Zoombak ™

Zoombak Privacy Policy

This Privacy Policy describes the privacy polices and practices of:

(a)        Zoombak Limited in relation to its provision of the location services which are described in Zoombak’s Customer Agreement (the “Services”); and

(b)        Zoombak LLC in relation to its provision of the zoombak.com web site (the "Web site").

In this Privacy Policy, references to "Zoombak" means each of Zoombak LLC and Zoombak Limited.

Zoombak reserves the right to change this Privacy Policy at any time.  Any changes will be notified to you using the email address you have given to us or by an announcement on this Web site.

Information Zoombak Limited Collects to Provide the Services.

A person who purchases the Services (a “Customer”) must provide his or her name, address, telephone numbers, email address, and payment card information (“Personal Information”) to Zoombak Limited to activate the Services.  Customers must promptly notify Zoombak Limited of any changes to such Personal Information. Zoombak Limited may also receive other information about a Customer, such as credit information, from other sources.  Zoombak Limited will consider any such additional information about a Customer as Personal Information.  

When the Services are being used, Zoombak Limited periodically collects GPS coordinates that show the location of the pet, vehicle, item, or person that Customer chooses to track using the Services (“Location Information”).   Location Information regarding Services performed for each Customer is linked to the Personal Information of that Customer.  Zoombak Limited or its contractors retain Personal and Location Information on their servers which may be located in the United States.

Customers may suspend the collection of Location Information by turning off the Assisted GPS Device that Zoombak Limited uses to provide the Services.  Customers may terminate the collection of Location Information by terminating the Customer Agreement, as described in that agreement.

Zoombak Limited may remove data that identifies any specific Customer from Personal and Location Information and combine such data to create “Aggregate Information”.   Such anonymized Aggregate Information is not Personal or Location Information.    

A Customer’s Personal Information will be retained for as long as the Customer receives the Services and for any period during which there is a dispute between the Customer and Zoombak Limited.

Information Zoombak LLC Collects from the Web Site.

When Customers and others visit the Web site, Zoombak LLC collects the visitor’s IP address (the unique set of numbers used to identify the visitor’s computer), and his or her registered domain or home server.  Zoombak LLC also collects information pertaining to the visitor’s operating system, browser version, referring site, and keywords used to locate the Web site.  

Zoombak LLC, its contractors and other third parties that help Zoombak LLC provide the Web site (“Zoombak’s agents”) may use “cookies” to improve visitors’ experience at the Web site.  A “cookie” is a small file placed on a Web site visitor’s computer hard drive that identifies the computer and data about the visit so that, when the visitor returns to the site, the site recognizes the visitor, which allows Zoombak LLC to tailor its site to the visitor. 

Cookies do not contain personally identifiable information but may be linked to personal information that visitors provide to Zoombak LLC.  Advertisers that place ads on the Web site may use their own cookies.  Any information collected by advertisers is not subject to this Privacy Policy.

Zoombak LLC may use Web beacons, also known as “Web bugs.”   Web beacons are typically small (1x1 pixel) graphic files placed on Web pages and other electronic documents that are often the same color as the background of Web page or other file.  Web beacons can collect the IP address of the computer that the Web beacon is sent to, the URL of the page the Web beacon comes from, and the time the Web beacon was viewed.  Zoombak LLC does not place Web beacons that link to personal information on other sites, nor does Zoombak LLC permit third parties, other than those working on Zoombak’s behalf, to place them on Zoombak LLC’s site.  Zoombak LLC may use Web beacons on the Zoombak Web site and may link a particular beacon to personal information.

If a visitor to the Web site requests information from Zoombak LLC by sending Zoombak LLC an e-mail or by filling out a registration form on the Web site, Zoombak LLC may retain the visitor’s e-mail address and any other information that the visitor provides.  This information may be used by Zoombak LLC to contact the visitor in the future by mail, by e-mail, or by phone to respond to the user's inquiry.  Such information also allows Zoombak LLC to respond to visitors’ inquiries concerning career opportunities at Zoombak LLC.  Visitors will always be provided with the option not to be contacted or to unsubscribe if they register with the Web site.

How Zoombak Uses and Discloses Personal Information.

A.  Zoombak Limited's use and disclosure of Customer Information.

Zoombak Limited uses each Customer’s Personal and Location Information to provide Services to that Customer.  In order to provide the Services, Zoombak Limited will transfer Personal and Location Information to Zoombak LLC in the United States.  So as to properly protect Personal and Location Information, Zoombak LLC adheres to the US-EU Safe Harbor Privacy Principles with respect to the use and processing of such data in the United States (“EU Safe Harbor”).   For further background about the EU Safe Harbor, please refer to the U.S. Department of Commerce’s website at http://www.export.gov/safeharbor, or contact Zoombak as set out in the "Contact Us" section of this Privacy Policy.

Zoombak Limited may use or disclose Personal and Location Information to: verify payment details, perform a credit check with a licensed credit reference agency, verify your identity, create and maintain account and billing information, deliver the Services, collect payments and deal with queries or concerns the Customer may have.

Zoombak Limited may use Aggregate  Information to analyze how Customers use the Services to determine ways in which Zoombak Limited can improve the Services and to consider offering new services to Customers.  

B. Zoombak LLC's use of Web site users' information.

Zoombak LLC may use Web site users' personal information to deal with queries or concerns that the user may have. Zoombak LLC may also use information from a Web beacon to ensure that a Customer can move between Zoombak LLC’s technical assistance Web page, the Customer service page, and Zoombak LLC’s online store and still be recognised as the same Customer. Zoombak LLC may use information collected from the Web site to analyze traffic to the Web site to determine how to improve the site.

Additionally, Zoombak LLC will store personal information provided by Web site users on servers that are located in the United States. Where personal information is stored on services located in the United States, Zoombak LLC will ensure that appropriate security measures are taken to safeguard that personal information.

C. Zoombak's general use and disclosure of Personal Information.

Neither Zoombak Limited nor Zoombak LLC currently shares, sells, or rents any Personal or Location Information or information collected from the Web site to any third parties, other than contractors and other third parties that help Zoombak Limited provide the Services and Zoombak LLC provide the Web site (“Zoombak’s agents”).  

Zoombak Limited and Zoombak LLC may use and disclose such information to comply with applicable laws; to protect the rights and property of Zoombak Limited, Zoombak LLC or others; to protect a person’s safety; to prevent abuse; as evidence in legal proceedings and to cooperate with properly authorised law enforcement investigations and to comply with any court order from a court of competent jurisdiction.

Zoombak Limited and Zoombak LLC (as applicable) will use good faith efforts to promptly notify a Customer of any court order that seeks any of the Customer’s Personal or Location Information to enable the Customer to seek to challenge the court order.  Finally, Zoombak Limited may disclose or sell Customer Personal Information and Zoombak LLC may disclose or sell information collected from the Web site, as an asset in conjunction with the sale of Zoombak Limited or Zoombak LLC to a third party or in conjunction with the sale of a portion of Zoombak Limited’s or Zoombak LLC's assets.

Zoombak Limited and Zoombak LLC may share Personal Information, Location Information, and information collected from the Web site (as applicable) with Zoombak’s agents, corporate affiliates, or advisors who help Zoombak Limited or Zoombak LLC operate and improve its business.  Zoombak Limited and Zoombak LLC have entered into written agreements with their agents, corporate affiliates, and advisors to which they disclose Personal Information, Location Information, and information collected from the Web site (as applicable) that requires them to adhere to pertinent provisions of this Privacy Policy, the UK Data Protection Act 1998 and the Safe Harbor Principles issued by the U.S. Department of Commerce, which are available at http://www.export.gov/safeharbor/SH_Privacy.asp. These written agreements ensure that the recipient of the data will provide an adequate level of protection for personal information and that appropriate security measures for protection of the data are in place. Zoombak also prohibits its agents, corporate affiliates, and advisors from using any information disclosed to them by Zoombak for purposes other than implementing Zoombak’s instructions.

How Zoombak Limited uses Location Information

Zoombak Limited's location service is designed to allow Customers to monitor the location of the pet, vehicle, or person chosen by the Customer. Zoombak Limited processes the Location Information on the Customer's behalf in order to provide the Services, but the Customer retains control over whether Zoombak Limited processes Location Information and what Location Information Zoombak Limited processes.

Zoombak Limited has put in place measures that comply with the Industry Code of Practice for the Use of Mobile Phone Technology to Provide Passive Services in the UK ("the Code").  These include measures to verify the identity of the person wishing to use the passive location based service and to ensure the ongoing consent of the person, if relevant, who is being located.

How to Access and Correct Information Obtained by Zoombak.

A Customer may obtain a copy of the Personal Information and the information collected from the Web site that Zoombak holds regarding that Customer by emailing a request for a copy of that information to privacy@zoombak.com or by sending a letter to Zoombak Ltd., Gainsborough House, 59-60 Thames Street, Windsor SL4 1TX, United Kingdom. Zoombak will mail the information to the Customer at the address previously provided by the Customer if it is supplied with sufficient information to allow it to confirm the identity of the person making the request. If any of the information regarding the Customer is inaccurate, the Customer may send corrected information and a request that Zoombak corrects its records to Zoombak Ltd., Gainsborough House, 59-60 Thames Street, Windsor SL4 1TX, United Kingdom.

How Information Is Secured.

Zoombak Limited uses a variety of physical, technical, and procedural safeguards to guard against loss, misuse, and alteration of Personal and Location Information.   For example, Location Information transmitted from Devices to Zoombak Limited is encrypted; access to Personal Information is limited to Zoombak Limited and contractor personnel who need the information to provide the Services; and Zoombak Limited uses and requires its contractors to use technical measures to guard against unauthorised access to Personal and Location Information.  In the same way Zoombak LLC uses and requires its contractors to use technical measures to guard against unauthorised access to Personal Information collected from the Web site,  Zoombak Limited also requires Customers to use user identification and passwords to access Personal and Location Information.  Similarly, when visitors conduct payment card transactions with Zoombak Limited using the internet, Zoombak Limited uses procedures required by the Payment Card Industry Data Security Standards. 

Zoombak cannot, however, guarantee the security of any Personal or Location Information, or information collected from the Web site.  Despite Zoombak’s efforts to secure such information, it may be accessed, disclosed, altered, or destroyed by a breach of Zoombak’s physical, technical, and procedural safeguards.  Customers use the Services and visitors use the Web site at their own risk.  If Zoombak Limited or Zoombak LLC learns that a Customer’s Personal or Location Information has been disclosed to an unauthorized person, Zoombak Limited or Zoombak LLC (as applicable) will attempt to notify the Customer.

Children’s Information.

Zoombak recognizes the importance of protecting the privacy of children.  Zoombak will not knowingly collect any personally identifiable information from children.  The Web site is not directed to children under the age of eighteen.  

When a visitor to the Web site discloses information on the Web site, the visitor represents that he or she is an adult.  If a child visits the Web site and provides his or her personally identifiable information, Zoombak LLC will delete that child’s information from its records at the request of the child’s parent or guardian.

Information Collected by Others.

This Privacy Policy addresses only the policy and procedures of Zoombak.  Zoombak is not responsible for the privacy policies of third parties, including but not limited to those whose web sites may be linked to the Zoombak Web site.

Enforcement.

If a Customer believes that his or her rights as described in this Privacy Policy have been violated by Zoombak Limited or Zoombak LLC, the Customer should email the Director of Customer Care at privacy@zoombak.com or send a letter to Zoombak Ltd., Gainsborough House, 59-60 Thames Street, Windsor SL4 1TX, United Kingdom. Zoombak Limited will attempt to resolve Customer complaints as quickly as possible.

Contact Us.

For more information about our Privacy Policy and practices, e-mail us at info@zoombak.com or call 0800 028 0101.By using the Services or the Web site, you acknowledge that you have read and consent to the processing of your Personal Information and Location Information in accordance with this Privacy Policy.  If you do not consent to the terms set out in this Privacy Policy, please do not use the Services or the Web site.

Last updated April 22, 2008