INTRODUCTION
Zensimu SAS (“Zensimu”) is concerned about privacy issues and wants
you to be familiar with how we collect, use and disclose information.
This Privacy Policy describes our practices in connection with
information that we collect through websites operated by us from which
you are accessing this Privacy Policy (the “Websites”), through the
software applications made available by us for use on or through
computers and mobile devices (the “Apps”), and through HTML-formatted
email messages that we send that link to this Privacy Policy
(collectively, including the Websites and Apps, the “Services”). By
providing Personal Information to us, you agree to the terms and
conditions of this Privacy Policy.
If you are a California resident, please see “Additional Information
for California Residents,” below, for more information about our
practices and your rights.
PERSONAL INFORMATION
“Personal Information” is information that identifies an individual or
relates to an identifiable person, including:
For instructors (“accountholders”), who create an account on the
website in order to host their own simulations:
Name,
Email
address,
The password for your account,
Financial
information such as billing address (required when subscribing for
paid plans),
The type of organization you work in (either
university or business environment),
Company, University or
organization name,
Company or University picture if you decide to
customize the app.
For participants, who only join a game created by someone else:
User
name to identify their position in the game,
The participant
Email may be collected if given by an instructor to share more easily
his simulations with his participants.
We need to collect and process these informations in order to provide
the requested Services to you, or because we are legally required to
do so. If you do not provide the information that we request, we may
not be able to provide the requested Services.
If you submit any Personal Information relating to other people to us
or to our service providers in connection with the Services, you
represent that you have the authority to do so and to permit us to use
the information in accordance with this Privacy Policy.
The instructor is responsible for ensuring that any collection and
processing of personal data from participants is carried out in
accordance with applicable law, including e.g. having obtained consent
from the participant, if required.
How We Collect Personal Information We and our service providers
collect Personal Information from accountholders in a variety of ways,
including:
Through the Services: We collect Personal Information through the
Services, e.g., when you create an account, register your credit/debit
card information and other financial data that we/our payment
processors need to provide the Services, or populate your profile.
Offline: We collect Personal Information from you offline, such as
when you contact customer service. From Other Sources: We may receive
your Personal Information from other sources, such as Google (if you
choose to register using your Google account), public databases, joint
marketing partners and other third parties. How We Use Personal
Information
We and our service providers use Personal Information for our
legitimate business purposes, including the following:
Providing the functionality of the Services and fulfilling your
requests. To provide the Services’ functionality to you, such as
arranging access to your account. To respond to your inquiries and
fulfill your requests, such as to send you newsletters. To complete
your transactions. To send administrative information to you, such as
information regarding the Services and changes to our terms,
conditions and policies. To allow you to share simulations, and to
notify you when a simulation is shared with you. We engage in these
activities to manage our contractual relationship with you and/or to
comply with a legal obligation.
Providing you with marketing material that we believe may be of
interest to you. We engage in this activity with your consent or where
we have a legitimate interest.
Analysis of Personal Information for business reporting and providing
personalized services. To personalize your experience on the Services
by presenting products and offers tailored to you. We provide
personalized services either with your consent or because we have a
legitimate interest.
Anonymizing and/or aggregating Personal Information. We may anonymize
and/or aggregate Personal Information so that it will no longer be
considered Personal Information. We do so to generate other
information for our use, which we may use and disclose for any
purpose.
Accomplishing our business purposes. For our business purposes, such
as data analysis, audits, fraud monitoring and prevention, developing
new products, enhancing, improving or modifying our Services,
identifying usage trends, determining the effectiveness of our
promotional campaigns and operating and expanding our business
activities. We engage in these activities to manage our contractual
relationship with you, to comply with a legal obligation, and/or
because we have a legitimate interest.
How Personal Information May Be Disclosed The Personal Information of
accountholders may be disclosed:
To our third party service providers who provide services such as
website hosting, data analysis, information technology and related
infrastructure provision, customer service, email delivery, auditing,
payment processing and other services. To identify you to anyone with
whom you share a simulation or other messages, through the Services.
By you, on profile pages and other services to which you are able to
post information and materials. Please note that any information you
post or disclose through these services will become public and may be
available to other users and the general public. We urge you to be
very careful when deciding to disclose any information on the
Services.
Other Uses and Disclosures We also use and disclose Personal
Information as necessary or appropriate, especially when we have a
legal obligation or legitimate interest to do so:
To comply with applicable law and regulations: – This can include laws
outside your country of residence. To cooperate with public and
government authorities: – To respond to a request or to provide
information we believe is important. – These can include authorities
outside your country of residence. To cooperate with law enforcement:
– For example, when we respond to law enforcement requests and orders
or provide information we believe is important. For other legal
reasons: – To enforce our terms and conditions. – To protect our
rights, privacy, safety or property, and/or that of our affiliates,
you or others. In connection with a sale or business transaction: – We
have a legitimate interest in using, disclosing, or transferring your
Personal Information to a third party in the event of any
reorganization, merger, sale, joint venture, assignment, transfer, or
other disposition of all or any portion of our business, assets or
stock (including in connection with any bankruptcy or similar
proceedings). Such third parties may include, for example, an
acquiring entity and its advisors.
OTHER INFORMATION
Other Information We Collect “Other Information” is any information
that does not reveal your specific identity or does not directly
relate to an individual, such as:
Browser and device information App usage data Information collected
through cookies, pixel tags and other technologies Demographic
information and other information provided by you Aggregated
information If we are required to treat Other Information as Personal
Information under applicable law, then we may use it for the purposes
for which we use and disclose Personal Information as detailed in this
Policy.
How We Collect Other Information We and our third party service
providers collect Other Information in a variety of ways, including:
Through your browser or device: Certain information is collected by
most browsers or automatically through your device, such as your Media
Access Control (MAC) address, computer type (Windows or Macintosh),
screen resolution, operating system name and version, device
manufacturer and model, language, Internet browser type and version
and the name and version of the Services (such as the App) you are
using. We use this information to ensure that the Services function
properly.
Using cookies: Cookies are pieces of information stored directly on
the computer that you are using. Cookies allow us to collect
information such as browser type, time spent on the Services, pages
visited, language preferences, and other anonymous traffic data. We
and our service providers use the information only to support the
internal operations of the Services, such as for security purposes, to
facilitate navigation, to display information more effectively, to
personalize your experience while using the Services and to recognize
your computer in order to assist your use of the Services. We also
gather statistical information about use of the Services in order to
continually improve their design and functionality, understand how
they are used and assist us with resolving questions regarding them.
Learn more about cookies at : https://www.cookiesandyou.com/
If you do not want information collected through the use of cookies,
there is a simple procedure in most browsers that allows you to
automatically decline cookies or be given the choice of declining or
accepting the transfer to your computer of a particular cookie (or
cookies) from a particular site. You may also wish to refer to
http://www.allaboutcookies.org/manage-cookies/index.html. If, however,
you do not accept cookies, you may experience some inconvenience in
your use of the Services. For example, we may not be able to recognize
your computer, and you may need to log in every time you visit.
Using pixel tags and other similar technologies: Pixel tags (also
known as web beacons and clear GIFs) may be used in connection with
some Services to, among other things, track the actions of users of
the Services (including accountholders that may receive emails from
us), measure the success of marketing campaigns and compile statistics
about usage of the Services and response rates.
Analytics: We use third parties, including Google Analytics and Heap
Analytics, which use cookies and similar technologies to collect and
analyze information about use of the Services and report on activities
and trends. You can learn about Google’s practices by going to
www.google.com/policies/privacy/partners/, and opt out of them by
downloading the Google Analytics opt-out browser add-on, available at
https://tools.google.com/dlpage/gaoptout.
IP Address: Your IP address is a number that is automatically assigned
to the computer that you are using by your Internet Service Provider
(ISP). An IP address may be identified and logged automatically in our
server log files whenever a user accesses the Services, along with the
time of the visit and the page(s) that were visited. Collecting IP
addresses is standard practice and is done automatically by many
websites, applications and other services. We use IP addresses for the
purposes of providing support for the internal operations of the
Services, such as calculating usage levels, diagnosing server
problems, and administering the Services. We may also derive your
approximate, general, location from your IP address.
From you: Information such as communications preference may be
collected from accountholders when they voluntarily provide it.
By aggregating information: Aggregated Personal Information does not
personally identify you or any other user of the Services.
How We Use and Disclose Other Information We use and disclose Other
Information for any purpose, except where we are required to do
otherwise under applicable law. In some instances, we may combine
Other Information with Personal Information. If we do, we will treat
the combined information as Personal Information as long as it is
combined.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
This section provides information for California residents in
connection with the California Consumer Privacy Act (“CCPA”). This
section does not expand upon our practices with respect to our
collection of Personal Information, as described. This section may,
however, give children who are residents of California (and their
parents or guardians) additional rights.
If you are a California consumer, you have the following rights:
(A)
Right to Know. You have the right to request that we disclose to you
the following information covering the 12 months preceding your
request: The categories of Personal Information we collected about you
and the categories of sources from which we collected such Personal
Information; The specific pieces of Personal Information we collected
about you; The business or commercial purpose for collecting Personal
Information about you; and The categories of Personal Information
about you that we disclosed and the categories of third parties to
whom we disclosed such Personal Information.
(B) Right to Request
Deletion. You have the right to request that we delete Personal
Information we collected from you. To make a request for the
disclosures or deletion described above, please email
hello@zensimu.com. In some instances, we may decline to honor your
request where, for example, we are unable to verify your request or
where an exception applies, such as where the disclosure of Personal
Information would adversely affect the rights and freedoms of another
California resident.
(C)Right to be Free from Discrimination. You have the right to be free
from unlawful discrimination for exercising your rights under the
CCPA.
THIRD PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for,
the privacy, information or other practices of any third parties,
including any third party operating any site or service to which the
Services link. The inclusion of a link on the Services does not imply
endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection,
use, disclosure or security policies or practices of other
organizations, such as Facebook, Twitter, WhatsApp, Apple, Google,
Microsoft, or any other app developer, app provider, social media
platform provider, operating system provider, wireless service
provider or device manufacturer, including with respect to any
Personal Information you disclose to these or other organizations.
List of third party processors
- Hosting : Google, LLC (Firebase) -
1600 Amphitheatre Parkway, Mountain View, CA 94043, USA - Purpose :
Save all the users parameters and simulations data for the app to work
- Payment processing : Stripe Inc. -
510 Townsend Street, San Francisco, CA 94103 USA - Purpose :
Process payments, send invoices
- Communication : Peaberry Software Inc. (Customer.io) -
921 SW Washington St, Suite 820, Portland, OR 97205, USA - Purpose :
Send personalized messages (welcome emails or newsletters) and transactional emails
- Analytics : Segment.io, Inc -
101 Spear Street, San Francisco, 94105 California, USA - Purpose :
User interaction data collection for analytics or communication
- Analytics : Mixpanel, Inc. -
One Front Street, 28th Floor San Francisco, California 94111, USA - Purpose :
User interaction data and product analytics, to improve the app
- Advertising : Google, LLC (Google Ads, Google Analytics) -
1600 Amphitheatre Parkway, Mountain View, CA 94043, USA - Purpose :
Data analytics, re-targeting advertising campaigns
- Internal Management : Google, LLC (Gmail, Google Drive) -
1600 Amphitheatre Parkway, Mountain View, CA 94043, USA - Purpose :
Internal management and external communication
- Customer Support : Help Scout -
177 Huntington Ave, Ste 1703, PMB 78505, Boston, MA 02115-3153, USA - Purpose :
Helpdesk and Knowledge Base, to resolve issues and provide assistance
- NPS and Surveys : Satismeter -
Česká 1113/1, Prague 5, 158 00, Czech Republic - Purpose :
In-app and email survey to help us improve the app and the user experience
- Feedback and Product Roadmap : Canny -
San Francisco, 94105 California, USA - Purpose :
Feedback board and roadmap
SECURITY
We seek to use reasonable organizational, technical and administrative
measures to protect Personal Information within our organization.
Unfortunately, no data transmission or storage system can be
guaranteed to be 100% secure. If you have reason to believe that your
interaction with us is no longer secure (for example, if you feel that
the security of your account has been compromised), please immediately
notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal
Information We give accountholders choices regarding our use and
disclosure of their Personal Information for marketing purposes. You
may opt-out from receiving marketing-related emails from us on a
going-forward basis by clicking the unsubscribe link in any such
email. We will try to comply with your request(s) as soon as
reasonably practicable. Please note that if you opt-out of receiving
marketing-related emails from us, we may still send you important
administrative messages, from which you cannot opt-out.
How you can access, change or suppress your Personal Information If
you are an accountholder and you would like to request to review,
correct, update, suppress or delete Personal Information, restrict the
processing of your Personal Information, object to the processing of
your Personal Information, or if you would like to receive an
electronic copy of your Personal Information for purposes of
transmitting it to another company (to the extent this right to data
portability is provided to you by applicable law), you may contact us
in accordance with the “Contacting Us” section below. We will respond
to your request consistent with applicable law.
In your request, please make clear what Personal Information you would
like to have changed, whether you would like to have your Personal
Information suppressed from our database or otherwise let us know what
limitations you would like to put on our use of your Personal
Information. For your protection, we may only implement requests with
respect to the Personal Information associated with the particular
email address that you use to send us your request, and we may need to
verify your identity before implementing your request.
Please note that we may need to retain certain information for
recordkeeping purposes and/or to complete any transactions that you
began prior to requesting a change or deletion.
RETENTION PERIOD
We keep your Personal Information for as long as needed or permitted
in light of the purpose(s) for which it was obtained and consistent
with applicable law. The criteria used to determine our retention
periods include (i) the length of time we have an ongoing relationship
with you and provide our Services to you; (ii) whether there is a
legal obligation to which we are subject; or (iii) whether retention
is advisable in light of our legal position (such as in regard of
applicable statutes of limitations, litigation, or regulatory
investigations).
CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country
where we have facilities or in which we engage service providers, and
by using the Services you understand that your information will be
transferred to countries outside of your country of residence, which
may have data protection rules that are different from those of your
country.
If you are located in the European Economic Area (“EEA”): Some of the
non-EEA countries are recognized by the European Commission as
providing an adequate level of data protection according to EEA
standards. For transfers from the EEA to countries not considered
adequate by the European Commission, we have put in place adequate
measures, such as standard contractual clauses adopted by the European
Commission to protect your Personal Information. You may obtain a copy
of these measures by contacting us (see below under Contacting Us).
SENSITIVE INFORMATION
We ask that you not send us, and you not disclose, any sensitive
Personal Information (e.g., social security numbers, information
related to racial or ethnic origin, political opinions, religion or
other beliefs, health, biometrics or genetic characteristics, criminal
background or trade union membership) on or through the Services or
otherwise to us.
UPDATES TO THIS PRIVACY POLICY
We may change this Privacy Policy. The “LAST UPDATED” legend at the
top of this page indicates when this Privacy Policy was last revised.
Any changes will become effective when we post the revised Privacy
Policy on the Services.
CONTACTING US
If you have any questions about this Privacy Policy, please contact us
at hello@zensimu.com or :
Zensimu, 5 Avenue du General de Gaulle,
94160 SAINT-MANDE, FRANCE
Because email communications are not
always secure, please do not include sensitive information in your
emails to us.
ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA
If you are located in the EEA, you may lodge a complaint with a
supervisory authority competent for your country or region.