Privacy Policy

Zoot Enterprises, Inc. (“Zoot Enterprises”, “we” or “us”) provides data processing and decisioning services to commercial customers in the financial and medical services sectors. The data we process includes personal information about consumers that is provided by our customers and their designated third party data providers. Zoot does not collect this data directly from consumers. However, Zoot does collect personal information about the visitors to our Web site (https//:www.zootsolutions.com, or any replacement site, the “Site”) in order to operate the site effectively, respond to your queries, and develop marketing leads. Our marketing team uses cookies and analytics to understand the activity on our Site, identify businesses that may be interested in Zoot’s services, and provide targeted advertising on partner sites. This notice (this “Privacy Policy”) describes the personal information we collect, how we collect it, and what choices you have regarding the information we collect from you, including with respect to opting out of advertising.

Personal Information We Collect

The data we collect depends the extent of your interactions with our Site and our customers, the choices you make (including your privacy settings), the features you use, and applicable law. The data we collect can include the following:

Individual Identifiers. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Credentials. Passwords, password hints, and similar security information used for authentication and account access.

Demographic Data. Information about your age, gender, country, and preferred language.

Business Affiliation. Data associating you with a company or business, such as a business name in your IP address.

Applicant Data. Data about applicants for employment, some of which is collected when you fill out an initial application through our Site. This can include data on your previous employers, past addresses, educational history, reference information, and credit and background check data.

Professional and Employment-Related Information. Data concerning your professional qualifications and licensure, certifications, employment and disciplinary history.

Education Information. Data concerning your educational history, such as your transcript, degrees, and professional certifications or licenses.

Benefits and Claims Data. Data about your health insurance provider, plan or account numbers, claims, and benefits.

Payment and Account History. Data to process payments, such as your credit card and authorization information, and information about the activities associated with your account.

Usage Data. Data generated by your activity on the Site. This can include data you provide in order to make use of the Site and its features (like search queries), as well as data we generate based on your activity on the Site (such as error reports).

• Interactions. Data about your interactions with the Site and its features, including the amount of time you spend on the Site, the webpages you visit, and search queries that you submit.
• Device and Configuration Data. Data about your device and your device configuration, such as the domain name of your Internet Service Provider, the Internet Protocol address assigned to the computer by which you are connected to the Internet, the name and version of your Web browser, and your computer’s operating system and platform.
• Error Reports and Performance Data. Data about the performance of the Site and any problems you experience, including error reports. Error reports can contain information about your activity on the Site, including files you may have downloaded from the Site and your use of the Site’s features.
• Communications, Preferences, and Requests. Data you submit using one of the Site’s contact forms, including the content of any communications you make using the form.
• Troubleshooting and Support Data. Data you provide when you contact us for help, such as the products you use, and other details that will help us diagnose the problem and provide you support.

Internet or Other Electronic Network Activity Information.

When you visit our Site or click on one of our ads, a cookie, tag, or similar technology is placed on your computer to provide us with information about your browsing history, search history, and interactions with our Site and advertisements. Our advertising service providers, including Microsoft, Google, LinkedIn, and Terminus, use this information to affiliate you with your business, assess your degree of interest in our products and services, and develop a customer profile of your business. Several of these cookies store a standard identifier on your computer, which can be used to track your behavior on the internet and serve you with targeted advertising for our goods and services. Although we do not receive personally identifying information from our advertising partners, they have access to this information through the cookie or tag that is installed when you visit our website. For more information about how your data is used for cross-contextual and interest-based advertising and how to opt-out, see the “Advertising” section of this policy.

Feedback Data. Information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write.

Visual Information. Visual images of personnel employed in, visiting, or transiting our facilities.

Biometric Information. Data concerning the physiological characteristics of company personnel to be used, singly or in combination with other identifying data, to establish individual identity.

Commercial Information. We may receive data concerning products or services you have purchased, obtained, or considered for processing on behalf of a financial institution, retail organization, or other customer. This information may reflect your purchasing or consuming histories or tendencies, including your credit history, and be processed for a variety of purposes, including credit decisioning, loan origination, fraud detection and prevention.

Health Information. We may receive your identifiable health information from one of our institutional or corporate customers for records management, data processing, software design, and/or application development. In some cases, we perform these services for a covered entity as a business associate subject to the Health Insurance Portability and Accountability Act (“HIPAA”). In other cases, however, our customers are businesses that provide health and wellness services that are not subject to HIPAA. The health information we process may include data concerning your physical characteristics, health indicators, level of fitness, as well as inferences drawn therefrom concerning your lifestyle, habits, and risk of injury or disease.

Medical Information. We may receive medical information, such as prescriptions, test results, pharmacy services, health insurance data, member or account numbers, and claims from one of our institutional or corporate customers for records management, data processing, software design, and/or application development. We perform these services for covered entities as a business associate subject to HIPAA.

Our Sources of Personal Information

Users. We collect the personal information you provide to us, either through a direct communication with our company or by interacting with our Site and advertisements. If you elect to submit an application for employment with our company, we will collect personal information to assess your suitability, educational background, and professional qualifications.

Visitors. We collect personal information from visitors to our facilities, including individual identifiers, visual information (photographs), and employment information.

Our Employees. We collect individual identifiers, biometric, and visual information to restrict access to our facilities and networks to authorized personnel, identify potential security risks, and maintain accountability of and communication with our personnel, in the event of an incident or emergency. We also collect professional and employment related information, including professional certifications and degrees, educational history, performance evaluations, and disciplinary records. We use personal information from our employees to administer payroll, track employee performance and training, and manage our employee benefits programs, to include our life and health insurance plans.

Our Customers. As part of our business, we process information about consumers that is provided to us through contractual relationships with our business partners and certain third-party data providers. This may include information such as names, addresses, other contact information, social security numbers, financial account numbers, consumer reports, health information, and medical information. We are subject to stringent contractual obligations regarding the use and safeguarding of such information, and we use industry standard precautions and data security measures to maintain the confidentiality, security, and integrity of such information while it is in our possession or control.

Data Providers. We obtain data from third parties at the direction of our customers, as necessary to deliver our products and services. Our data providers include consumer reporting agencies, financial institutions, healthcare organizations, health plans, educational institutions, credentialing bodies, and state and federal agencies. In some cases, the information we collect is publicly available, such as open public sector, academic, and commercial data sets. More often, we enter into agreements with the data provider on behalf or at the behest of a customer. Our use of the data is then subject to any additional restrictions imposed by the source.

How We Use Personal Information

To Provide Our Products and Services. We provide advanced origination, acquisition, and decision management solutions for some of the largest organizations in the United States. Our software is highly adaptable, customizable, and data-agnostic. Traditionally, our customers have come from the financial services sector and our core business involves the processing of consumer credit information for major banks and retailers. We receive consumer financial information, credit information, and personally identifiable information from our clients and their designated data providers for processing against a client’s specific criteria and logic. However, our decisioning software has applications across multiple sectors, including healthcare. For example, we offer a credentialing solution that collects and processes professional and employment information on behalf of clients in the healthcare sector, including hospitals and health insurers. The data we receive from our clients and their data providers is subject to contractual, legal, and regulatory safeguards. We do not share or sell this data, except as specifically directed by the customer or required by law.

New Product Development. We use data gathered through our advertising and marketing programs to build customer profiles of businesses that may be interested in our software. We use that information to refine our existing products and identify opportunities for new lines of business.

Customer Support. We use data to troubleshoot and diagnose product problems, restore service to customers, and provide customer support, including helping us to identify, investigate, and resolve potential security incidents. This may include the use of automated systems to detect security and safety issues.

Customize and Improve Our Site. We use data that we collect on or through the Site to analyze and improve the content, features, materials, and opportunities that we make available on the Site, evaluate your needs, and customize the Site content delivered to you according to those needs.

Promotional Communications. We use data we collect to deliver promotional communications. Visitors to our Site can provide their contact information and express a preference concerning the sales and promotional materials they would like to receive. You can sign up for email subscriptions, request a call from a Sales representative, and sign up for updates concerning the products or topics that interest you. For information about managing your contact data, email subscriptions, and promotional communications, see the “How to Opt-Out of Promotional Communications” section of this policy.

Advertising. We use data to identify the business affiliation of visitors to our Site and build customer profiles of their companies. Because our products and services are marketed to large corporate clients that require decisioning across a high volume of transactions, we neither request nor receive individually identifiable information from our service providers for advertising. Nonetheless, our advertising partners use cookies and tags installed on our Site to recognize and serve our visitors with advertising for our products and services. These tags, such as Microsoft’s Universal Event Tracker (UET), allow our advertising partners to identify you even after you have left our Site. Our partners may pair data about your activity on our site, or your interaction with our advertisements, with information they already have about you. We participate in Microsoft Advertising, Google Ads, LinkedIn Ads, and Terminus advertising. You can find more information about these programs and each advertiser’s use of your data by visiting their website and reviewing their privacy policy. If you wish to discontinue an advertiser’s use of your data entirely, you will need to take advantage of that company’s opt-out procedures, which you can find posted on their website or in the applicable privacy policy. Our opt-out mechanism, described in further detail below, extends only to the information that we collect.

Human Resources. We use data to perform human resources functions, from processing employment applications and onboarding employees to managing employee discipline and departures. We also use data that our employees provide to us to administer our employee benefits program, from various health and wellness initiatives to our insurance and retirement plans.

Security and Business Continuity. We use data to secure our networks and facilities, assess and respond to security incidents, and maintain critical functions after a disaster or emergency. We collect personal information from all visitors to our facilities as part of our access control and visitor management programs.

Payment Processing. We use payment data to complete and process transactions, as well as to detect and prevent fraud.

Legal and Contractual Compliance. We process data to comply with the law and the data processing agreements we have entered into with our customers. Many of our customers are financial institutions and other highly regulated entities. Individual consumers typically enjoy data protection and privacy rights with respect to the information they have provided to these institutions. As a service provider, we process data to help our customers comply with their legal and regulatory obligations to consumers.

Enforcement. We may disclose your personal information if we are legally required to do so. We may also use and disclose personal information to establish or exercise our legal rights as permitted by law, to enforce any applicable Terms of Use, to assert and defend against legal claims as permitted by law, or if we believe such disclosure is necessary and permitted to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

How We Protect Your Personal Information

We are committed to protecting the security of your personal data and utilize a variety of security technologies and procedures to help protect your data from unauthorized access, use, or disclosure. For example, we store your personal information on computer systems that have limited access and are in controlled facilities. However, we cannot and do not guarantee that our systems, or that any such transmissions or information, will be totally secure. Unencrypted Internet communications are not secure, and no security measures are impenetrable. Please notify us immediately of any breach of Site security, or of this Privacy Policy, of which you become aware.

Consistent with our contractual and legal obligations, we also use industry standard, commercially reasonable measures and technology to secure and protect the personal information that we obtain from our business partners and their third-party data providers. We have designed our information security program to maintain compliance with the Payment Card Industry Data Security Standard (“PCI DSS”) requirements for service providers and Gramm-Leach Bliley Act Safeguards Rule, as well as the Federal Trade Commission’s standards for safeguarding consumer information. We process medical and health information in an environment that is HIPAA compliant and certified by HITRUST. You can learn about HITRUST certification on their website, https://hitrustalliance.net.

We Use Cookies on Our Site

A cookie is a file that is stored on your computer when you visit a website, including our Site. Cookies contain information about you and the websites you visit. If the cookies are persistent, they will remain on your computer even after your browser is closed. Permanent cookies are stored on your computer for a specific period of time and activate each time you visit the website that created the cookie. Temporary “session” cookies let us know what you do on our Site, but are deleted when your browser is closed. Our Site uses both persistent and temporary cookies to provide us with information about you and your interactions with our Site. These cookies are issued as soon as you visit the Site, unless your browser settings are adjusted to prevent such an occurrence.

In addition to using our own cookies, we have allowed our advertising partners to place cookies on the Site to provide us with better insights into the use of our Site and to provide relevant advertising to you. These advertisers may collect information about your online activities over time and across different websites through the use of their cookies, tags, and similar technologies. Additional general information about cookies and how they work is available at www.allaboutcookies.org.

We Share Personal Information with Our Advertising Partners

Our Site uses cookies, tags, and similar technologies to share personal information about our visitors with our advertising partners for advertising and marketing purposes, including individual end user tracking and cross-context behavioral advertising. These services allow us to identify businesses that have visited our Site before and serve their representatives with ads for our products and services. By placing these cookies and tags on your device when you visit our Site, or click on one of our advertisements, we are able to collect personal information about your device, such as your IP address, operating system, and browser, as well as your internet activity, including what you do after you have visited our Site or interacted with one of our advertisements. This information is automatically shared with the advertiser responsible for the cookie or tag, who then uses that information to serve you with ads on our behalf. You may opt-out of our sharing of your personal information for advertising and marketing purposes by following the opt-out procedures described below, in the “How to Opt-Out of Our Sharing of Your Personal Information” section of this policy. If you wish to exercise your opt-out rights with respect to interest-based advertising in general, we have also included information on some of the industry-wide resources available to you.

Google Analytics

In addition to the service we receive from our other advertising partners, we use Google Analytics as part of our marketing analytics and advertising. Google Analytics collects first-party cookies, data related to the device/browser, IP address and on-site/app activities to measure and report statistics about user interactions on the websites and/or apps that use Google Analytics. Google uses Google Analytics data to provide the Google Analytics measurement service to us and their other customers. Identifiers such as cookies and app instance IDs are used to measure user interactions with our Site, while IP addresses are used to provide and protect the security of the service, and to give us a sense of where in the world our users come from. The features we may use on the Site include Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform Integrations, and Google Analytics Demographics and Interest Reporting. We may also use other services provided by Google Analytics from time to time.

At present, Google provides users an opportunity to opt-out of the Google Analytics features through Google’s Ads Settings and their Opt-Out Browser Ad-on, available here: https://tools.google.com/dlpage/gaoptout/. We do not control these opt outs, which may be updated or removed in accordance with its own policies. For more information on how Google uses data from sites that share information with Google, see https://www.google.com/policies/privacy/partner-sites (or other relevant URL that Google may provide from time to time).

How to Opt-Out of Our Sharing of Your Personal Information

If you wish to opt out of our sharing of your personal information with our advertising partners, you can do so by clicking here: Do Not Share My Personal Information. Clicking on the “Do Not Share My Personal Information” link will immediately effectuate your right to opt-out of our sharing of your personal information for advertising and marketing

How to Opt-Out of Interest-Based Advertising

Several of our advertising partners use online interest-based advertising to identify potential customers and show them advertisements that may be of interest. They do this by pairing information about your activity on our Site, which they collect using cookies and tags from our Site, with information they have about you from other sources. Our advertising partners use a variety of digital marketing networks and ad exchanges, as well as a variety of advertising technologies, like web beacons, pixels, ad tags, cookies, and mobile identifiers. When you see one of our ads, that ad may be have been selected based on data processed by our advertiser, such as your interests and favorites, your location, your transactions, how you use their products, your search queries, or the content you view. The ads you see may also be based on other information the advertiser has learned about you over time, using demographic data, location data, search queries, interest and favorites, usage data from their products and sites, and the information they have collected about you from the sites and apps of their advertisers and partners, of which we are one. Our advertising partners – Microsoft, Google, LinkedIn, and Terminus – all offer interest-based advertising.

To learn more about interest-based ads or to opt-out of receiving third-party interest based ads, please visit one of the industry’s self-regulatory programs, such as the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAI). Both programs offer opt-out resources to consumers, which you can access at https://optout.networkadvertising.org/ or https://youradchoices.com/control. Please note that if you opt of interest-based advertising, you will still see advertisements – they will just not be tailored to your interests. Also note that the opt-out preference is stored in a cookie, so if you delete your browser cookies, you may need to opt-out again in the future.

How to Opt-Out of Promotional Communications

You may request a call from our Sales team by providing your name, company, and contact information through our Site. If you elect us to provide us this information, it will be used for advertising and marketing purposes, including promotional communications and targeted advertising. If you would like us to stop using your contact information, you may send a request to sales@zootweb.com. You can also limit the types of communications you receive by submitting your communication preferences at https://go.zootsolutions.com/user-preferences/.

Browser-Based Controls

When you use a browser, you may be able to control your personal data using certain features. For example:

• Cookie Controls. You can control the data stored by cookies and withdraw consent to cookies by using your browser-based cookie controls. Should you choose to decline or block cookies by adjusting your browser settings, you may disrupt the operation of cookies that are essential to our Site. As a result, some or all of our Site may be functional or accessible to you.
• Tracking Protections. You can control the data third-party sites can collect about you using Tracking Protection in Internet Explorer (versions 9 and up) and Microsoft Edge. This feature will block third-party content, including cookies, from any site that is listed in a Tracking Protection List you add. This feature is not available on all browsers, and is often confused with a “Do Not Track” request.
• Browser Controls for “Do Not Track.” Some browsers have incorporated “Do Not Track” features that can send a signal to websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the “Do Not Track” signal, not all services respond to this browser signal. Until the industry reaches a common understanding of how to treat these signals, you should use the “Do Not Track” feature in conjunction with another form of opt-out. Many websites still collect and use your browsing data to improve security, provide content, services, ads and recommendations on their websites, and generate reporting statistics.

If we receive or detect an opt-out preference signal from your browser or device, we shall treat the preference signal as a valid request to opt-out of our sharing of your personal information. If the opt-out signal conflicts with your prior consent for such sharing, we may notify you of the conflict and provide you with an opportunity to consent to the sharing of your personal information.

Sensitive Personal Information

“Sensitive personal information” means personal information that reveals: (1) your social security, driver’s license, state identification card, or passport number; (2) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (3) your precise geolocation; (4) your racial or ethnic origin, religious or philosophical beliefs, union membership, or information specifying your sex life; (5) the contents of your mail, email, and text messages (unless we are the intended recipient); (6) your genetic data; and (7) specific medical or health conditions. Sensitive personal information does not include data that you have manifestly made public. We only use or disclose sensitive personal information for the following purposes:

• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information;
• To resist malicious, deceptive, fraudulent, or illegal actions directed at our business and to prosecute those responsible for those actions;
• To ensure the physical safety of natural persons;
• For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your interaction with our Site;
• To provide services to you, consistent with the purposes of the original collection;
• To perform services on behalf of our business, such as maintaining and servicing accounts, providing customer service, verifying customer information, providing analytic services, and processing payments.
• To carry out our obligations in the field of employment law;
• To verify or maintain the quality or safety of a product or a service that we provide or control; and
• For collection or processing that is not for the purpose of inferring characteristics about you.

Should we seek to use or disclose your sensitive personal information for a purpose that has not been listed, we will request your affirmative express consent (opt-in) and provide you with a Notice of Right to Limit the Use of Your Sensitive Information. The Notice will include a description of your right to limit our use of such information and instructions on how you can submit a request to limit.

Collection of Data from Children

We have no actual knowledge that we have sold or shared the personal information of consumers under 16 years of age. Our products and services cannot be used by minors and we do not knowingly collect information about or target advertising to anyone under the age of 16.

We Have Not Disclosed Personal Information to a Third Party in the Past 12 Months

We consider a “third party” to mean anyone other than: (1) the business who provided the personal information to us for processing, pursuant to a written agreement; (2) a consumer reporting agency, to the extent the personal information constitutes a consumer report under the Fair Credit Reporting Act; (3) a service provider; or (4) a contractor. We do not disclose personal information to third parties unless required to do so to comply with federal, state, or local law; comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; cooperate with law enforcement agencies; or exercise or defend a legal claim.

Consumer Rights – California, Virginia, Connecticut and Colorado

Certain states have enacted consumer data privacy laws affording the residents of their states specific rights with respect to the collection, use, and handling of their personal information. Because we are a service provider with respect to most of the personal information we process, we may not be authorized to act on behalf of a customer in resolving your request. If we have been so authorized, we will respond to you in accordance with our customer’s instructions. In all other cases, we will inform you that your request has been sent to a service provider and cannot be acted upon by us.

Rights of California Residents

• The California Consumer Privacy Act (“CCPA”) confers certain rights on California residents with respect to the processing of their personal information. These rights include:
• The right to know what personal information we have collected about you;
• The right to delete personal information that we have collected about you, subject to certain exceptions;
• The right to correct inaccurate personal information that we maintain about you;
• The right to opt-out of our sharing of your personal information, which you may exercise here: Do Not Share My Personal Information; and
• The right not to receive discriminatory treatment for the exercise of these rights, including an employee or applicant’s right not to be retaliated against. We will not discriminate against you because you exercised your rights under the CCPA. Examples of retaliation include denying you goods or services, charging different prices or rates for goods or services, or suggesting that you will receive a different price or level of service based on your exercise of rights.

You may exercise your rights yourself or through an authorized agent, using the procedures outlined below. No later than ten (10) business days upon receiving a request to delete, request to correct, or request to know, we will confirm receipt of your request and provide information about how we will process it. If we have conducted business in California such that the CCPA applies to us, we will respond to you with a decision in 45 days, or, in unusual cases, an explanation of the need for an additional 45 days. If we deny your request in whole or in part, we will explain the basis of the denial to you, unless prohibited from doing so by law.

Rights of Virginia Residents

The Virginia Consumer Data Protection Act (“VCDPA”) authorizes certain consumer rights for residents of the Commonwealth of Virginia with respect to the processing of their personal data. We will comply with a consumer request to exercise any of the following rights:

• To confirm whether or not we are processing your personal data and to access such personal data;
• To correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing;
• To delete the personal data provided by or obtained about you;
• To obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrances, where the processing is carried out by automated means; and
• To opt-out of the processing of personal data for the purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. You may exercise your opt-out here: Do Not Share My Personal Information.

We will respond to you without undue delay, but in all cases within 45 days of receipt of a request submitted pursuant to this policy. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of your requests. In that event, we will inform you of the extension, together with the reason for it.

If we decline to take action regarding your request, we will inform you without undue delay, but in all cases and at the latest within 45 days of receipt of the request, of the justification for declining to take action and instructions for how to appeal the decision. We may be precluded from acting on your request because we are acting as a service provider with respect to the processing of your personal information.

You may address appeals to our Legal Department at legal@zootweb.com. A member of our legal team will review the action taken on your request, any matters you may wish to submit, and make a recommendation to our Chief Compliance Officer regarding the appropriate resolution of your appeal. The Chief Compliance Officer will make the final decision on your appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with an online mechanism, if available, or other method through which you may contact the Attorney General to submit a complaint.

Rights of Connecticut Residents

The Connecticut Data Privacy Act provides consumers the right to:

• Confirm whether or not we are processing your data and access such data, unless such confirmation or access would require us to reveal a trade secret;
• Correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of our processing;
• Delete personal data provided by, or obtained about, you;
• Obtain a copy of your personal data if processed by us (or a service provider), in a portable and, to the extent technically feasible, readily usable format suitable for transmission to another company; and
• Opt-out of the processing of personal data for the purposes of (i) targeted advertising, (ii) the sale of personal data, except as authorized under the Act, or (iii) profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer.

We will respond to you without undue delay, but not later than 45 days after receipt of the request. We may extend the response period by 45 additional days when reasonably necessary, considering the complexity and number of your requests, provided we inform you of any such extension within the initial 45 day response period.

If we decline to take action regarding your request, we will inform you without undue delay, but not later than 45 days after receipt of the request, of the justification for declining to take action and instructions for how to appeal the decision. We may be precluded from acting on your request because we are acting as a service provider with respect to the processing of your personal information.

You may address appeals to our Legal Department at legal@zootweb.com. A member of our legal team will review the action taken on your request, any matters you may wish to submit, and make a recommendation to our Chief Compliance Officer regarding the appropriate resolution of your appeal. The Chief Compliance Officer will make the final decision on your appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with an online mechanism, if available, or other method through which you may contact the Attorney General to submit a complaint.

Rights of Colorado Residents

The Colorado Privacy Act provides consumers the right to:

• Opt-out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer;
• Confirm whether we are processing your personal data and access such personal data;
• Delete personal data concerning you;
• Obtain your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

We will inform you of any action taken on your request without undue delay and, in any event, within 45 days after receipt of the request. We may extend the 45 day period by 45 additional days where reasonably necessary, taking into account the complexity and number of requests. We will inform you of an extension within 45 days after receipt of the request, together with the reasons for the delay.

If we do not take action on your request, we will inform you, without undue delay and within 45 days after receipt of your request, of the reasons for not taking action and instructions for how to appeal the decision. We may be precluded from acting on your request because we are acting as a service provider with respect to the processing of your personal information.

You may address appeals to our Legal Department at legal@zootweb.com. A member of our legal team will review the action taken on your request, any matters you may wish to submit, and make a recommendation to our Chief Compliance Officer regarding the appropriate resolution of your appeal. The Chief Compliance Officer will make the final decision on your appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with an online mechanism, if available, or other method through which you may contact the Attorney General to submit a complaint.

How to Exercise Your Rights under State Law

You can submit a request to exercise your rights to us via email at the following address: compliance@zootweb.com. Please contact us at (406) 586-5050 before sending us supporting documentation containing sensitive personal information. If you have requests a copy of your personal data, we may contact you to determine a technically feasible and secure means of providing you with a copy, in light of the sensitivity of the data and the technology available to you.

Identity Verification and Authentication

Upon receipt of a request to exercise your rights with respect to your personal data or information, we will determine if we have collected your personal information. If we have collected your personal information, we will confirm receipt of your request and contact you to verify your identity and state of residence. The method by which we will verify your identity may vary, depending on the type and sensitivity of your personal information, the risk of harm to you, and the technology available to you. If we cannot verify your identity with reasonable certainty, we will deny your request and inform you that your identity cannot be verified. Although you have no obligation to cooperate with our efforts to verify your identity, we cannot act on your request until you have done so.

You will not be required to verify your identity to opt-out of our sharing of your personal information, which you can do here at any time: Do Not Share My Personal Information.

Using an Authorized Agent

You may authorize an agent to submit a request on your behalf. If you do so, we will require you to: (1) verify your identity directly with us, and (2) directly confirm that you provided your agent with permission to submit the request.

U.S.-E.U. Data Transfers

We process data for U.S. companies operating around the world, including those with operations in the European Union. To comply with the General Data Protection Regulation’s (“GDPR”) requirements for data controllers, our customers impose data protection safeguards through the use of Standard Contractual Clauses (“SCCs”) that have been pre-approved by the European Commission. When data is transferred to us from companies within the E.U., we are subject to the GDPR as a data processor only. We do not process data originating in the E.U. without a written agreement in place with the data controller.

Taking into account the nature of the processing, we assist our data controllers in fulfilling their obligation to respond to requests for exercising a data subject’s rights under the GDPR. We process such data only on the instructions of a data controller and only for the purposes outlined in this privacy policy. Requests to exercise a data subject’s right of access or choice will either be referred to the E.U. controller directly or resolved in accordance with the controller’s instructions.

Linked Sites

For your convenience, some hyperlinks may be posted on our Site that link to external Web sites which we do not control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of other companies. You should not assume that our Privacy Policy applies to any external sites, or that the policies applicable to those sites are similar to ours. You will need to review each site’s privacy policy to understand how your personal information will be collected and used by the owner of the site.

Changes to this Privacy Policy

We update this policy when necessary to provide greater transparency or in response to feedback from our customers or regulators; changes in industry standards or frameworks; changes in the capabilities or functionality of our products and services; or changes in the scope of our data processing activities. When we post changes to this policy, we will revise the “Last Updated” data at the top of the policy. If there are material changes to the policy, such as a change to the processing of your personal data that is not consistent with the purpose for which it was originally collected, we will notify you by either (1) prominently posting a notice of such changes before they take effect; or (2) by directly sending you a notification. We encourage you to periodically review this policy for updates.

How to Contact Us

If you have any questions or comments concerning this Privacy Policy, our privacy practices, or any other questions about Zoot Enterprises, the Site, or our products and services, please contact us at the numbers or addresses given below. Zoot Enterprises, Inc.
Attn: Zoot Enterprises Legal Department
555 Zoot Enterprises Lane
Bozeman, MT 59718
Phone: 406-586-5050
Fax: 406-587-8414
Email: compliance@zootweb.com

If you correspond with the Company through the System or via email, we will collect and retain the content of, and metadata regarding, any correspondence you may have with us. We may share your messages with those within our organization who are most capable of addressing the issues contained in your message. We will keep a copy of your message until we have had an opportunity to address your concerns.

Notice of Collection (Cookies, Tags, and Similar Technologies)

The purpose of this Notice of Collection is to provide you with timely notice, at or before the point of collection, about the categories of personal information to be collected, the purposes for which the personal information is collected or used, and whether that information is sole or shared, so that you have a means of exercising meaningful control over our use of your personal information. For example, you use the information in this notice as a tool to choose whether or not to interact with us, or to direct us not to share your personal information.

What Personal Information Do We Collect?

We use cookies, tags, and similar technologies on our website to collect personal information from you. The personal information we collect includes individual identifiers, such as your Internet Protocol (“IP”) address, and internet or other electronic network activity information, such as your interactions with our website and advertisements, browsing history and search history. For example, cookies on the Site may track “macro” information, such as the number of independent visits made to the Site each day, or “micro” information about you and your device, such as the type of browser and Internet-connected device being used to access the Site, your home domain or Internet service provider, your referrer URL (the URL for the website you were viewing prior to visiting our Site), how you were directed to the Site, which specific pages you access on the Site, how long you viewed each page, the time and date you access our Site and the total number of visitors to the Site and its associated webpages.

What is a Cookie?

A cookie is a file that is stored on your computer when you visit our Site. Cookies contain information about you and the websites you visit. If the cookies are persistent, they will remain on your computer even after your browser is closed. Permanent cookies are stored on your computer for a specific period of time and activate each time you visit the website that created the cookie. Temporary “session” cookies let us know what you do on our Site, but are deleted when your browser is closed. Our Site uses both persistent and temporary cookies to provide us with information about you and your interactions with our Site. These cookies are issued as soon as you visit the Site, unless your browser settings are adjusted to prevent such an occurrence.

In addition to using our own cookies, we have allowed our advertising partners to place cookies on the Site to provide us with better insights into the use of our Site and to provide relevant advertising to you. These advertisers may collect information about your online activities over time and across different websites through the use of their cookies, tags, and similar technologies. Additional general information about cookies and how they work is available at www.allaboutcookies.org.

How We May Use Your Personal Information

We use data that we collect on or through the Site to analyze and improve the content, features, materials, and opportunities that we make available on the Site, evaluate your needs, and customize the Site content delivered to you according to those needs.

We also use data to identify the business affiliation of visitors to our Site and build customer profiles of their companies. Because our products and services are marketed to large corporate clients that require decisioning across a high volume of transactions, we neither request nor receive individually identifiable information from our service providers for advertising. Nonetheless, our advertising partners use cookies and tags installed on our Site to recognize and serve our visitors with advertising for our products and services. These tags, such as Microsoft’s Universal Event Tracker (UET), allow our advertising partners to identify you even after you have left our Site. Our partners may pair data about your activity on our site, or your interaction with our advertisements, with information they already have about you. We participate in Microsoft Advertising, Google Ads, LinkedIn Ads, and Terminus advertising. You can find more information about these programs and each advertiser’s use of your data by visiting their website and reviewing their privacy policy. If you wish to discontinue an advertiser’s use of your data entirely, you will need to take advantage of that company’s opt-out procedures, which you can find posted on their website or in the applicable privacy policy. Our opt-out mechanism, described in further detail below, extends only to the information that we collect.

We Share Personal Information with Our Advertising Partners

Our Site uses cookies, tags, and similar technologies to share personal information about our visitors with our advertising partners for advertising and marketing purposes, including individual end user tracking and cross-context behavioral advertising. These services allow us to identify businesses that have visited our Site before and serve their representatives with ads for our products and services. By placing these cookies and tags on your device when you visit our Site, or click on one of our advertisements, we are able to collect personal information about your device, such as your IP address, operating system, and browser, as well as your internet activity, including what you do after you have visited our Site or interacted with one of our advertisements. This information is automatically shared with the advertiser responsible for the cookie or tag, who then uses that information to serve you with ads on our behalf. You may opt-out of our sharing of your personal information for advertising and marketing purposes by following the opt-out procedures described below, in the “How to Opt-Out of Our Sharing of Your Personal Information” section of this policy.

Google Analytics

In addition to the service we receive from our other advertising partners, we use Google Analytics as part of our marketing analytics and advertising. Google Analytics collects first-party cookies, data related to the device/browser, IP address and on-site/app activities to measure and report statistics about user interactions on the websites and/or apps that use Google Analytics. Google uses Google Analytics data to provide the Google Analytics measurement service to us and their other customers. Identifiers such as cookies and app instance IDs are used to measure user interactions with our Site, while IP addresses are used to provide and protect the security of the service, and to give us a sense of where in the world our users come from. The features we may use on the Site include Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform Integrations, and Google Analytics Demographics and Interest Reporting. We may also use other services provided by Google Analytics from time to time.

At present, Google provides users an opportunity to opt-out of the Google Analytics features through Google’s Ads Settings and their Opt-Out Browser Ad-on, available here: https://tools.google.com/dlpage/gaoptout/. We do not control these opt outs, which may be updated or removed in accordance with its own policies. For more information on how Google uses data from sites that share information with Google, see https://www.google.com/policies/privacy/partner-sites (or other relevant URL that Google may provide from time to time).

We Do Not Sell Your Personal Information

Because we do not sell your personal information, we have not offered you a right to opt-out.

The Length of Time We Intend to Retain Your Personal Information

The length of time we will retain your personal information will be primarily determined by the context of your interactions with our company, your use of our Site and its features, and the preferences you have expressed. If you consent to all cookies, we will use your personal information to contact you, serve you with targeted ads on sites affiliated with our advertising partners, and improve the functionality and features of our Site. If you respond with interest, we will retain your personal information as long as necessary to respond to you and provide you with information regarding our products and services. If you do not respond, or if your interactions with our site are minimal or otherwise indicate a lack of interest or suitability for our services, we will use a shortened retention period.

We do not control the retention of your personal information by our advertising partners. We neither request nor receive all of the personal information that may be collected through the use of third-party cookies and tags, including those belonging to Microsoft, Google, and LinkedIn. You can find more information about each advertiser’s retention of your data by visiting their website and reviewing their privacy policy. If you wish to discontinue an advertiser’s use of your data entirely, you will need to take advantage of that company’s opt-out procedures, which you can find posted on their website or in the applicable privacy policy.

How to Opt-Out of Our Sharing of Your Personal Information for Advertising

If you wish to opt out of our sharing of your personal information with our advertising partners, you can do so by clicking here: Do Not Share My Personal Information. Clicking on the “Do Not Share My Personal Information” link will immediately effectuate your right to opt-out of our sharing of your personal information for advertising and marketing

How to Review Our Privacy Policy in Full

You are encouraged to read our privacy policy in full for further information regarding our use and collection of your personal information. To do so, please scroll to the top of this page.

Notice of Collection (Contact Forms)

The purpose of this Notice of Collection is to provide you with timely notice, at or before the point of collection, about the categories of personal information to be collected, the purposes for which the personal information is collected or used, and whether that information is sole or shared, so that you have a means of exercising meaningful control over our use of your personal information. For example, you use the information in this notice as a tool to choose whether or not to interact with us, or to direct us not to share your personal information.

What Personal Information Do We Collect?

This contact form is used to collect individual identifiers about you, such as your real name, email address, phone number, and employer. If you include personal information in a query or comment to us, we will collect that information as well. This form is not intended, and should not be used, to communicate sensitive personal information to us, such as account, credit, or health information.

How We May Use Your Personal Information

We use data we collect to deliver promotional communications, respond to feedback, and make improvements to our Site. Visitors to our Site can provide their contact information and express a preference concerning the sales and promotional materials they would like to receive. You can sign up for email subscriptions, request a call from a Sales representative, and sign up for updates concerning the products or topics that interest you. If you provide us feedback data, we will use that information to analyze and improve the content available through the Site, evaluate your needs, and customize the functionality and features we offer.

We Do Not Sell or Share Your Contact Information

Because we do not sell or share your contact information or the content of your communications with us, we have not offered you a right to opt-out.

The Length of Time We Intend to Retain Your Personal Information

The length of time we will retain your personal information will be primarily determined by the context of your interactions with our company, your use of our Site and its features, and the preferences you have expressed. If you request to be contacted, we will retain your personal information as long as necessary to respond to you and provide you with the relevant information regarding our products and services. Should you become one of our customers, we will retain your personal information for as long as necessary to provide our products and services to you. If you do not respond, or if your interactions with our site are minimal or otherwise indicate a lack of interest or suitability for our services, we will use a shortened retention period.

How to Review Our Privacy Policy in Full

You are encouraged to read our privacy policy in full for further information regarding our use and collection of your personal information. To do so, please scroll to the top of this page.

Notice of Collection (Employment Applications)

The purpose of this Notice of Collection is to provide you with timely notice, at or before the point of collection, about the categories of personal information to be collected, the purposes for which the personal information is collected or used, and whether that information is sole or shared, so that you have a means of exercising meaningful control over our use of your personal information. For example, you use the information in this notice as a tool to choose whether or not to interact with us, or to direct us not to share your personal information.

What Personal Information Do We Collect?

If you proceed to our applicant page, you will be invited to fill out a web-based application for employment hosted by our service provider, Paycor. Paycor will collect personal information about you and submit it to us as part of the application process. This personal information will include individual identifiers about you, such as your real name, email address, phone number, home address, as well as professional and employment related information concerning your previous employers, job titles, salary, and dates of employment. We will also collect education information, such as your transcript, degrees, and professional certifications or licenses. Based on the information you provide, we may collect personal data about you from third parties, such as recruiting agencies, job platforms like LinkedIn, referrals, your references, and employment background check providers, to the extent permitted by applicable law.

As part of our application, you will be asked to provide use with information about your race, gender, veteran status, and if you have, or have had, a disability. This information concerns protected classifications under state and federal law. If you elect to provide us with this information, we will use it to providing equal employment opportunities to all qualified employees and applicants. It will be kept confidential and only used in accordance with applicable law, including those that require the information to be summarized and reported to the federal government for civil rights enforcement.

How We May Use Your Personal Information

We will use your personal information for legitimate human resources and business management purposes including:

• Identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
• Contacting references;
• Recordkeeping in relation to recruiting and hiring;
• Contacting new hires prior to their start date;
• Ensuring compliance with legal requirements, including for diversity, inclusion, and equal opportunity;
• Conducting criminal history and credit checks as permitted by applicable law; or
• Protecting our legal rights to the extent authorized or permitted by applicable law, including monitoring the use of our website and information systems.

We may analyze your personal data or aggregate data to improve our recruiting and hiring process and improve our ability to attract successful candidates.

We Do Not Sell or Share Personal Information for Advertising

Because we do not sell or share your personal information for advertising and marketing purposes, we have not offered you a right to opt-out.

The Length of Time We Intend to Retain Your Personal Information

The length of time we will retain your personal information will be primarily determined by our legal and compliance obligations with respect to applicants for employment, your employment status with our company, and the preferences you express to us. For example, unless you tell us otherwise, we may retain the information from your application so that we may consider you for future employment opportunities with our company.

How to Review Our Privacy Policy in Full

You are encouraged to read our privacy policy in full for further information regarding our use and collection of your personal information. To do so, please scroll to the top of this page.