PRIVACY POLICY

Effective as of October 28, 2019

This Privacy Policy ("Privacy Policy") explains how LLC ZENIA AI ("Company" or "we" or "us") collects, stores, uses, and discloses information from our users ("you") in connection with the Zenia - Yoga Teacher application and related services (collectively, the "App").

1. ACCEPTANCE OF PRIVACY POLICY. CHANGES TO PRIVACY POLICY

This Privacy policy is an integral part of Terms of use. By accepting Terms of use, you also accept this Privacy Policy. In some cases, we may ask you to explicitly accept this Privacy Policy.

We reserve the right to and may periodically change, amend, or update this Privacy Policy. We will notify you by email, through the App, or by presenting you with a new version of Privacy policy for you to accept if we make modifications that materially change your rights. Your continued use of the App after the effective date of an updated version of this Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, we may ask you to explicitly accept the updated Privacy Policy.

2. PERSONAL DATA AND INFORMATION WE COLLECT

When you download, install, and use the App, we may collect the following personal data and information:

  • Location information (Country/Region);

  • Demographics (Age and Gender);

  • Interests/affinities within the App;

  • Information about your device (description of a device that is used to access the App, for example, device ID, type of OS, its version)

  • Sessions (Completed Sessions across OS)

  • Information that is gathered about your use of the App (frequency of use, experienced problems, etc.) via cookies or similar technologies (for instance, through third party services like FireBase and Amplitude). We need such information in order to improve App's functionality and technical stability. This section may include information about your interaction with Third-party services as defined in Terms of use).

The information covered by Sections 2 and 3 is de-identified and does not refer to any identified or identifiable natural person, we may use it for any business purpose, and per se does not qualify as personal data. To the extent information covered by these Sections is associated with an identified or identifiable natural person (if we, for example, start collecting identifiers that whilst linked to the Information will amount to personal data under applicable law) and is protected as personal data under applicable data protection laws, it will be referred to in this Privacy Policy as "Personal Data."

3. YOUR CONSENT

By using the App, you explicitly consent that:

  1. WE MAY STORE AND PROCESS YOUR PERSONAL DATA AND INFORMATION FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES AND OTHER PURPOSES INDICATED IN SECTION 4 OF THIS PRIVACY POLICY. SUCH SERVICES MAY INCLUDE SENDING YOU INFORMATION AND REMINDERS THROUGH THE APP.

  2. WE WILL NOT TRANSMIT ANY OF YOUR INFORMATION TO THIRD PARTIES, EXCEPT IF IT IS REQUIRED TO PROVIDE THE SERVICE TO YOU (E.G. TECHNICAL SERVICE PROVIDERS), UNLESS WE HAVE ASKED FOR YOUR EXPLICIT CONSENT.

4. HOW WE USE YOUR INFORMATION


We use all Personal Data and information to improve the App and deliver better experience. Among others, we may use your Personal data and information to:

  1. analyze, operate, maintain and improve the App, to add new features and services to the App;

  2. provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders;

  3. customize product and service offerings and recommendations to you, including third-party products and offerings;

  4. send you technical notices, updates, security alerts and support and administrative messages;

  5. monitor and analyze trends, usage and activities in connection with our App.

5. HOW WE STORE AND SHARE YOUR INFORMATION


We do not share your Information with any third parties except as specified by this Privacy Policy.

We may share some of your information indicated in Section 2 of this Privacy Policy with the following third parties:

  1. FireBase. FireBase is an analytical platform owned by Google that allows us to understand the App usage and user engagement. See more about FireBase's privacy policy here;

  2. Amplitude. Amplitude is a behavioral analytics product that is enabling us to see and analyze how you navigate through the App, what features you prefer the most, and how to improve your experience with the App. See more here about Amplitude's approach to privacy here;

  3. Backendless. Backendless is mBaaS is a complete backend with support for user authentication, data persistence, file storage, messaging and custom business logic. See more here about Amplitude's approach to privacy here;

The above-mentioned third-party services are either EU-based or compliant with the GDPR (for example, EU-US Privacy Shield Framework that ensures that European data protection requirement are met). The privacy policy of these services can be found on their respective websites.

We may preserve and share your Personal Data in response to a legal request from a competent authority (search warrant, subpoena, court order). We may also preserve and share your Personal Data when we have a good belief that that is necessary for a legitimate purpose: like detecting fraudulent behavior in the App, in order to protect the security of the App, and in other cases

You may choose to share your content using our proprietary or third-party services. Please note that any such third-party services are not governed by this Privacy Policy. For instance, you may choose to send an email to share your video using your Google account, then all applicable Google privacy policy will apply. When you access and use Third-party services via the App, we are not responsible for these Third-party services and we do not endorse or make any warranties and representations about such Third-party services.

6. DATA RETENTION AND SECURITY

If you choose to delete the App, we may retain your Information for as long as your account is active and within reasonable period thereafter in case you decide to re-activate the App, but normally no longer that 1 year.

We take all reasonable and appropriate measures to protect all collected Personal data and information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Among others, we utilize the following information security measures to protect your Personal data:

  1. Encryption of your Information in transit and in rest;

  2. Systematic vulnerability scanning and penetration testing;

  3. Protection of data integrity.

Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information won't be intercepted while being transmitted to us. If we learn of a security systems breach, we may post a notice, and will take reasonable steps to remedy the breach.

7. YOUR RIGHTS

Modification, correction and erasure. You have a right to modify, correct, erase, and update your Personal Data by writing us at support@zenia.co.

Access. You have a right to access your Personal Data you insert into the App and ask us about what king of Personal Data we have about you. You can do this by using the App settings or by writing us at support@zenia.co.

EEA residents. Individuals residing in the countries of the European Economic Area have certain statutory rights in relation to their personal data introduced by the General Data Protection Regulation (the "GDPR"). Subject to any exemptions provided by law, you have the following rights:

  1. Rectification of Personal Data and Restriction of Processing. You are responsible for ensuring the accuracy of your Personal Data that you submit to the App. If you believe that your Personal Data is inaccurate, you have right to contact us and ask us to correct such Personal Data by contacting us at support@zenia.co. . You shall also have the right to request restriction of processing of your Personal Data, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.

  2. Access to your Personal Data and Data Portability. You shall have the right to request information about whether we have any Personal Data about you, to access your Personal data (including in a structured and portable form) by simply writing us at support@zenia.co. .

  3. Erasure of your Personal Data. If you believe that your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent or object to the processing of your Personal Data, or in cases where the processing of your Personal Data does not otherwise comply with the GDPR, you have right to contact us and ask us to erase such Personal Data. You can simply write us at support@zenia.co. . Please be aware that erasing some Personal Data inserted by you may affect your possibility to utilize the App and its features. Erasure of some Personal Data may also take some time due to technical reasons.

  4. Notification requirements. We commit to notify you within reasonable period of time and your data protection authority within the timeframe specified in applicable law (72 hours) about any personal data breaches in the App.

  5. Data Protection Authorities. Subject to GDPR, you also have the right to (i) restrict our use of Personal Data and (ii) lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with GDPR.
Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage the individual in a dialogue so as to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.

Please note that we will grant your request within 30 days after receiving it, but it may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems - this is due to the size and complexity of the systems we use to store data.

8. CHILDREN'S PRIVACY

General age limitation. We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 13 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the App, please contact us at support@zenia.co. and we will take required steps to delete such information and (or) delete her account.

Age limitation for EEA residents. Due to requirements of the GDPR you shall be at least 16 years old in order to use the App. To the extent prohibited by applicable law, we do not allow use of the App by the EEA residents younger than 16 years old. If you are aware of anyone younger than 16 using the App, please contact us at support@zenia.co.

9. CONTACT US

If you have any questions or concerns about your privacy, any provisions of this Privacy Policy or any of your rights, you may contact us at:

Zenia, Inc

Address: 2093 PHILADELPHIA PIKE #8414 CLAYMONT , DE 19703