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Zoombak Privacy Policy

This Privacy Policy describes the privacy polices and practices of Zoombak, LLC (“Zoombak”) regarding the Zoombak.com Web site, http://www.zoombak.com// (the “Web site”), and regarding Zoombak’s location-based services (the “Services”), which are described in Zoombak’s Customer Agreement, which is available on the Web site.  
Information Zoombak 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 to activate the Services.  Customers must promptly notify Zoombak of any changes to such Personal Information.  Zoombak may also receive other information about a Customer, such as credit information, from other sources.  Zoombak will consider any such additional information about a Customer as Personal Information.  

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

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.  Location Information will be retained for each Customer for a period that Zoombak will decide in its sole discretion.

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

Zoombak 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.   


Information Zoombak Collects from the Web Site

When Customers and others visit the Web site, Zoombak 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 also collects information pertaining to the visitor’s operating system, browser version, referring site, and keywords used to locate the Web site.  


Zoombak, its contractors and other third parties that help Zoombak provide the Services or 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 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.  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 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 does not place Web beacons that link to Personal Information on other sites, nor does Zoombak permit third parties, other than those working on Zoombak’s behalf, to place them on Zoombak’s site.  Zoombak may use Web beacons on the Zoombak Web site and may link a particular beacon to Personal Information.


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


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 has regarding that Customer by emailing a request for a copy of that information to privacy@zoombak.com or by sending a letter to 1000 Chesterbrook Blvd., Berwyn, PA  19312 USA.  Zoombak will make a good faith effort to mail the information to the Customer at the address previously provided by the Customer if Zoombak 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 correct its records to privacy@zoombak.com.  Zoombak will make the correction if Zoombak is supplied with sufficient information to allow it to confirm the identity of the person making the request.

How Information Is Secured.

Zoombak 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 is encrypted; access to Personal Information is limited to Zoombak and contractor personnel who need the information to provide the Services; and Zoombak uses and requires its contractors to use technical measures to guard against unauthorized access to Personal and Location Information.   Zoombak also requires Customers to use user identification and passwords to access Personal and Location Information.  Similarly, when visitors to the Web site conduct payment card transactions with Zoombak, Zoombak 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 learns that a Customer’s Personal or Location Information has been disclosed to an unauthorized person, Zoombak will attempt to notify the Customer.


How Zoombak Uses Customers’ and Web site Visitors’ Information.

Zoombak uses each Customer’s Personal and Location Information to provide Services to that Customer.  Zoombak does not collect information of any kind other than to provide such Services.  Zoombak does not currently share, sell, or rent any Personal or Location Information or information collected from the Web site to any third parties, other than to Zoombak’s agents, and does not intend to do so in the future. 


    Right to opt-out:  Any Customer who does not want Zoombak to share, sell, or rent any Personal or Location Information or information collected from the Web site to any third parties, other than Zoombak’s agents has the right to opt-out of such potential information sharing.  To request that such information not be shared, a Customer should either send an email to privacy@zoombak.com or send a letter to Zoombak, Director of Customer Care 1000 Chesterbrook Blvd., Berwyn, PA  19312 USA.

Zoombak may share Personal Information, Location Information, and information collected from the Web site with Zoombak’s agents, corporate affiliates, or advisors who help Zoombak operate and improve its business.  Zoombak has entered into written agreements with its agents, corporate affiliates, and advisors to which it discloses Personal Information, Location Information, and information collected from the Web site that requires them to adhere to pertinent provisions of this Privacy Policy 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).  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.
Zoombak may use Aggregate Data to analyze how Customers use the Services to determine ways in which Zoombak can improve the Services and to consider offering new services to Customers.  Zoombak may also use information collected from the Web site to analyze traffic to the Web site to determine how to improve the site.  Zoombak may also use information from a Web beacon to ensure that a Customer can move between Zoombak’s technical assistance Web page, the Customer service page, and Zoombak’s online store and still be recognized as the same Customer.

Zoombak may use or disclose Personal and Location Information and information collected from the Web site:  to comply with applicable laws; to protect the rights and property of Zoombak or others; to protect a person’s safety; to prevent abuse; as evidence in legal proceedings; to cooperate with properly authorized law enforcement investigations; and in response to subpoenas from third parties.  Zoombak will use good faith efforts to promptly notify a Customer of any subpoena that seeks any of the Customer’s Personal or Location Information to enable the Customer to seek to quash the subpoena.  Finally, Zoombak may disclose or sell Personal Information and information collected from the Web site as an asset in conjunction with the sale of Zoombak to a third party or in conjunction with the sale of a portion of Zoombak’s assets.

Children’s Information

Zoombak recognizes the importance of protecting the privacy of children.  Zoombak will not knowingly collect any personally identifiable information from children.  Personal Information collected from a Customer must be information from an adult.
Consistent with the Children’s Online Privacy Protection Act, the Web site is not directed to children under the age of thirteen.  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 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.

Verification

Zoombak has self-assessed that its Privacy Policy conforms to EU Safe Harbor principles regarding personal information received from the EU.

Enforcement

If a Customer believes that his or her rights as described in this Privacy Policy have been violated by Zoombak, the Customer should email Director of Customer Care at privacy@zoombak.com or send a letter to Zoombak, Director of Customer Care at 1000 Chesterbrook Blvd., Berwyn, PA  19312 USA.  Zoombak will attempt to resolve Customer complaints as quickly as possible.
If Zoombak is unable to resolve a Customer’s complaint regarding an alleged violation of this Privacy Policy, the Customer may file a complaint with the Data Protection Authority for the country in which the customer lives. 

Amendments to this Privacy Policy

Zoombak reserves the right, at its sole discretion, to change, modify, add to, or remove any portion of this Privacy Policy, in whole or in part, at any time.  Zoombak will include such Amendments on the version of this Policy that is posted on Zoombak’s Web site (www.Zoombak.com) and will notify Customer by e-mail that the Policy has been amended.  Amendments to the Policy will take effect immediately upon being posted to the Web site.  Customer’s continued use of the Services after Zoombak posts an Amendment constitutes Customer’s acceptance of and consent to the Amendment.  If Customer does not accept such an Amendment, Customer must notify Zoombak within 30 days after Zoombak notifies Customer of the Amendment that Customer has elected to terminate the Services rather than accept the Amendment.  Zoombak will not charge Customer a termination fee if Customer terminates the Services as described in this paragraph.

Contact Us

For more information about our Privacy Policy and practices, e-mail us at privacy@Zoombak.com or call 1.610.680.1000.

By using the Services or the Web site, you acknowledge that you have read and accepted this Privacy Policy.  If you do not accept this Privacy Policy, please do not use the Services or the Web site.

Copyright © 2007, Zoombak, LLC.

Last revised December 11, 2007