We at Zencity Technologies Ltd. and its affiliates (collectively, "Zencity", "us", "we", or "our") recognize and respect the importance of maintaining the privacy of our customers, including local government stakeholders and their authorized representatives ("Cities"). This Privacy Notice describes the types of information we collect from you when you access or use the Zencity Hall community platform ("Community Platform"), including the services thereon ("Services"), which is a feature of our civic engagement platform ("Platform"). This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at https://community.zencity.io/site/terms ("Terms"). "You" means any authorized representative of City using the Services.
If you are an individual located in the European Union ("EU Individual"), some additional terms and rights may apply to you, as detailed herein. Zencity is the data controller in respect of the processing activities outlined in this Privacy Notice. Our registered office is Carlibach 20, Tel Aviv, Israel and our registration number is 515264430.
Prighter Ltd. has been designated as Zencity's representative in the United Kingdom for data protection matters pursuant to the UK GDPR. Prighter Ltd. may be contacted on matters related to the processing of personal data of residents of the UK, at https://prighter.com/q/17328186 or at 20 Mortlake High Street, London, SW14 8JN, United Kingdom.
"Personal Data" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data is collected by us in connection with the provision of the Services.
Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section in order to find out more information about any topic. These key points do not substitute the full Privacy Notice.
1. Personal Data We Collect, Uses and Legal Basis.
Depending on your usage, we collect different types of data and we and any of our third-party subcontractors and service providers use the data we collect for different purposes, as specified below. You have no legal obligation to provide us with certain Personal Data, but if you refuse to provide such Personal Data we may not be able to register you to use the Services or part thereof.
1.1 Registration Data – In order to use our Services, you will need to have a registered account. You can register by logging in through your existing account on the Platform and authorizing us to register you using your Platform account.
How we use this data: (1) to provide you and the applicable City with the Services and to respond to your inquiries and requests and to contact and communicate with you; and (2) to prevent fraud, protect the security of and address any problems with the Community Platform.
Legal Basis: (1) We process this Personal Data for the purpose of providing the Services to you, which is considered the performance of a contract with you or the City, as applicable, including responding to your inquiries and requests and providing customer support. (2) When we process your Personal Data for the purposes of preventing fraud, protecting the security of and/or addressing problems with the Services, such processing is based on our legitimate interests.
1.2 Automatically Collected Data - When you visit the Community Platform, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system, and Personal Data such as your IP address, device ID, as well as your browsing and viewing history and any other information regarding your use of our Community Platform. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section "Cookies and Similar Technologies" below.
How we use this data: (1) to review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and Services; and (2) to prevent fraud, protect the security of the Community Platform and Services, and address any problems with the Community Platform and/or Services.
Legal Basis: We process this Personal Data for our legitimate interests to develop and improve our products and Services, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights.
1.3 Materials You Upload – Any materials, including posts, images, pictures, photos, and/or documents, you may upload to the Community Platform will be collected by us.
How we use this data: To provide you with the Services.
Legal Basis: We process this Personal Data for the purpose of performance of a contract with you or the City.
2. Additional Uses – Statistical Information and Analytics.
We and/or our service providers use analytics tools, to collect and analyze information about the use of the Community Platform and/or Services, such as how often users visit the Community Platform, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Community Platform. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Community and Services, understand trends and customer needs and consider new products and services, and tailor existing products and services to customer desires. The information we collect is anonymous and aggregated and we will not link it to any Personal Data. We may share such anonymous information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.
3. Sharing the Personal Data We Collect.
We share your information, including Personal Data, as follows:
3.1 Affiliates. We share information, including your Personal Data, with our affiliated companies, Zencity Technologies US Inc. and Zencity Technologies CA Ltd. where this is necessary to provide you with our products and Services, and for the purpose of management of our business.
3.2 Service Providers, and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Community Platform and/or Services and (2) aid in their understanding of how users are using our Community Platform and/or Services.
Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services and data analysis.
3.3 Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.
3.4 Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party's rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.
3.5 Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.
3.6 Other Uses or Transfer of Your Personal Data. If you use our Community Platform and/or Services with or through a third-party service, site and/or mobile application, we may receive information (including Personal Data) about you from those third parties. Please note that when you use third-parties outside of our Community Platform and/or Services, their own terms and privacy policies will govern your use of those services.
4. International Transfer.
4.1 We use subcontractors and service providers and have affiliates who are located in countries other than your own, such as Israel, the US, the UK, or the EU and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such third country.
4.2 Whenever we transfer your Personal Data to third parties based outside of the European Economic Area ("EEA") and when required under applicable law, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
4.2.1 We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
4.2.2 Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
4.3 Please contact us at firstname.lastname@example.org if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:
5.1 Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data.
5.2 Access Control – We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need to know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.
5.3 Internal Policies – We maintain and regularly review and update our privacy related and information security policies.
5.4 Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.
5.5 Encryption – We encrypt the data in transit using secure HTTPS and TLS protocols.
5.6 Database Backup – The hosting platform databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.
5.7 However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
5.8 As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
6. Your Rights - How to Access and Limit Our Use of Certain Personal Data.
Subject to applicable law and certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
6.1 Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.
6.2 Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.
6.3 Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.
6.4 Deletion of Personal Data ("Right to Be Forgotten"). If you are an EU Individual, you have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (v) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should terminate your account with us, and clear our cookies from any device where you have used our Community Platform. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.
6.5 Right to Restrict Processing. If you are an EU Individual, you can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.
6.6 Right to Object. If you are an EU Individual, you can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
6.7 Right to Lodge a Complaint with Your Local Supervisory Authority. If you are an EU Individual, you may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
7. Data Retention.
7.1 Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor's retention policy.
7.2 In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.
7.3 Please contact us at email@example.com if you would like details regarding the retention periods for different types of your Personal Data.
8. Cookies and Similar Technologies.
9. Third-Party Applications and Services.
All use of third-party applications or services, including participation in any events posted on the Community Platform, is at your own risk and subject to such third party's terms and privacy policies.
We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account.
We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has registered without parental permission, please advise us immediately.
12. Changes to the Privacy Notice.
We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site or via email.
13. Comments and Questions.
If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at firstname.lastname@example.org.
Last updated: April 2022