Us
2.1 Our company name is Mozenda, Inc. and we are a data extraction technology company. In this Policy, we have referred to Mozenda Inc., as: Mozenda, we, us, or our. We are based at the following address: 4626 N. 300 W. STE 360, Provo, UT 84604. If you have any questions or concerns about this Policy, please feel free to contact us any time at: dataprivacy@Mozenda.com or by writing to us at the address provided above, please mark your communication for the attention of the Data Protection Representative.
3. Your Personal Data
3.1 We process your personal data when we understand that you may be interested in purchasing or have purchased or otherwise use our services or where you express an interest in working with us. We may also use your personal data when you have made it publicly available on the world wide web.
3.2 Types of Information We Collect
3.2.1 We will collect information about you when you enquire about our company and services, this will typically include, name and contact details. Where you purchase services from us we will also collect your payment information as well as additional financial information that may be required to secure credit.
3.2.2 If you visit our website we may automatically collect some personal about you including the details of your browser and operating system, the website from you visit our website, the pages that you visit on our website, the date of your visit, and the IP address assigned to you by your internet service provider. We collect some of this information using Cookies, for further information on Cookies refer to section 5.
3.2.3 If you have purchased services from us or are otherwise using our services we may collect your name and contact details and if we provide you with service support we may record your voice and images of your desktop computer screen.
3.2.4 Our telephone calls may be recorded for quality and training purposes and we will retain any voicemail message you may have left for us or one of our personnel.
3.2.5 Mozenda also collects and stores information about our user’s use of the Site and our services, including page scraping activities to improve our Site and our services.
3.2.6 In providing our services to our clients we may collect any data about you (including personal data) that is manifestly made public via the internet. Which specific data will be collected will depend on the criteria of the data scraping search as instructed or carried out by our clients.
3.2.7 If you have expressed an interest in working with us we will collect your name, contact details, curriculum vitae, and any other information that you choose to provide to us or a recruitment agency to support your application.
3.3 How do we use your Personal Data and what is our lawful basis for doing so?
3.3.1 Where we are required to do so to perform our contract with you or to pursue our legitimate interests in performing our contract with your company or employer we process your information to set up your contract, to provide you with the service, to take payment from you and to provide you with technical support and assistance.
3.3.2 Where it is in our legitimate interests to do so to perform our contract with our clients for web data scraping services we may collect and collate your data (including personal data) that is manifestly made public via the internet and will provide this data to our client. The data collected will be stored on our system until such time as our client deletes it or their contract with us is terminated.
3.3.3 Where it is in our legitimate interests to do so and you have expressed an interest in our services or company we will use your personal data to provide you with the information you have requested and may also use it to keep you updated on events and information related to our business which we think will be of interest to you.
3.3.4 Where it is in our legitimate interests to do so we may process your personal data to manage any application or expression of interest you may have made to work within our organization.
3.3.5 Where you have expressly consented, we may provide your personal data to Facebook or other social media platforms to provide you with our specifically targeted advertising campaigns.
3.3.6 We may further process your information to allow us to pursue our legitimate interests including:
i. Analysing our performance to further improve our customer service, our Site, and our services;
ii. Market research, training and to administer our websites including tailoring our sites to your interests;
iii. Complying with any requests from you in relation to your personal data including the exercise of your rights as set out in section 9;
iv. For the purpose of corporate restructure, reorganization or sale of our business or any of its assets;
v. For the purposes of preventing or investigating fraud or other criminal acts; and
vi. Enforcing our legal rights or to defend legal proceedings and for general administration purposes.
3.4 Collecting Your Aggregate Information
Aggregate information is collected as you visit our Site or interact with our services even if you do not enter any information. Generally, aggregate information is used in a collective manner, and no single person can be identified by that compiled information. Mozenda uses aggregate information to provide its services, as well as to determine the use of our Site and to monitor, audit, and analyze information pertaining to our business metrics.
3.5 Sharing of Your Personal Information with Third Parties
3.5.1 We may share your personal information with our third-party service providers as we deem necessary for the third party to provide services to us or directly to you on our behalf e.g. advertising agencies (including Facebook and other social media platforms) or administrative service providers such as credit card payments processors, or other functions necessary to our business. When we disclose your data to these third-party service providers we only disclose to them the personal data that is necessary for them to provide their service and we have a contract in place that ensures that they are not authorized to retain, share, store or use your personal information for any purposes other than to provide the services for which they have been hired to provide and they will keep your data secure
3.5.2 When you submit your personal information, you also agree that we may, subject to your consent where applicable, use your personal information to contact you by email, telephone, cell phone, direct mail, or text message about certain offers made available by us.
3.5.3 We do not sell, trade, or otherwise share your personal information with unrelated third parties for their own marketing purposes, however, we may use your personal data to pass onto you information of certain products, offers, or promotions on behalf of our third-party partners which we determine you might be interested in.
3.6 Sharing, Selling and Trading Aggregate Information Collected Online with Third Parties
We may use aggregated information to improve the Site and services, to monitor traffic and general usage patterns, and for other general business purposes. We may disclose aggregate information to third parties for a variety of business reasons, including to potential investors so that they may better understand our user base, etc.
3.6.1 In addition to the foregoing, Mozenda may elect to share or transfer your personal information to unrelated third parties: (i) to comply with a legal requirement, a judicial proceeding, court order, or legal process served on Mozenda, (ii) to investigate a possible crime, such as fraud or identity theft; (iii) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of Mozenda; (iv) when we believe it is necessary to protect the rights, property, or safety of Mozenda or other persons, or (v) as otherwise required or permitted by law.
3.7 How long do we keep your data for?
3.7.1 Where you have purchased services from us we will retain your data for the life of our contract with you until either you or we terminate the contract, or it expires. We will also retain certain of your personal data for up to a further 7 years for tax purposes and in anticipation of any legal proceedings.
3.7.2 If you have expressed an interest in our services (and have not purchased our services) we will retain your data for 5 years following your last communication with us or until you ask us to remove your data from our database. You may ask us to remove your data at any time by contacting us at the details in section 2.1 or by clicking on the unsubscribe link in any marketing email you receive from us.
3.7.3 Voice recordings of telephone calls are retained for one month.
3.7.4 If you have asked us not to market to you we will always retain sufficient information to allow us to remember your instruction.
3.7.5 The retention periods set out in this section 3.7 may be extended if we are required to do so by law.
4. Transferring Data Outside the EEA & Appropriate Safeguards
4.1 The Site is hosted on Mozenda web servers in the United States. If you are located in a non-US jurisdiction, for example in the European Economic Area (“EEA”) / European Union (“EU”) (including the United Kingdom) by providing us with your personal data you consent to the transfer of such personal data, to the United States, a jurisdiction that may not provide an equivalent level of data protection to the laws in your home country.
4.2 We have however taken steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected to the standard imposed by the EU data protection laws.
4.3 These measures include imposing contractual obligations on the recipients of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection.
4.4 Please contact us if you would like more information about the protections that we put in place to ensure the protection of your personal data.
5. Cookies & Social Plug-Ins
5.1 If you do not provide us any of your personal information, we are limited in the information we may collect from you. For example, we may be able to determine your IP address for the purposes of administering the Site and tracking Site usage. However, your IP address may vary each time you visit or it may remain the same depending on the type of Internet connection you are using or the location from which you access the Site.
5.2 We may also collect information about the websites that directed you to the Site after you clicked on a text or banner link or an ad from another website, or the day and time you visited the Site and how long you spent on the Site. We aggregate such information to help us to compile reports as to trends and other behaviour about users visiting our Site; however such information is anonymous and cannot be tied directly to you. We may also use “cookies” and your personal information to enhance your experience on the Site and with the services and to provide you with personalized offers. A cookie is a small data file placed on your computer’s hard drive that contains information that allows us to track your activity on the Site. The cookie itself does not contain any personal information; however, if you provide us any personal information the cookie may act as an identifier to tie your personal information to your IP address or computer. You may choose to delete cookies from your computer’s hard drive at any time or to disable cookies on your computer. If you delete cookies that relate to the Site, we may not be able to identify you upon your return to the Site. Additionally, if you disable your computer’s cookies, you may not be able to access certain features of the Site or services that require that cookies be enabled. The Site’s cookies cannot be used to read data from your hard drive and cannot retrieve information from any other cookies created by other websites. Additionally, our cookies cannot be used as a virus, Trojan horse, worm, or any other malicious tool that could impair your use of your computer. Our cookies are used to help us better understand how you and other users use the Site so we can continue to provide a better, more personalized user experience on the Site. To find out more about Cookies visit www.youronlinechoices.com.
5.3 We use so-called social plugins (buttons) of social networks such as Facebook, Google+ and Twitter.
5.4 When you visit our Site, these buttons are deactivated by default, i.e. without your intervention they will not send any data to the respective social networks. Before you can use these buttons, you must activate them by clicking on them. They then remain active until you deactivate them again or delete your cookies. After their activation, a direct link to the server of the respective social network is established. The contents of the button are then transmitted from the social network directly to your browser and incorporated in the Site. After activation of a button, the social network can retrieve data, independently of whether you interact with the button or not. If you are logged on to a social network, the network can assign your visit to the Site to your user account. If you are a member of a social network and do not wish it to combine data retrieved from your visit to our Site with your membership data, you must log out from the social network concerned before activating the buttons.
5.5 We have no influence on the scope of data that is collected by the social networks through their buttons. The data use policies of the social networks provide information on the purpose and extent of the data that they collect, how this data is processed and used, the rights available to you and the settings that you can use to protect your privacy.
6. Security of your Data
6.1 We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of your data having regard to the state of the art, the nature of the data and the risks to which they are exposed. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.
6.2 We restrict access to personal information to Mozenda employees, service providers and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline or other sanctions if they fail to meet these obligations.
6.3 We use secure socket layer (“SSL”) technology to encrypt and protect the security of your personal information, including but not limited to your credit card number, when it is sent over the Internet. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.
7. Children and Privacy
Our Site is not directed to children and we will not request personally identifiable information from anyone who we know to be under the age of 18, unless we have obtained verifiable parental consent from a parent or legal guardian. If we become aware that a user under the age of 18 has registered with our Site without prior verifiable consent from a parent or legal guardian, we will immediately delete the user’s personal information.
8. Links to Other Websites
The Site may contain links to websites operated by other people or companies. Mozenda does not have any responsibility for those websites, and we provide the links solely for the convenience of our visitors. You are recommended to review the privacy policies of those websites.
9. Your Rights
9.1 Your Right to Stop Marketing Communications
If you prefer not to receive newsletters or other marketing e-mails from Mozenda, please let us know by clicking on the unsubscribe link within any newsletter or marketing e-mail you receive. If you prefer not to receive marketing mail via the mail carrier, please let us know by contacting customer service at support@Mozenda.com. Please be sure to include in any e-mail your full name, e-mail address, and any message. Please note that such requests may take up to ten (10) days to become effective.
9.2 Your Right to Access Data
9.2.1 We always aim to be as open as we can and allow individuals access to their personal information. Where we hold your personal data, you can make a ‘Subject Access Request’ to us and we will provide you with:
i. a description of your data that we hold;
ii. an explanation of why we are holding it;
iii. information about who it could be disclosed to; and
iv. a copy of the information – unless an exception to the disclosure requirements is applicable.
9.2.2 If you would like to make a ‘Subject Access Request’ please make it in writing to our contact email address noted in section2 and mark it clearly as ‘Subject Access Request’.
9.2.3 If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone. Unless you agree a different time, we will complete your subject access request within one month.
9.3 Right to Be Forgotten
If we hold personal data about you, but it is no longer necessary for the purposes that it was collected and cannot otherwise be justified – you have the right to request that we delete the data.
9.4 Right to Restrict Data
If we hold personal data about you and you believe it is inaccurate you have the right to request us to restrict the data until it is verified. You also have the right to request that the data is restricted where you have a right to it being deleted but would prefer that it is restricted.
9.5 Transferring your Personal Data
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under section 3.3, you may ask us to provide you with a copy of that information to you or to another service provider. We will usually send the data in a CSV file.
9.6 Right to complain
You always have the right to complain to the personal data regulator. To locate the relevant national data regulator in the European Union click here. In the United States any complaint should be addressed to the Federal Trade Commission You may also be entitled to seek compensation if there has been a breach of data protection laws.
10. Changes to this Policy
We may change this Policy at any time and without prior notice, by posting the revised version of this Policy on our Site. Your continued use of the Site and/or services indicates your consent to our collection of and use of your personal and aggregate information under the then current Policy.