Zelthy Privacy Policy

This Zelthy Privacy Statement ("Privacy Statement") explains our privacy practices for the activities described herein. Please read this Privacy Statement carefully to learn how we collect, use, share, and otherwise process information relating to individuals ("Personal Data"), and to learn about your rights and choices regarding your Personal Data.

A reference to "Zelthy," "we," "us" or the "Company" is a reference to Zelthy Technologies Pvt ltd. and its relevant affiliate involved in the collection, use, sharing, or other processing of Personal Data.

Zelthy is the controller of your Personal Data as described in this Privacy Statement, unless specified otherwise.

This Privacy Statement does not apply to the extent we process Personal Data in the role of a processor or service provider on behalf of our customers, including where we offer to our customers various cloud products and services through which our customers (or their affiliates): (i) create their own websites and applications running on our platforms; (ii) sell or offer their own products and services; (iii) send electronic communications to others; or (iv) otherwise collect, use, share or process Personal Data via our cloud products and services.

For detailed privacy information related to a Zelthy customer or a customer affiliate who uses the Zelthy cloud products and services as the controller, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Statement.

This Privacy Statement applies to the processing of Personal Data collected by us when you:

• Visit our websites that display or link to this Privacy Statement;
• Visit our branded social media pages;
• Visit our offices;
• Receive communications from us, including emails, phone calls, texts or fax;
• Use our cloud products and services as an authorized user (for example, as an employee of one of our customers who provided you with access to our services) where we act as a controller of your Personal Data;
• Register for, attend or take part in our events, webinars, or contests; or
• Participate in community and open source development.

Processing of Personal Data is required for receiving certain products or services.

Our websites and services may contain links to other websites, applications, and services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices.

The Personal Data we collect directly from you includes identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information. We collect such information in the following situations:

• If you express an interest in obtaining additional information about our services; request customer support (including accessing the Help & Training Portal); use our "Contact Us" or similar features; register to use our websites; sign up for an event, webinar or contest; or download certain content, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, email address or username and password;
• If you make purchases via our websites or register for an event or webinar, we may require that you provide to us your financial and billing information, such as billing name and address, credit card number or bank account information;
• If you attend an event, we may, with your further consent, scan your attendee badge, which will provide to us your information, such as name, title, company name, address, country, phone number and email address;
• If you register for an online community that we host, we may ask you to provide a username, photo or other biographical information, such as your occupation, location, social media profiles, company name, areas of expertise and interests;
• If you interact with our websites or emails, we automatically collect information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data) using cookies, web beacons, or similar technologies;
• If you use and interact with our services, we automatically collect information about your device and your usage of our services through log files and other technologies, some of which may qualify as Personal Data;
• If you communicate with us via a phone call from us, we may record that call;
• If you voluntarily submit certain information to our services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request; and
• If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival. Additionally, due to the COVID-19 pandemic, you may be required to provide information regarding your health status, including your temperature, COVID-19-related symptoms, exposure to COVID-19 positive individuals, and recent travel history.

If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us by using the information in the "Contacting us" section below.

We also collect information about you from other sources including third parties from whom we purchase Personal Data and from publicly available information. We may combine this information with Personal Data provided by you. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. The Personal Data we collect from other sources includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. In particular, we collect such Personal Data from the following sources:

• Third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information; and
• Another individual at your organization who may provide us with your business contact information for the purposes of obtaining services; and
• Platforms such as GitHub to manage code check-ins and pull requests. If you participate in an open source or community development project, we may associate your code repository username with your community account so we can inform you of program changes that are important to your participation or relate to additional security requirements.

As is true of most websites, we gather certain information automatically when individual users visit our websites. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider, mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the websites. This information is used to analyze overall trends, help us provide and improve our websites, offer a tailored experience for website users, and secure and maintain our websites.

In addition, we gather certain information automatically as part of your use of our cloud products and services. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, browser type, Internet service provider or mobile carrier, the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system and system configuration information and date and time stamps associated with your usage.

We use technologies such as web beacons, pixels, tags, and JavaScript, alone or in conjunction with cookies, to gather information about the use of our websites and how people interact with our emails.

When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer-browsing preferences, and improve and customize your browsing experience.

We use both session-based and persistent cookies on our websites. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off.

We collect and process your Personal Data for the following purposes. Where required by law, we obtain your consent to use and process your Personal Data for these purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the (a) performance of a contract or (b) legitimate interest) to collect and process your Personal Data.

• Providing our websites and services: We process your Personal Data to perform our contract with you for the use of our websites and services and to fulfill our obligations under the applicable terms of use and service;
• Promoting security: We process your Personal Data by tracking use of our websites and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies;
• Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
• Handling contact and user support requests: If you fill out a "Contact Me" web form or request user support, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
• Managing events: We process your Personal Data to plan and host events or webinars for which you have registered or that you attend;
• Managing contests or promotions: If you register for a contest or promotion, we process your Personal Data to perform our contract with you;
• Managing payments: If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments;
• Developing and improving our services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services;
• Assessing and improving user experience: We process device and usage data to analyze trends and assess and improve the overall user experience;
• Marketing communications: We will process your Personal Data to send you marketing information, product recommendations and other non-transactional communications about us and our affiliates and partners;
• Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws.

We may share your Personal Data as follows:

• Service Providers: With our contracted service providers, who provide services such as IT and system administration and hosting, research and analytics, marketing, customer support and data enrichment;
• Affiliates: If you use our websites to register for an event or webinar organized by one of our affiliates, we may share your Personal Data with the affiliate to the extent this is required on the basis of the affiliate's contract with you;
• Event Sponsors: If you attend an event or webinar organized by us, or download or access an asset on our website, we may share your Personal Data with sponsors of the event;
• Professional Advisers: In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, and insurers;
• Third Parties Involved in a Corporate Transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party.

Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16 unless (a) we have obtained consent from a parent or guardian, (b) such collection is subject to a separate agreement with us or (c) the visit by a child under the age of 16 is unsolicited or incidental. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us and we will take steps to delete their Personal Data from our systems.

We may retain your Personal Data for a period of time consistent with the original purpose of collection or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

• Access your Personal Data held by us;
• Know more about how we processed your Personal Data;
• Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
• Erase or delete your Personal Data (also referred to as the right to be forgotten), to the extent permitted by applicable data protection laws;
• Restrict our processing of your Personal Data, to the extent permitted by law;
• Transfer your Personal Data to another controller, to the extent possible (right to data portability);
• Object to any processing of your Personal Data;
• Opt out of certain disclosures of your Personal Data to third parties;
• Not be discriminated against for exercising your rights described above;
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects;
• Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

To exercise your rights, please contact us by using the information in the "Contacting us" section, below. Your personal data may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity.

10.1 Your Rights Relating to Customer Data

As described above, we may also process Personal Data submitted by or for a customer to our cloud products and services. To this end, if not stated otherwise in this Privacy Statement or in a separate disclosure, we process such Personal Data as a processor on behalf of our customer (and its affiliates) who is the controller of the Personal Data.

10.2 Your Preferences for Email and SMS Marketing Communications

If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from Zelthy by clicking on the "unsubscribe" link located on the bottom of Zelthy marketing emails, by replying or texting 'STOP' if you receive SMS communications.

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.

We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use.

While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in the "Contacting us" section, below.

We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the "effective date" at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes.

We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.

To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement email us at privacy@zelthy.com, or write to us at: