PRIVACY AND SECURITY POLICY

tZERO Group, Inc. (tZERO, we, or us) has created the following Privacy and Security Policy (Privacy Policy) to inform you of the following: what information we collect, when we collect it, how and why we collect it, how we use it, how we protect it, how we share it and what choices you have regarding our collection and use of this information.

This Privacy Policy applies to the following site: https://www.tzero.com (the Site). Entering the Site constitutes your acceptance and agreement to the terms contained in this Privacy Policy. If you do not agree with the terms set forth in this Privacy Policy, please do not enter the Site.

WHAT INFORMATION WE COLLECT
Types of Information We Collect
  • Your name
  • Your e-mail address
  • Your phone (or mobile) number
  • Information on how you are using the Site
We Collect Information When
  • You request information about our products and services from the Site or mobile applications.
  • You visit the Site or participate in interactive features of the Site or mobile applications.
  • You use a social media service, for example, our Facebook page or YouTube channel.
  • You sign up for e-mails, mobile messages, or social media notifications from us.
  • You enter a contest or sweepstakes, respond to one of our surveys, or participate in a focus group.
  • You provide us with comments, suggestions, or other input.
  • You interact with any of the Sites through your computer, tablet or mobile device.
HOW AND WHY WE COLLECT INFORMATION
Technologies Used

We may use tracking pixels/web beacons, cookies and or other technologies to receive and store certain types of information. This information includes Internet Protocol (IP) addresses, browser information, Internet Service Provider (ISP), operating system, date/time stamp and clickstream data. This information helps us customize your website experience and make our marketing messages more relevant. It also allows us to provide features such as storage of items in your cart between visits. This includes our content presented on other websites or mobile applications. In order to provide the best customer experience possible, we also use this information for reporting and analysis purposes, such as how you are interacting with our website, performance of our marketing efforts, and your response to those marketing efforts.

Third Party Cookies

We allow third-party companies to collect anonymous information when you visit the Site and to use that information to serve ads for our products or services or for products or services of other companies when you visit the Site or other websites. These companies may use anonymous information (e.g., navigational, non-personally identifiable information, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, etc.) during your visits to the Site and other websites in order to provide advertisements about our goods and services likely to be of interest to you. These parties may use a cookie or a third party web beacon, or other technologies, to collect this information.

To opt out of third-party vendors' cookies, see the What Choices Do You Have? section of this privacy policy for instruction how to do so.

User Experience Information

In order to improve customer online shopping experience, help with fraud identification, and to assist our customer care representatives in resolving issues customers may experience in completing online purchases, we use tools to monitor certain user experience information, including, but not limited to, login information, IP address, data regarding pages visited, specific actions taken on pages visited (e.g., information entered during checkout process), and browser information.

Information from Other Sources

We may also obtain information from companies that can enhance our existing customer information to improve the accuracy and add to the information we have about our customers (e.g., adding address information). This may improve our ability to contact you and improve the relevancy of our marketing by providing better product recommendations or special offers that we think will interest you.

Public Forums

Any information you submit in a public forum (e.g., a blog, chat room, or social network) can be read, collected, or used by us and other participants, and could be used to personalize your experience. You are responsible for the information you choose to submit in these instances.

Mobile Privacy

We offer mobile applications (commonly known as apps) that allow you to check product availability, learn about sales events, or receive other information from us. All information collected by us via our mobile application is protected by this Privacy Policy.

Although you do not have to provide your location information to us to use our mobile applications, our services require a zip code to function. If you have questions about location and notification privacy, please contact your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

HOW WE PROTECT THE INFORMATION WE COLLECT
Security Methods

We maintain technical, administrative, physical, electronic and procedural safeguards to protect the confidentiality and security of information transmitted to us. To guard this information, the Site uses Secure Sockets Layer (SSL). SSL encrypts your credit card number, name and address so only we are able to decode the information.

E-mail Security

Please note that e-mail is not encrypted and is not considered to be a secure means of transmitting credit card information. Phishing is a scam designed to steal your information. If you receive an e-mail that looks like it is from us asking you for certain information, do not respond. Though we might ask you your name, we will never request your password, credit card information or other information through e-mail.

Information About Children

We recognize the particular importance of protecting privacy where children are involved. We are committed to protecting children's privacy and we comply fully with the Children's Online Privacy Protection Act (COPPA). We will never knowingly request or collect personal information from any person under 13 years of age without prior verifiable parental consent. If we become aware that an individual is under the age of 13 and has submitted any information to us, for any purpose without prior verifiable parental consent, we will delete his or her information from our files.

Additional Security

We also ask customers to carefully review their accounts and immediately report any unexpected activity to us and their issuing bank or credit card company. We ask all our customers to take measures to help protect information in their online accounts, including the following:

  • Install the latest security updates and anti-virus software on your computer to help prevent malware and viruses.
  • Reset your e-mail account passwords frequently.
  • Use complex passwords (a minimum of 7 alpha/numeric cAsE sEnsitive characters).
  • Do not use the same password on more than one website.
  • Do not share your password with others.
  • Sign out/log off website sessions so that your session is closed and cannot be accessed by another user on the same computer, especially when using a public computer or terminal
HOW WE PROTECT THE INFORMATION WE COLLECT
General Policy

We do not sell or rent customer information to third parties; except, under limited circumstances outlined below, we may share information with third parties

Service Providers

We may share information with companies that provide support services to us (such as a printer, e-mail, mobile marketing, or data enhancement provider) or that help us market our products and services. These companies may need information about you in order to perform their functions. These companies are not authorized to use the information we share with them for any other purpose.

Legal Requirements

We may disclose information you provide to us when we believe disclosure is appropriate to comply with the law; to enforce or apply applicable terms and conditions and other agreements; or to protect the rights, property or safety of our company, our customers or others.

When You Direct Us

At your direction or request, we may share your information.

Business Transfers

If some or all of our business assets are sold or transferred, we generally would transfer the corresponding information regarding our customers. We also may retain a copy of that customer information.

WHAT CHOICES DO YOU HAVE
E-mail

Promotional E-mail. If you do not wish to receive promotional e-mails from us, click here. You also have the ability to unsubscribe to promotional e-mails via the opt-out link included in each e-mail. It may take up to 10 business days before you stop receiving promotional e-mails.. Important Notices and Transactional E-mail. From time to time, we may send non-commercial electronic email messages with important information about us or the Site to your email address.

Mobile

We may distribute mobile coupons and text messages to mobile devices of customers who have requested this information via an opt-in request. Customers will be able to opt out of a specific mobile messaging campaign.

tzero.com Cookies

The help function of your browser should contain instructions to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time. If you set your computer to not receive cookies at any time, certain personalized services cannot be provided to you, and accordingly, you may not be able to take full advantage of all of the Site features.

Third-Party Cookies

To opt-out of third-party vendor's cookies on other websites, visit the Network Advertising Initiative website, click here http://www.networkadvertising.org/choices/.

Telephone

If you do not wish to receive promotional communication from us, call us at (800) 843-2446 to opt out. This opt out does not apply to operational communication, for example, confirmation of delivery address.

SPECIAL NOTICE TO CALIFORNIA RESIDENTS

Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared personal information about you or your family for marketing purposes during the previous calendar year, and a description of the categories of the personal information shared. If you are a California resident and wish to make such a request, please send an email to [email protected] and include the phrase “California Privacy Request” in the subject line, and provide us with your name, address, and email address. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. We will respond to you within thirty (30) days of receiving such a request. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.

PRIVACY POLICY SCOPE

This Privacy Policy applies to all current or former customer information collected by or provided to us.

The Site may offer links to other sites. If you visit one of these sites, you may want to review the privacy policy on that site. In addition, you may have visited our website through a link or a banner advertisement on another site. In such cases, the site you linked from may collect information from people who click on the banner or link. You may want to refer to the privacy policies on those sites to see how they collect and use this information.

PRIVACY POLICY REVISIONS

By accessing the Site or interacting with us, you consent to our use of information that is collected or submitted as described in this Privacy Policy. We may change or add to this privacy policy, so we encourage you to review it periodically.

EU ADDENDUM

This addendum (the Addendum) provides to users of the Site (Users) that are in the European Union additional information in connection with the processing by tZERO Group, Inc. of data relating to their use of the Site (“Personal Data”) as described in the Privacy Policy and their rights in this respect. For such Users, this Addendum supplements the provisions of the Privacy Policy and, in the event of a contradiction between the Privacy Policy and the Addendum, the provisions of the Addendum shall prevail.

Purposes for Processing

tZERO processes your Personal Data for the following purposes: (1) to market our products and services to you and to respond to your queries; (2) to provide the services that you order; (3) to analyze data to send more targeted messages to you or other Users of our Site; (4) to conduct research and analyze data to improve our products, services, and Site; (5) to deliver email messages like special offers, updates, newsletters, customer service, and service announcements; (6) to verify User information; and (7) to protect our Site or its Users.

Legal Basis for Processing

tZERO processes your Personal Data on the following legal bases, depending on the processing purpose:

  • On the basis of your consent, for sending you our marketing communications and responding to your queries;
  • On the basis of the performance of a contract with you, for providing you the services that you order from us;
  • On the basis of our legitimate interest to better target our communications, for the processing activities involving the analysis of your interests and preferences and serving you ads related thereto;
  • On the basis of our legitimate interest to improve our products, services and the Site, for the processing activities relating thereto;
  • On the basis of the compliance with a legal obligation – to the extent applicable – or otherwise on the basis of our legitimate interest to ensure the security of the use of our products and services, for the processing activities relating to the verification of User information, the protection of our Site and Users;
  • On the basis of our legitimate interest to conduct and further develop our business, for processing activities required by business management and reorganization needs.
Recipients

Your Personal Data may be communicated to duly authorized personnel of tZERO, suppliers and vendors of tZERO acting on its behalf, regulators, governmental authorities and law enforcement, as well as our external advisors, to the extent required by the processing activity at stake.

Retention Period

tZERO will retain your Personal Data in accordance with the following principles:

  • Until you withdraw your consent, for our marketing activities directed to you;
  • For the duration of ou contract with you and, thereafter, during the limitation period applicable to contractual claims, for your Personal Data relating to your contract with us for the provision of our services;
  • For the period necessary for responding to you, when you send us a query;
  • For a period of 2 years, for the processing activities involving the analysis of your interests and preferences and serving you ads related thereto;
  • For a period of 2 years, for the processing activities necessary to improve our products, services and the Site;
  • For a period of six months for the processing activities required for the security of the use of our products and services, unless further retention is required pursuant to a legal obligation;
  • For the duration of the relevant business transaction, for processing activities required by business management and reorganization needs.
International Data Transfers

Your Personal Data is transferred to tZERO, which is located in the United States, on the basis of your consent to using the Site. Although the United States are not recognized as having a sufficient level of protection of personal data with respect to the requirements applicable in the European Union, tZERO will strive to comply with the legal requirements applicable to our processing of your Personal Data.

Your Rights

You have the following rights in relation to your Personal Data, subject to the applicable legal conditions: right to access and rectify your Personal Data, right to request erasure of your Personal Data, restriction of the processing or object to the processing as well as the right to portability of your Personal Data. You have the right to withdraw your consent at any time, for any processing activity that is based on your consent. You also have the right to lodge a complaint with a supervisory authority for any issue relating to the processing of your Personal Data.

In order to exercise your rights, you can contact us at [email protected] The representative of tZERO for the purpose of this Addendum is:

tZERO Group, Inc.

29 Broadway

New York, NY 10006

Attention: Legal Department

[email protected]

Cookies

The following categories of cookies may be used by the Site:

Category 1: Strictly necessary cookies.

These cookies are strictly necessary to enable you to use the Site and use its features, such as accessing your account and provide you the services you have requested.

You can deactivate these cookies using your browser settings. However, their deactivation may lead to a drop in performance of the Site or in improper functioning of the Site.

Category 2: Functionality cookies.

These cookies allow us to remember the choices you have made (such as your user name, language used or country) and provide enhanced and more relevant Site features.

  • These cookies may be used for user preferences purposes. Preference cookies remember settings you have applied to the Site (e.g. the layout, default views, search filters, number of search results per page and video bandwidth).
  • These cookies may be used for optimizing user's Site experience. The cookies are aimed at remembering recently viewed pages as well as your last search terms.

You can find out how to deactivate these cookies by visiting http://www.allaboutcookies.org. However, their deactivation will deteriorate the Site functionalities and your Site experience.

Category 3: Site performance third-party cookies.

These cookies collect information about how visitors use the Site for instance which pages visitors go to most often. Such information do not include personal data.

These cookies are only used to improve the way the Site works.

  • These cookies may be used for web analytics purposes. Google Analytics Adobe Analytics cookies are used to improve the design and the user’s Site experience by providing statistics on the use of the Site and the pages visited.
  • You can opt out of Google Analytics by following the instructions provided at https://tools.google.com/dlpage/gaoptout.
  • You can deactivate these cookies by visiting http://www.allaboutcookies.org.
Category 4: Targeting and/or Advertising third-party cookies.

These cookies which are implemented by advertising networks with the Site publisher’s consent are used to deliver more relevant ads in accordance with your interests. Such cookies are also used to remember the Sites you have visited, limit the number of times an ad is displayed to you as well as to measure the effectiveness of an advertising campaign, promotions and e-newsletters.

You can opt-out of Google Advertising by following the instructions provided at http://www.google.com/policies/technologies/ads/.

This Privacy Policy was last revised and updated on January 10, 2019.