Privacy Policy

Last modified: September 20, 2022

Introduction

Zebit, Inc. (“Company” “we” “our” or “us”) provides credit services that allow our users to make purchases of consumer goods in the form of retail installment transactions. We have prepared this Privacy Policy to explain how we collect, use, and disclose your personal information when you visit our website and/or apply for an account with Zebit by accessing www.zebit.com (our “Website”) and when you utilize our services to make credit purchases (“Services”). This Privacy Policy applies to all users of the Website and Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website and our Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Website and/or Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy policy periodically for updates.

Children

Our Website and Services are not intended for individuals under 18 years of age. If you believe we might have any information from or about a child, please contact us at privacy@zebit.com.

Personal Information We Collect About You and How We Collect It

We collect several types of personal information from and about users of our Website and Services, including:

Account Information including name, email address, social security number, address, phone number, employment status, bank account information, and other similar information (“personal information“). The aforementioned list is non-exhaustive, and we may require additional information from you before granting you an account;
Services Information such as your shopping history and search history, which may or may not be used to identify you; and
Automatically Collected Information including your internet connection, the equipment you use to access our Website, and usage details.

We collect personal information:

From you when you or others provide it to us.
Automatically as you navigate through the Website and Services. Personal information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, as described below.

Personal Information You Provide to Us

The personal information we collect on or through our Website and Services may include:

Personal information that you provide by filling in forms on our Website and/or Services. This includes personal information provided at the time of registering for the Services and any personal information you provide while utilizing the Services. We may also collect personal information related to purchases and/or activity related to your account.
Records and copies of your correspondence (including email address and other contact information).
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions through our Website and Services including the fulfillment of your orders. You may be required to provide additional personal information before placing an order through our Website and Services.
Your search queries and activity on the Website and Services.

You also may provide personal information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website and/or Services or other third parties (collectively, “User Contributions“). Your User Contributions are posted publicly and transmitted to others at your own risk. We cannot control the actions of others so please exercise care.

Personal Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website and utilize the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically helps us to improve our Website and to deliver a better and more personalized Services, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website and/or Services according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website and/or Services.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Google Analytics. We use Google Analytics and other third party analytics providers on our Website and Services to collect usage data and to analyze how users are using the Website and Services. For more information about how to opt-out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

We may combine personal information about you that we collect from other sources such as Internet service providers, operating systems and platforms, data brokers, credit reporting agencies, government entities, advertising networks and data analytics providers.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Our Website may use social media plug-ins (e.g., Facebook, Instagram, LinkedIn, Twitter and YouTube) to enable you to easily share information with others. When you visit our Website, the operator of the social plug-in can place a cookie on your computer or other electronic device that enables that operator to recognize individuals who have previously visited our Website or other sites or services and to receive information that you have visited our Website. The social media plug-in also allows the social media site to share information about your activities on our website with other users of their social media site. These sharing settings are managed by the social media site and governed by its privacy policy.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website, Services and its contents to you.
To provide you with information, products, or Services that you request from us.
To fulfill any other purpose for which you provide it, including processing your application for credit.
To provide you with notices and other information about your account.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes and other information about our Website or any products or Services we offer or provide though it.
To allow you to participate in features on our Website and Services.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

To our subsidiaries and affiliates.
To contractors and service providers we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To third parties such as Internet service providers, operating systems and platforms, advertising networks, credit reporting agencies, data brokers and analytics providers.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website and Services users is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent and other lawful purposes.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use, Account Holder Agreement, Purchase Agreements, including for billing and collection purposes, and any other agreements between you and Company.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, you and/or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website and/or Services may then be inaccessible or not function properly. We do not control the collection or use of your information by advertising networks or partners to serve interest-based advertising. However, based on your location, you may also opt out through one of the advertising industry solutions as follows:
United States. In the United States, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page, at http://www.aboutads.info/choices/, as well as the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page at http://www.networkadvertising.org/choices/, for information about opting out of interest-based advertising.
Canada. In Canada, you may go to the Digital Advertising Alliance of Canada (“DAAC”) Opt-Out Tool at http://youradchoices.ca/choices/ for more information and to opt out of interest based advertising by certain ad networks.
European Union. In the European Union, you may go the European Interactive Digital Advertising Alliance (“EDAA”) Your Online Choices website at http://www.youronlinechoices.com/ and select your country to learn more about interest-based advertising and how to exercise choice.

Opting out of one or more of ad networks only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Website or other sites. For example, you may continue to receive advertisements based on the particular site or page that you are viewing (also known as contextual advertising). If your browser is configured to reject cookies when you visit the opt-out page or you subsequently erase your cookies or change browsers, you may need to update your choices.

Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties’ products or services, you can opt-out by clicking un-subscribe at the bottom of any promotional email you’ve received from us or at any other time by sending us an email stating your request to privacy@zebit.com. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights below for more information.

Accessing and Correcting Your Information

You can change or update some of your personal information by logging into your account, contacting our Customer Service Department at help@zebit.com

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see below.

Data Security

We maintain physical, electronic, and procedural safeguards designed to safeguard your personal information. You are responsible for keeping your password confidential, and we ask you not to share it with anyone. Unfortunately, the transmission of information via the Internet and mobile platform is not completely secure, and we cannot guarantee the security of your personal information, other information we collect, or automatically collected information. Any transmission of information is at your own risk, and we are not responsible for circumvention of any privacy of security measures we provide.

Data Transfers

We may transfer the personal information we collect to the United States and other countries, which may have different data protection laws than your country. If we do so, we will transfer the personal information only for the purposes described in this Privacy Policy. When we transfer your personal information to recipients in other countries, we will take appropriate measures to protect that information to the extent required by applicable law.

Retention of Personal Information

To the extent permitted by applicable law, we retain personal information we obtain about you for as long as it is needed for the purposes for which it was collected as described in this Privacy Policy and to comply with applicable laws, resolve disputes, enforce our agreements, and to fulfill regulatory obligations.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Website and Services and update the notice’s effective date.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

privacy@zebit.com

Zebit, Inc.
Attn: Legal Department
9920 Pacific Heights Blvd, Suite 150
San Diego, CA 92121

Privacy Notice for California Residents

Last Updated: September 21, 2022

This Privacy Notice for California Residents supplements the information contained in Zebit’s Website Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA. Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.	Yes
B. Customer Records.	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older) or veteran or military status	Yes
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics.	No
F. Usage Data.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Location based on IP address and/or ISP.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information such as, thermal screenings and CCTV footage, photographs and images and call recordings (e.g., of customer support calls).	Yes
I. Professional or employment-related information.	Current or past job history.	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act.	Education records directly related to a student maintained by an educational institution or party acting on its behalf.	No
K. Inferences.	Profile reflecting a person’s preferences, characteristics, predispositions, behavior, and attitudes.	Yes.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you.
From third-party data providers.
From advertising and social networks, internet service providers, and operating systems and platforms.
From data analytics providers.
Indirectly from you.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
To service any and all finance transactions you enter into with us.
To provide, support, personalize, and develop our Website, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud, identity theft, and illegal activity.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

Disclosures of Personal Information for a Business Purpose

Below, we list the categories of personal information we have disclosed for business purposes (such as to companies that provide services to us or where we are required by law to do so) and for each the categories of third parties to whom we may disclose such information in the preceding twelve (12) months:

Category A: Identifiers: Service providers, affiliates, Government agencies, Internet service providers, operating systems and platforms, advertising networks and data analytics providers

Category B: California Customer Records: Service providers, affiliates, Government agencies, Internet service providers, operating systems and platforms, advertising networks and data analytics providers.

Category D: Commercial information: Service providers, affiliates, Government agencies, Internet service providers, operating systems and platforms, advertising networks and data analytics providers.

Category F: Usage Data: Service providers, affiliates, Government agencies, Internet service providers, operating systems and platforms, advertising networks and data analytics providers.

Category H: Sensory Data: Service providers, affiliates, Government agencies, Internet service providers, operating systems and platforms, advertising networks and data analytics providers.

Category K: Inferences: Service providers, affiliates, Government agencies, Internet service providers, operating systems and platforms, advertising networks and data analytics providers.

Under the CCPA, a “sale” includes disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Sites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. As defined by the CCPA, we may “sell” certain categories of personal information as follows: Cat. A: Identifiers, Cat. F: Usage Data and Cat. K Inferences to advertising networks and data analytics providers.

CCPA Rights. In general, California residents have the following rights with respect to their personal information as set forth below.

Do-not-sell (opt-out):

Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.

Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):

- - categories of personal information collected;
  - categories of sources of personal information;
  - categories of personal information about them we have disclosed for a business purpose or sold;
  - categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
  - the business or commercial purposes for collecting or selling their personal information; and
  - a copy of the specific pieces of personal information we have collected about them.

Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests

To exercise your right to know, or right of deletion as described above, please submit a verifiable consumer request to us by clicking on the following link: CCPA Request

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. When you submit a request to know or a request to delete, we will take steps to verify your request by requiring you to log into your account or by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents will be required to provide proof of their authorization, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Other California Privacy Rights

Your Privacy Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at privacy@zebit.com, and include in your request a current California address and your attestation that you are a California resident.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date.

Loyalty Programs and Financial Incentives Disclosure

Zebit offers a loyalty incentive program Zebit Z Rewards Program (“Z Rewards”) to its customers. Z Rewards, provides special offers and benefits to customers who participate Z Rewards (Rewards Participants).

Z Rewards, provides Rewards Participants with points for their rewards-earning actions, including but not limited to purchases, on-time payments, continuous enrollment in automatic payments, and installation of the Zebit mobile app. Rewards Participants can subsequently redeem the points for coupon codes that they can apply to future orders with Zebit. In order to provide Rewards Participants with the incentives described above, we use personal information about Rewards Participants including account number, purchase history, payment history, etc. to identify them as a member of the program and provide them with relevant messaging, experiences and deals. Zebit does not generally assign monetary value to consumers’ personal information. Although Zebit does not collect additional information for joining the Z Rewards other than what is already collected in order for the customers to use and purchase from us, to the extent the CCPA requires that a value be assigned to such programs, we value the information as being equal to the value of the discounts we offer in Z Rewards through points redemption. We do not calculate the value of consumer data in our financial statements. We make this good faith estimate for California residents.
Categories of Personal Information used in Z Rewards:

Identifiers (e.g., name, mailing address, email address, phone number)
Birth year and month
Commercial information (e.g., products or services purchased, purchase history, payment history)
Internet or other electronic network activity (e.g., browse or search history)
Inferences drawn from any of the above (e.g., preferences or characteristics)

You may opt in to Z Rewards online and you may opt out at any time by emailing help@zebit.com. Please put Z Rewards Opt Out in the subject line of the email and state that you wish to opt out of the program in body of the email.

Contact Information

If you have any questions or comments about this Notice, the ways in which Zebit collects and uses your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: www.zebit.com/contact/

Email: privacy@zebit.com

Postal Address:

Zebit, Inc.
Attn: Customer Service
9920 Pacific Heights Blvd, Suite 150
San Diego, CA 92121