Effective date: 10 - 01 - 2019
We at Zilingo (hereinafter referred to as “Zilingo or Company”) know you care about how your
personal information is used and shared, and we take your privacy seriously. Please read the
manner, you acknowledge that you accept the practices and policies outlined in this Privacy
Policy, and you hereby consent that we will collect, use, and share your information in the
that we gather when you are accessing or using our Services, but not to the practices of companies
we don’t own or control, or people that we don’t manage. We gather various types of Personal
Data from our users, as explained in more detail below, and we use this Personal Data internally in
connection with our Services, including to personalize, provide, and improve our services, to allow
you to set up a user account and profile, to contact you and allow other users to contact you, to
fulfill your requests for certain products and services, and to analyze how you use the Services.
In certain cases, we may also share some Personal Data with third parties, but only as described below.
What Information does Zilingo Collect?
We collect Personal Data about you when you provide such information directly to us, when third
parties such as our business partners or service providers provide us with Personal Data about you,
or when Personal Data about you is automatically collected in connection with your use of our
Information You Provide to Us:
We receive and store any information you provide to us. For example, through the registration
process and/or through your account settings, we may collect Personal Data such as the following:
Please note that certain information may be required to register with us or to take advantage of
some of our features.
Information Collected Automatically
Whenever you interact with our Services, we automatically receive and record information on our
server logs from your browser or device, which may include the following:
Additional Information about Cookies:
us how and when you visit and use our Site and Services, to analyze trends, learn about our user
base and operate and improve our Services. Cookies are small files – usually consisting of letters
and numbers – placed on your computer, tablet, phone, or similar device when you use that device
to visit our Site. We sometimes combine information collected through Cookies that is not Personal
Data with Personal Data that we have about you, for example, to tell us who you are or whether
you have an account with us. We may also supplement the information we collect from you with
information received from third parties.
Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary
Cookies that are stored on your device while you are visiting our Site or using our Services, whereas
“persistent Cookies” are stored on your device for a period of time after you leave our Site or
Services. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie.
We use persistent Cookies to store your preferences so that they are available for the next visit, and
to keep a more accurate account of how often you visit our Services, how often you return, how
your use of the Services may vary over time. We also use persistent Cookies to measure the
effectiveness of advertising efforts. Through these Cookies, we may collect information about your
online activity after you leave our Services. Your browser may offer you a “Do Not Track” or
“DNT” option, which allows you to signal to operators of websites, and web applications, and
services that you do not wish such operators to track certain of your online activities over time and
across different websites. Because we collect browsing and persistent identifier data, the Services
do not support Do Not Track requests at this time, which means that we may collect information
about your online activity both while you are using the Services and after you leave our properties.
Some Cookies are placed by a third party on your device and may provide information to us and
third parties about your browsing habits (such as your visits to our Site or Services, the pages you
have visited and the links and advertisements you have clicked). These Cookies can be used to
determine whether certain third party services are being used, to identify your interests, to retarget
advertisements to you and to serve advertisements to you that we or others believe are relevant to
you. We do not control third party Cookies.
We use the following types of Cookies:
You can decide whether or not to accept Cookies. One way you can do this is through your internet
browser’s settings. Most browsers have an option for turning off the Cookie feature, which will
prevent your browser from accepting new Cookies, as well as (depending on the sophistication of
your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways.
You can also delete all Cookies that are already on your computer. If you do this, however, you
may have to manually adjust some preferences every time you visit a site and some Services and
functionalities may not work.
To explore what Cookie setting are available to you, look in the “preferences” or “options” section
of your browser’s menu. To find our more information about Cookies, including information about
how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or
Additional information about interest-based advertisements:
Information We Receive From Third Party Sources
Some third parties such as our business partners and service providers provide us with Personal
Data about you, such as the following:
How Do We Use Your Personal Data?
We process Personal Data to operate, improve, understand and personalize our Services. For
example, we use Personal Data to:
Create and manage user profiles
As noted above, we may communicate with you if you’ve provided us the means to do so. For
example, if you’ve given us your email address, we may send you promotional email offers on
behalf of other businesses, or email you about your use of the Services. Also, we may receive a
confirmation when you open an email from us. This confirmation helps us make our
communications with you more interesting and improve our services. If you do not want to receive
communications from us, please indicate your preference by emailing us at
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for
processing include consent, contractual necessity and our “legitimate interests” or the legitimate
interest of others, as further described below.
Will Zilingo Share Any of the Personal Data it Receives?
We may share your Personal Data with third parties as described in this section:
Data That’s Been De - identified
We may de-identify your Personal Data so that you are not identified as an individual, and provide
that information to our partners. We may also provide aggregate usage information to our partners
(or allow partners to collect that information from you), who may use such information to
understand how often and in what ways people use our Services, so that they, too, can provide you
with an optimal online experience. However, we never disclose aggregate usage or de-identified
information to a partner (or allow a partner to collect such information) in a manner that would
identify you as an individual person.
We share Personal Data with vendors, third party service providers, and agents who work on our
Unless we tell you differently, our agents do not have any right to use the Personal Data we share
with them beyond what is necessary to assist us.
In certain situations, businesses or third party websites we’re affiliated with may sell or provide
products or services to you through or in connection with the Services (either alone or jointly with
us). You can recognize when an affiliated business is associated with such a transaction or service,
and we will share your Personal Data with that affiliated business only to the extent that it is related
to such transaction or service. We have no control over the policies and practices of third party
websites or businesses as to privacy or anything else, so if you choose to take part in any transaction
or service relating to an affiliated website or business, please review all such business’ or websites’
Data Shared at Your Request
We also share Personal Data when necessary to complete a transaction initiated or authorized by
you or provide you with a product or service you have requested. In addition to those set forth
above, these parties also include:
User Profiles and Submissions
Certain user profile information, including your name, location, and any video or image content
that such user has uploaded to the Services, may be displayed to other users to facilitate user
interaction within the Services or address your request for our services. Please remember that any
content you upload to your public user profile, along with any Personal Data or content that you
voluntarily disclose online in a manner other users can view (on discussion boards, in messages
and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your
user name may also be displayed to other users if and when you send messages or comments or
upload images or videos through the Services and other users can contact you through messages
and comments. Additionally, if you sign into the Services through a third party social networking
site or service, your list of “friends” from that site or service may be automatically imported to the
Services, and such “friends,” if they are also registered users of the Services, may be able to access
certain non-public information you have entered in your Services user profile. Again, we do not
control the policies and practices of any other third party site or service.
We share Personal Data with our affiliates or other members of our corporate family. We may
choose to buy or sell assets, and may share and/or transfer customer information in connection with
the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we
go out of business, enter bankruptcy, or go through some other change of control, Personal Data
could be one of the assets transferred to or acquired by a third party.
Protection of Zilingo and Others
We reserve the right to access, read, preserve, and disclose any information that we believe is
agreements; or protect the rights, property, or safety of Zilingo, our employees, our users, or others.
Is Personal Data About Me Secure?
Your account is protected by a password for your privacy and security. If you access your account
via a third party site or service, you may have additional or different sign-on protections via that
third party site or service. You must prevent unauthorized access to your account and Personal
Data by selecting and protecting your password and/or other sign-on mechanism appropriately and
limiting access to your computer or device and browser by signing off after you have finished
accessing your account.
We endeavor to protect the privacy of your account and other Personal Data that we hold in our
records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use,
hardware or software failure, and other factors, may compromise the security of user information
at any time.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open account with us or as
otherwise necessary to provide you Services. In some cases we retain Personal Data for longer,
if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees
owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we
retain some information in a depersonalized or aggregated form but not in a way that would
identify you personally.
What Personal Data Can I Access?
Through your account settings, you may access, and, in some cases, edit or delete the following
information you’ve provided to us:
The information you can view, update, and delete may change as the Services change. If you
have any questions about viewing or updating information we have on file about you, please
contact us at firstname.lastname@example.org. Residents of California and the European Union may have
other rights – please see below for additional information.
What choices do I have?
You can always opt not to disclose information to us, but keep in mind some information may be
needed to register with us or to take advantage of some of our features.
You may be able to add, update, or delete information as explained above. When you update
information, however, we may maintain a copy of the unrevised information in our records. You
may request deletion of your account by emailing us at email@example.com. Some information
may remain in our records after your deletion of such information from your account. We may use
any aggregated data derived from or incorporating your Personal Data after you update or delete it,
but not in a manner that would identify you personally.
Personal Data of Children
information from children under Thirteen (13); if you are a child under Thirteen (13), please do not
attempt to register for or otherwise use the Services or send us any personal information. If we
learn we have collected personal information from a child under Thirteen (13), we will delete that
information as quickly as possible. If you believe that a child under Thirteen (13) may have
provided us personal information, please contact us at firstname.lastname@example.org.
from time to time as well, but we will alert you to changes by placing a notice on
https://business.zilingo.com/en-us/, by sending you an email, and/or by some other means.
Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t
provided us with your email address), those legal notices will still govern your use of the
Services, and you are still responsible for reading and understanding them. If you use the
time such information is used.
The following terms apply to residents of California:
Erasure. You may request that we delete the Personal Data that we have collected from you
by emailing us at email@example.com. However, we may not be required to delete your
Personal Data under certain circumstances, including if such data is necessary
for us to provide you with the Services, if we use such data only for our internal
analytical use, and if such data is needed to complete a transaction or other action you
have requested. If you request that we delete your Personal Data, you may no longer be
able to use the Services.
European Union Residents
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or
Iceland, you may have additional rights under the EU General Data Protection Regulation (the
“GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the
GDPR, but “Personal Data” generally means information that can be used to individually identify
a person, and “processing” generally covers actions that can be performed in connection with data
such as collection, use, storage and disclosure. Zilingo will be the controller of your Personal Data
processed in connection with the Services.
the policy or portion that is more protective of Personal Data shall control to the extent of such
conflict. If you have any questions about this section or whether any of the following applies to
you, please contact us at firstname.lastname@example.org.
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For
more information about these rights, or to submit a request, please email
email@example.com. Please note that in some circumstances, we may not be able to fully
comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the
rights of others, or if it is not required by law, but in those circumstances, we will still respond to
notify you of such a decision. In some cases, we may also need to you to provide us with
additional information, which may include Personal Data, if necessary to verify your identity and
the nature of your request.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Zilingo and its service
providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where
you reside. By using the Services, you acknowledge that any Personal Data about you, regardless
of whether provided by you or obtained from a third party, is being provided to Zilingo in the
U.S. and will be hosted on U.S. servers, and you authorize Zilingo to transfer, store and process
your information to and in the U.S., and possibly other countries. You hereby consent to the
transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating
standard data protection clauses promulgated by the European Commission, a copy of which can
be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087, (ii)
binding corporate rules for data protection that align with the GDPR’s requirements, or (iii)
adherence to an industry- or technology-specific approved code of conduct blessed by the
Company has certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks set forth by the
U.S. Department of Commerce regarding the collection and use of Personal Data transferred from
the EU and Switzerland to the U.S., respectively. For more information about the Privacy Shield
Program, and to view Company’s certification, please visit http://www.privacyshield.gov. Company is
committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for
onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7)
recourse, enforcement and liability with respect to all Personal Data received from within the EU
and Switzerland in reliance on the Privacy Shield. The Privacy Shield Principles require that we
remain potentially liable if any third party processing Personal Data on our behalf fails to comply
with these Privacy Shield Principles (except to the extent we are not responsible for the event
giving rise to any alleged damage). Company’s compliance with the Privacy Shield is subject to
the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Please contact us at firstname.lastname@example.org with any questions or concerns relating to our
Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy
Shield-related complaint from us, or if we have not resolved your complaint, you may also
resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution
provider located in the United States. You can visit https://www.jamsadr.com/file-an-eu-us-
privacy-shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you.
Under certain conditions, you may also be entitled to invoke binding arbitration for complaints
not resolved by other means.
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed
message to the physical or email address below, and we will try to resolve your concerns:
2035 Sunset Lake Road, Suite B-2, Newark-19702 County- New Castle (Registered address for
Effective: 10 - 01 - 2019
placed on your computer, tablet, phone, or similar device, when you use that device to visit a Site.
We will refer to cookies and similar technologies simply as “Cookies” for the remainder of this
how and when you visit and otherwise use the Services through the internet, to analyze trends, and
to learn about our user base.
We may combine non-personally identifiable information collected through cookies with other
Personal Information that we have about you, for example, to tell us who you are or whether you
have an account. We may also supplement the information we collect from you with information
received from third parties in order to enhance our Services, or to offer you information that we
identifiable, or that can become personally identifiable if we combine it with other information, the
You can control and/or delete cookies as you wish – for details, see aboutcookies.org. Most
browsers have an option for turning off the cookie feature, which will prevent your browser from
accepting new cookies, as well as (depending on the sophistication of your browser software)
allowing you to decide on acceptance of each new cookie in a variety of ways. You can delete all
cookies that are already on your computer and you can set most browsers to prevent them from
being placed. If you do this, however, you may have to manually adjust some preferences every
time you visit a site and some services and functionalities may not work. We strongly recommend
that you leave cookies active, because they enable you to take advantage of the most attractive
features of the Services.
Further information on cookies can be found at
public/online/cookies/, or http://www.allaboutcookies.org/.
These are cookies that are required to provide you with features or services that you have requested.
For example, Cookies that enable you to log into secure areas of our site or use a shopping cart.
Disabling these Cookies will encumber the Services’ performance and may make certain features
and services unavailable.
These Cookies are used to recognize you when you return to our Services. This enables us to
personalize our content for you, greet you by name, and remember your preferences (for example,
your choice of language or region).
Performance/Analytical Cookies allow us to understand how visitors use our Website and Service
such as by collecting information about the number of visitors to the Website, what pages visitors
view on our Website and how long visitors are viewing pages on the Website.
Performance/Analytical Cookies also help us measure the performance of our advertising
campaigns in order to help us improve our campaigns and the Service’s content for those who
engage with our advertising.
Retargeting/Advertising Cookies collect data about your online activity and identify your interests
so that we can provide advertising that we believe is relevant to you.
Third Party Cookies
These are Cookies placed by a third party on your device and may provide information to those
third parties about browsing habits (including your visits to our Services, the pages you have visited
and the links and advertisements you have clicked) that may help identify if certain services that
such third parties provide are being used, identify your interests, retarget you and serve
advertisements that are relevant to you. We do not have control or access to such Cookies. If you
look at one page on our Services, an advertisement may be delivered to you on our Services or on
other sites, for products referenced on that page or for similar products and services. We do not
engage in retargeted advertising for children users of our Services.
Opt-out options are also available on the websites of the Network Advertising Initiative (NAI), the
Digital Advertising Alliance (DAA) and the European Digital Advertising Alliance (eDAA).
Session Cookies and Persistent Cookies
The types of Cookies described above may be “session Cookies” which are temporary Cookies that
are only stored on your device while you are visiting our site or “persistent Cookies” which are
Cookies that are stored on your device for a period of time after you leave our site. The length of
time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent
Cookies to store your preferences so that they are available for the next visit, and to keep a more
accurate account of how often you visit our Services, how often you return, how your use of the
Services may vary over time, and measure the effectiveness of advertising efforts. Through these
Cookies, we may collect information about your online activity after you leave our Services. Just
like any other usage information we collect, this information allows us to improve the Services and
customize your online experience. Your browser may offer you a “Do Not Track” option, which
allows you to signal to operators of websites and web applications and services (including
behavioral advertising services) that you do not wish such operators to track certain of your online
activities over time and across different websites. Our Services do not support DO Not Track
requests at this time, which means that we collect information about your online activity both while
you are using the Services and after you leave the Services.
B. WHAT IS THE GOOGLE ANALYTICS COOKIE AND HOW IS IT USED?
Our Services use Google Analytics, a web analysis service provided by Google Inc.
(“Google”) which is based on Cookie technology. The information generated by the Cookie is
usually sent to a Google server in the USA, where it is stored. [Because IP anonymization is
activated on this website, your IP address is abbreviated after being received by Google.] On behalf
of [Company], Google will use the generated information to evaluate your use of the website, to
compile reports on website activities, and to provide the website operator with additional services
connected with website and Internet use. The IP address transmitted by your browser in connection
with Google Analytics is not collated with other data by Google. To opt out of being tracked by
Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
C. COOKIE SETTINGS
You can decide whether or not to accept Cookies. One way you can do this is through your internet
browser’s settings. To find our more information about Cookies, including information about how
to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or
To explore what Cookie setting are available to you, look in the “preferences” or “options” section
of your browser’s menu.