Zeffry
EFFECTIVE DATE: DECEMBER 13, 2021

ZEFFRY PRIVACY POLICY

1. Our Commitment to Privacy.

This notice describes our Privacy Policy. Our privacy policy explains how Zenith Innovative Solutions LLC d/b/a Zeffry (“Zeffry”) collects, uses, and protects the personal information obtained through the use of our Zeffry mobile application (“App”), our website www.Zeffry.com (“Site”), social media accounts and the services available through both the App and Site (collectively, “Services”). Through the Services Zeffry provide a platform with payroll and tax calculation services for small and medium sized businesses. By visiting the Site, using or downloading the App, or using any of our Services, you agree that your personal information will be handled as described in this Privacy Policy. Your use of our Site, App, or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Zeffry Terms of Use are incorporated by reference into this Policy.

2. What Information is Collected.

Zeffry collect information about you directly from you and from third parties, as well as automatically through your use of our Site, App or Services. Zeffry has implemented technical and organizational measures with respect to processing personal information from European Union individuals for purposes of the EU General Data Protection Regulation (“GDPR”). Upon request, Zeffry will provide you with information as to whether and what personal data Zeffry store in relation to you. Should your personal data be incorrect, you may request to have it rectified. You may also revoke your consent to use your personal data in the future, in whole or in part, or request deletion of your personal data.

(a) Information Zeffry Collect Directly From You. In order to use the Services, you will be required to create a user account for your company (“Account”). To register an Account, you must provide at minimum your (i) first name and last name, (ii) a contact email, (iii) legally registered company name and company address, (iv) FEIN, (v) entity type, (vi) CA EDD account number, (vii) CA SUI ETT rate, (viii) bank account information and (ix) all employee names, addresses and social security numbers and any other information required in the Terms of Use. (“Personal Information”).

(b) Information Zeffry Collect Automatically. Zeffry may automatically collect information about your use of our Services through cookies, web beacons, and other technologies, including technologies designed for mobile applications. Zeffry combine this information with other information Zeffry collect about you. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Site:
  • domain name;
  • your browser type and operating system;
  • web pages you view; links you click; your IP address;
  • the length of time you visit our Site and or use our Services;
  • the referring URL, or the webpage that led you to our Site.
App:
  • mobile device ID; device name and model; operating system type, name, and version
  • language information;
  • activities within the App; and the length of time that you are logged into our App;

Zeffry do not collect any types of Sensitive Data from our users. Sensitive Data includes any Personal Information pertaining to: race or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic or biometric data, health or mortality, and sex life or sexual orientation. Please immediately notify Zeffry if you have accidentally submitted any Sensitive Data and Zeffry shall promptly remove such information.

3. How and When the Information is Used.

Zeffry will primarily use your Personal Information to provide our Services, and to complete core business functions such as authentication‚ internal business processes‚ marketing‚ loss and fraud prevention‚ and legal functions. If you have any questions about which features you can use without providing Personal Information, please feel free to contact Zeffry at support@zeffry.com . Currently, Zeffry use your information, on the Site and/or App for the following purposes:

a. To provide our payroll, tax and other related services (“Services”).
b. To work with our Service Providers and submit information to financial institutions and government agencies through functions of our Services.
c. To obtain credit reports for your business.
d. Investigate and prevent fraud and other illegal activities.
e. Provide, maintain, and improve Zeffry and our overall business.
f. To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes.
g. To tailor the content and information that Zeffry may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site, App or our Services.
h. For marketing and promotional purposes. For example, Zeffry may use your personal information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about services or information Zeffry think may interest you. Zeffry also may use the information that Zeffry learn about you to assist Zeffry in advertising our Services on third party websites.
i. To better understand how users access and use our Site, App and Services, both on an aggregated and individualized basis, in order to improve our Site and App and respond to user desires and preferences, and for other research and analytical purposes.
j. To protect our own rights and interests, such as to resolve any disputes, enforce our Terms of Use or to respond to legal process.
k. In addition to the uses outlined above, by using Zeffry, you agree to allow Zeffry to anonymously use the information from you and your experiences to improve the Zeffry experience. This research may be published on our social media accounts. However, all of your responses will be kept anonymous, and Zeffry assure you that no personal information will be published.

4. How Zeffry Share Your Information.

Zeffry may share your information, including personal information, as follows:

a. Service Providers. Zeffry will not sell, trade, or rent your Personal Information to others. However, Zeffry do provide some of our services through contractual arrangements made with affiliates, financial institutions, service providers, partners and other third parties ("Service Providers"). Our Service Providers include Human Interest and AP Intego/Next Insurance. Zeffry use Human Interest to provide 401k services to our users and AP Intego/Next Insurance to offer worker’s compensation insurance quotes and policies. Zeffry and our Service Partners may need to use some personal information in order to perform tasks between our App, or to deliver services to you.

Zeffry may also share information in the following circumstances:

a. Business Transfers. If Zeffry are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, Zeffry may transfer the information Zeffry have collected from you to the other company.

b. In Response to Legal Process. Zeffry also may disclose the information Zeffry collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

c. To Protect Zeffry and Others. Zeffry also may disclose the information Zeffry collect from you where Zeffry believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Privacy Policy, or as evidence in litigation in which Zeffry are involved.

d. Aggregate and De-Identified Information. Zeffry may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

e. With Account Administrator accounts for your company.

Zeffry may also disclose information about you that is not personally identifiable. For example, Zeffry may provide merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our users.

5. How Zeffry Protect Your Information.

To protect your personal identifiable information, Zeffry take reasonable precautions and follow industry standard SSL/TLS end-to-end encryption of data in transit to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. If you provide Zeffry with your financial or any other personal information, the information is encrypted using industry standard protections in our database. All other information Zeffry collect may be stored up to one year after termination of your Account, through our internal database.

Although Zeffry have implemented commercially reasonable precautions to protect the information Zeffry collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. Zeffry are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

6. CAN-SPAM Act and Opting Out of Emails.

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. Zeffry collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions.
• Zeffry may also send you additional information related to your Account and our Services.
• Market to our mailing list or continue to send emails to our clients after an Account has been created.

To be in accordance with CAN-SPAM Zeffry agree to the following:

• NOT use false, or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Include the physical address of our business or site headquarters
• Monitor third party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email

Zeffry may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for Zeffry to process opt-out requests. If you opt-out of receiving emails about recommendations or other information Zeffry think may interest you, Zeffry may still send you emails about your Account or any other transactional or service-oriented request.

7. Payment.

If you choose to register an administrator account, payments are exclusively processed through our internal payment processing systems. If you provide Zeffry with your financial or any other personal information, the information is encrypted using industry standard protections. All payment information is stored on our Site and through our processing partners.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or Zeffry. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. Once you leave our Services or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Terms of Use.

8. Our Use of Cookies and Other Tracking Mechanisms

Zeffry may use cookies and other tracking mechanisms to track information about your use of our Site or App. Cookies are typically defined in one of two categories, session and persistent. Session cookies do not stay on your device after you close your browser and persistent cookies do remain on your device until deleted or they expire. Zeffry may combine this information with other personal information Zeffry collect from you. Cookies are alphanumeric identifiers that Zeffry transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow Zeffry to make it easier for you to navigate our Site, while others are used to enable a faster login and payment process or to allow Zeffry to track your activities on our Site or App. Our Service Providers may also place cookies on our Site in order to properly provide their services.

WHAT ARE THE DIFFERENT TYPES OF COOKIES AND HOW DO ZEFFRY USE THEM?

a) Essential: These are cookies which are essential for the running of our Site. Without these cookies, parts of our Site would not function. These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

Examples of how Zeffry may use essential Cookies include:

• Setting unique identifiers for each unique visitor, so that user numbers can be analyzed.

b) Functional: These cookies are used to remember your preferences and login information on our Site and App and to provide enhanced, more personal features. The information collected by these cookies is usually anonymized, so Zeffry cannot identify you personally. Functional cookies do not track your internet usage or gather information which could be used for selling advertising.

Examples of how Zeffry may use functional Cookies include:

• Gathering data about visits to our Site and App, including numbers of visitors and visits, length of time spent on the Site or App, or where visitors have come from.
• Eliminating the need for returning users to re-enter their login details.

c) Third Party Cookies: You may notice on some pages of our Site that cookies have been set that are not related to Zeffry. When you visit a page with content embedded from these third-party service providers may set their own cookies on your computer or mobile device. Zeffry do not control the use of these third-party cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them. Please check the third-party websites or mobile applications for more information about these cookies.

d) Disabling Cookies: Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to refuse, disable, or delete cookies, some of the functionality of our Site may no longer be available to you. Without this information, Zeffry are not able to provide you with all the requested services, and any differences in services are related to your information.

• Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Zeffry currently do not take action in response to these signals.

e) Clear GIFs, pixel tags and other technologies: Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer and phone hard drives, clear GIFs are embedded invisibly on web pages. Zeffry currently do not use any pixels or clear GIFs on our Services.

9. SMS Messaging

You have an option to choose to receive text messages (SMS) from Zeffry to keep you informed of updates and Account activity. This service is optional and does not require you to purchase goods or services from Zeffry. However, Zeffry will need to confirm your identity when signing up for an Account by using text messaging. If you give Zeffry your mobile device number and opt into such text messaging as provided below, you hereby consent to the Zeffry’s use of your mobile device number in accordance with this Privacy Policy and any applicable terms of use until you withdraw such consent. You further consent to receive phone calls or pre-recorded messages, including those from automated dialing systems. Message and data rates may apply.

• To agree to receive text messaging from Zeffry, you can opt-in and configure your text-based notifications and security settings through the Site directly.

• To discontinue receiving SMS messages from Zeffry, you can opt-out of your text-based notifications and security settings through the Site.

10. Third Party Analytics

Zeffry may use automated devices and applications to evaluate usage of our Site and, to the extent permitted, our App. Zeffry also may use other analytic means to evaluate our Services. Zeffry uses these tools to help Zeffry improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. Zeffry do not share your personal information with these third parties

11. Third-Party Links

When you click on links on our App or Site, they may direct you away from our App or Site. Zeffry are not responsible for the privacy practices of other websites or mobile applications and encourage you to read their individual privacy policies. If you visit a third-party website or mobile application link from our App or Site, you do so at your own risk.

12. How You Can Access Your Information.

You control the accuracy of your Personal Information. If your Personal Information changes, please correct, update or delete it from your Account. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or App for a period of time.

Although Zeffry describe much of the following processes throughout this Privacy Policy, please do not hesitate to email Zeffry at support@zeffry.com to receive the following information:

What personal information pertaining to you is being processed
Why this information is being processed
Who has access to this personal information about you
How this personal information is being used in automated decisions
What processes are using this information

13. Children.

The Services not intended for use by children under the age of 13. Zeffry does not allow individuals under the age of 13 to create an account, nor do Zeffry knowingly collect or use any personal information from such children under the age of 13. If you are under the age of 13, do not submit any information to our App or Site. If Zeffry learn that Zeffry collected personal information from children under the age of 13, Zeffry will take steps to delete that information as soon as possible.

14. International Data Transfer.

Zeffry is a United States company. If you are located outside the United States and choose to provide information to Zeffry, Zeffry transfers and stores personal information to the United States for processing. The U.S. may not have the same data protection laws as the country in which you initially provided the information. When Zeffry transfer your information to the U.S., Zeffry will protect it as described in this Privacy Policy. By visiting the Site, the App, using our Services or providing Zeffry with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States.

Zeffry will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although Zeffry will do our best to protect your personal data, Zeffry cannot guarantee the security of your data transmitted to our Site or App; any transmission is at your own risk. Once Zeffry have received your information, Zeffry will use strict procedures and security features in an effort to prevent loss, theft and unauthorized access, use and disclosure.

15. California Residents: California Consumer Protection Act (“CCPA”)

The California Consumer Privacy Act (CCPA) provides consumers who are residents of the State of California with specific rights related to their personal information (which includes Personally Identifiable Information), subject to certain exceptions. It also requires Zeffry to disclose the information Zeffry collect, the purposes for which Zeffry collect it, and what Zeffry share and disclose.

The Personal Information Zeffry Collect and Why

You have the right to know what personal information Zeffry collect and why. The information Zeffry collect and the purposes for which Zeffry use it are described in this Privacy Policy.

The Personal Information Zeffry Share or Disclose

You have the right to know what personal information Zeffry disclose or share with third parties. The personal information Zeffry share is described in this Privacy Policy.

Right to Know

You have the right to ask Zeffry what personal information Zeffry have collected from you over the past 12 months. You may make such requests up to twice a year.

Right to Delete

You have the right to ask Zeffry to delete your personal information. In certain circumstances the law may not require or permit Zeffry to delete certain personal information, but if Zeffry cannot honor a deletion request, Zeffry will tell you.

Right to Opt-Out (“Do Not Sell”)

You have the right to tell Zeffry not to disclose or transfer your personal information to a third party in exchange for something of value. The CCPA refers to this as your right to say “Do Not Sell” my personal information. If you opt out of disclosure or transfer of your personal information, you may later opt-in again to having your personal information move more freely.

Exercising Your Rights

Right to Know and Right to Delete

You may ask Zeffry for the personal information Zeffry have about you, or ask Zeffry to delete your personal information, by emailing Zeffry at info@Zeffry.org. When you make a request online, Zeffry will verify your identity by sending you an email and asking you to respond.

If you ask what personal information, Zeffry have received from you, and Zeffry cannot verify your identity, or if providing the information you have requested creates a security risk, Zeffry will give you a general description of the type of personal information Zeffry have about you.

If you ask Zeffry to delete your personal information, and Zeffry can’t verify your identity and confirm that you made the request, Zeffry will not be able to honor it. Generally, though, if Zeffry can confirm your identity and your request, Zeffry will delete, de-identify, or aggregate your personal information so it can no longer be associated with you. There are some reasons that the law may require or permit Zeffry to keep your personal information, however.

Authorized Agents

If you are an authorized agent, you must make your request by emailing Zeffry at support@Zeffry.com and put the words “CCPA Requests, Authorized Agents” in the subject field. You also need to attach to your email proof that you are registered with the Attorney General, as required by law, and proof you have written authority to act for the consumer. You shall also provide the email address of the consumer you are representing so Zeffry can verify their identity or provide documentation that you have power of attorney for the consumer pursuant to Probate Code sections 4000-4465. Zeffry will not be able to honor requests without sufficient documentation that you are authorized to represent the consumer.

Requests made on behalf of a “Household”

If you would like to request personal information about your household, you may make your request by emailing Zeffry at support@Zeffry.com and putting the words "CCPA Household Request” in the subject field of the email. Zeffry will need to verify the users of the household, and in some cases, if a request raises security concerns for any household member, Zeffry may not be able to honor the request.

Financial Incentives

Zeffry do not offer any financial incentives for consumers to take any action or make any choices in using our services.

Non-Discrimination

Zeffry will not discriminate against you for exercising any of the rights described in this Privacy Policy. Specifically, Zeffry will not deny you goods or services or charge you different prices or rates for goods or services, including through the use of discounts or other benefits, or by imposing penalties.

California “Shine the Light” Law

Residents of the State of California may request a list of all third parties to which Zeffry have disclosed certain information during the preceding year for those third parties' direct marketing purposes.

California “Eraser” Law

If you are a California resident under the age of 18, and a user of the Services where this policy is posted, you may request removal of content or information you have publicly posted. Please be aware that such a request does not ensure complete removal from the Internet of the content or information you posted, and there may be circumstances in which the law does not require or allow removal.

Exercising these Rights

For all requests under the “Shine the Light” or “Eraser” Law, you must put the words "Your California Privacy Rights Shine the Light/Eraser Law" in the subject field of an email to support@Zeffry.com. You must also include your full name, street address, city, state, and zip code. Zeffry will accept requests to exercise these rights only by email with the proper subject line and complete and accurate information.

Contacting Zeffry

You may contact Zeffry with questions about Your California Rights or our Privacy Policy and practices at support@Zeffry.com.

16. Changes to Privacy Policy.

Zeffry reserves the right to change this Privacy Policy from time to time as it sees fit and your continued use of the Service will signify your acceptance of any adjustment to this Privacy Policy. If there are any changes to our Privacy Policy, Zeffry will announce that these changes have been made on our home page and on other key pages on our Services. If there are any changes in how Zeffry use our customers’ personal information, notification by e-mail will be made to those affected by this change. Any changes to our Privacy Policy will be posted on our Services 30 days prior to these changes taking place. You are therefore advised to re-read this statement on a regular basis.

Zeffry