Zaiku Group LTD and its subsidiaries (collectively, “Zaiku”) are committed to protecting your privacy and ensuring you have a positive experience on our websites and in using our products and services (“Solution” or “Solutions”). This Privacy Statement applies to our Solutions with websites or agreements that link to this Statement, but does not apply to those Zaiku Solutions with websites or agreements that have their own privacy statement. Our handling practices for Personal Information are set forth in this Privacy Statement, in the supplements to this Privacy Statement and in the notices we provide to you at the point of collection.

This privacy statement should be read in conjunction with privacy supplements which we publish from time to time and any other notice which we provide to you.

We know that your privacy is important to you, so this Privacy Statement explains:

• How we collect information and what information we collect.
• How we use, disclose, transfer and store the information we collect.

By using our Solutions, you consent to the collection, use, and disclosure of the information we collect in accordance with this Privacy Statement.

We have tried to keep this Privacy Statement as simple as possible. To assist in your review, here are a few important terms we use in the Privacy Statement and the meanings we give to them:

• Solutions: When we refer to “Solutions” in this policy, we mean any product, service, network, device, platform, software, apps or website offered by us to you or that you may make available to your customers, employees or visitors.

• You: When we say “you” in this policy, we mean you, your employees, your visitors and any other individuals you let use or access our Solutions.

• Zaiku: When we say, “we”, “Zaiku” or “us” we mean either Zaiku Group LTD or one of its worldwide subsidiaries – please see “Who we are” below in this regard.

• Personal information: When we talk about “Personal Information”, we mean information that can be used to identify you, such as your name, address, email address or phone number. “Personal Information” does not include depersonalized or aggregated information. Aggregated information is information that we collect about a group or category of products, services, users or individuals who access our Solutions that is not personally identifiable or from which individual entities are removed. We may use and disclose aggregated information, and other non-personally identifiable information, for various purposes at our sole discretion and without notice or liability to you.liability to you.

HOW DO WE COLLECT INFORMATION AND WHAT INFORMATION DO WE COLLECT?

We collect Personal Information and other information when you provide it to us. For example, when you contact us or when a device connects to a Zaiku Solution, we collect information – this can happen both automatically and when we ask you to provide information to us. While you frequently will know when you are using our Solutions, in some cases your device (or the devices of your employees, visitors and other end-users) may do so automatically.

COLLECTION OF VOLUNTARILY-PROVIDED INFORMATION

We collect information that you provide to us in a variety of ways. These include the following:

• User Accounts and Profiles. Some of our Solutions may allow you register for an account or to create and update a user profile. If we offer user account or profile functionality on a Solution, we will collect the Personal Information that you provide to us in the course of registering for the account or creating or updating a user account or profile. This information may include, for example, name, postal address, email address, telephone number, credit card information, promotional preferences, age and, potentially, related demographic information about you. We may indicate that some Personal Information is required for you to register for the account or to create the profile, while some is optional.

• Correspondence. If you contact us by email, using a contact form or by other means, we will collect the Personal Information contained in and associated with your correspondence.

• Chatrooms. If you participate in a Zaiku Group discussion forum or chat room on a Zaiku Group website, you should be aware that the information you provide there will be collected by us and will be made broadly available to others, and can be read, collected or used by other users of these forums both inside and outside of Zaiku Group.

• Newsletters. We may email newsletters from time to time relating to our Solutions. If you sign up to receive a newsletter from us, we will collect your email address.

• Customer Support. Many of our customers choose to provide information to us when they request technical support.

COLLECTION OF PASSIVELY-PROVIDED INFORMATION

We also collect information (both Personal Information and non-Personal Information) on you automatically.

For example, when you access certain of our Solutions, we may automatically collect your browser’s Internet Protocol (IP) address, your browser type, the nature of the device from which you are accessing our Solutions (e.g., a personal computer or a mobile device), identifiers for any handheld or mobile device that you may be using, the Web site that you visited immediately prior to accessing any Web-based Solutions, the actions you take once connected to our Solutions, and the content, features and activities that you access and engage with on our Solutions. We also may collect information regarding your interaction with email messages from us, such as whether you opened, clicked on, or forwarded a message.

We may collect this information passively using technologies such as standard server logs, cookies, and clear GIFs (also known as “Web beacons”). We use passively-collected information for a variety of reasons, including to administer, operate, maintain and improve our Solutions and our other services and systems and to provide content that is tailored to you.

When you use a location-enabled Zaiku Group service, we may collect, process, use and share information about your actual real-time geographic location, such as signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on and to nearby Wi-Fi access points.

If we link or associate any information gathered through passive means with Personal Information, or if applicable laws require us to treat any information gathered through passive means as Personal Information, we treat the combined information as Personal Information under this Privacy Statement. Otherwise, we use and disclose information collected by passive means in aggregated form or otherwise in a non-personally identifiable form.

NETWORK USAGE INFORMATION COLLECTED BY OUR PRODUCTS

Some of our Solutions collect information from terminal devices connected to networks that are managed by those Solutions. This information may include, for example, MAC address, device type, device model number, operating system, software versions, geolocation information, network traffic information (e.g., hostnames, protocols, port numbers and IP addresses) and device location information (e.g., GPS data, zip code, time zone and/or location coordinates), as well as mobile network information and platform information.

INFORMATION WE MAY RECEIVE ABOUT YOU FROM OTHER SOURCES

We may receive information about you, including Personal Information, from affiliated and unaffiliated third parties, and may combine this information with other Personal Information we maintain about you. If we do so, this Policy Statement governs any combined information that we maintain in personally identifiable format.

INFORMATION YOU MAY PROVIDE ABOUT OTHERS

If you provide Personal Information about another person (e.g. name, email and phone number), we will assume that you have that person’s permission to provide us with that information.

HOW DO WE USE YOUR INFORMATION?

We use the Personal Information we collect for various reasons. These include:

• to provide you with requested Solutions and respond to your inquiries;
• to enable use of certain features of our Solutions;
• to enable your use of our password protected “Channel Partner Site” portal;
• to manage our, and our customers’, networks;
• to notify you of changes to our policies or Solutions or of offers or events that may interest you;
• to conduct surveys, marketing promotions, direct mail, webinars, podcasts, teleconferences, seminars, or executive roundtables;
• to inform you of career opportunities or perform other Human Resources activities;
• to allow you to view or access white papers, technical briefs or product demonstrations;
• to process your orders and assist you in purchasing our Solutions;
• to activate and renew your subscriptions;
• to enhance, improve, operate, maintain and debug our website, services, programs and systems;
• to prevent fraudulent use of our Solutions;
• to prevent or take action against activities that are, or may be, in violation of our end-user license agreement or terms of use;
• to maintain a record of our dealings with you;
• to identify or troubleshoot issues and provide technical support or consulting services;
• to improve our existing Solutions and develop new ones;
• to otherwise operate our business; and
• for other purposes that we may disclose to you at the point at which we request your Personal Information.

As part of providing you with enhanced or new Solutions, we may use Personal Information we collect to:

• analyze your habits (which lets us do things such as identifying which Zaiku Group Solutions best suit you);
• analyze your usage of Zaiku Group Solution features (which lets us continually customize and improve our Solutions);
• analyze the aggregated profiles of users of our Solutions;
• analyze depersonalized network information to assist us with improving and managing the network and to monitor and analyze trends;
• provide notices of available software and app upgrades / updates;
• combine and link personal information we collect from you or your device with personal information we already have or that we obtain from other sources (which help us improve its overall accuracy and completeness and provides richer information about you so that we can deliver improved and more advanced and personalized Solutions); and
• show you more relevant ads on third party websites.

We also collect non-Personal Information and aggregated information – data in a form that does not permit direct association with any specific individual. We may collect, use, transfer and disclose non-Personal Information and aggregated information for any purpose. The following are some examples of non-Personal Information and aggregated information that we collect and how we may use it:

• We may collect information such as occupation, language, zip code, area code, unique device identifier, location and time zone in which a device is used so that we can better understand user behaviour and improve our Solutions.

• We may also collect information and share that information to show trends about the general use of our Solutions. The ways in which our business customers collect, use, disclose, and protect information received from or about users of our Solutions is set out in their own privacy statements, not this Privacy Statement. We are not responsible for what they do with your Personal Information.

DISCLOSURE OF YOUR INFORMATION

We are not in the business of selling your Personal Information to third parties. However, we may disclose your Personal Information to third parties from time to time including in the following circumstances:

• Consent: if we get your consent;
• Required by law: if are required to by applicable law, legal process or demand of a governmental authority;
• Protection: if we believe disclosure is necessary to protect our rights, our customers or others;
• Corporate transaction: if we are involved in a merger, acquisition, partial or total sale of assets or other corporate change;
• Zaiku Group and partners: if we determine that one of our subsidiaries, joint venture partners or other corporate affiliates are either subject to this Privacy Statement or follow privacy practices at least as protective as these, we may disclose your Personal Information to them;
• Sales and distribution partners: if we are participating in a joint sales promotion, we may disclose your Personal Information to one of our distribution partners;
• Illegal activities: to investigate, prevent or take action regarding illegal activities, suspected or potential fraud or brand protection matters (such as unauthorized use of Zaiku Group trademarks); or
• Third party service providers: if we are using a third party service provider (such as a credit card payment processor or a third party customer support provider) and that provider has agreed to use your information only for the purposes we request.

COOKIES / ADVERTISING NETWORKS We may use “cookies” and other similar technologies in connection with our websites, products and advertisements.

We may work with third-party advertising companies that collect and use information to deliver more relevant advertising across the Internet and when you are using our products and services.

LOCATION OF PERSONAL INFORMATION

As Zaiku Group is a global organization, we may transfer your Personal Information to different countries worldwide. Your Personal Information may, for example, be maintained, processed and stored by us, our affiliates, and our service providers in the United Kingdom or other countries. These countries may have different data protection rules and standards to those in your own country. We have developed our privacy practices to provide a globally consistent level of protection for Personal Information. This means that we will handle your Personal Information in the manner described in this Privacy Statement, even in countries whose laws provide less protection for your information. If you reside or are based in the European Union, You agree to the transfer and hosting of your Personal Information outside of Europe by using or accessing Zaiku Group Solutions.

PROTECTION OF PERSONAL INFORMATION

We recognize that security is important to you. While no product or service is completely secure, we have implemented reasonable industry-standard physical, electronic, and organizational measures to safeguard the security of your Personal Information.

THIRD-PARTY SERVICES / WEBSITES

Our Solutions may enable you to access or otherwise use third-party products and services and our websites may contain links to third-party websites. Such third parties have their own policies that govern their collection, use, and disclosure of information. We suggest that you read their privacy policies to learn about their practices, as we are not responsible for them.

CHILDREN’S PRIVACY

Zaiku Group does not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected Personal Information of a child under the age of 13, we will delete that data from our systems.

YOUR CHOICES / OPT-OUT

You can exercise choices regarding our use of your Personal Information:

• Promotional Communications: We will only send you promotional communications where we are permitted to do so by applicable law. If you do not want to receive promotional communications from us, you can change your preferences by following the instructions on the communication (e.g. clicking unsubscribe in an email), though in some cases you will still receive certain mandatory service / product related emails.

• Cookies: If you do not want us to store or otherwise use cookies on your computer, your browser may offer tools to disable or reject cookies (though you may not be able to use some website features if you do so).

• Apps: If you do not want us to collect location or other information from an Zaiku Group powered app, you can refrain from installing it or, if it is too late for that, uninstall it using your mobile device’s “uninstall” procedure. If you decide that you do not want us to collect location data, you can disable location services on your device. This is normally done through the device’s settings’ menu.

CHANGES TO THIS POLICY

Our business changes constantly and our Privacy Statement will also change, so please review it frequently. If we make a material change in how we treat your Personal Information, we will take reasonable steps to notify you in advance of the planned change.

QUESTIONS

If you are a human (not bot!) and have any questions about this Privacy Statement, please send an email to hello[[[AT]]zaikugroup.com  or send a letter to Zaiku Group LTD, 7th Floor, 4 Saint Paul`s Square, L3 9SJ, Liverpool.