Last modified: June 30, 2020

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 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 Policy applies to all users of the Website and Services.

Please read this 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 policy. This 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 policy periodically for updates.

Children Under the Age of 13

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 help@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 or you provide to us.

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.

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, service providers, and others 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 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 help@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 contacting our Customer Service Department at help@zebit.com help@zebit.com or via our toll-free number: 855-449-3248.

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.

Changes to Our Privacy Notice

We reserve the right to amend this policy at our discretion and at any time. When we make changes to this policy, we will post the updated notice on the Website and Services and update the notice’s effective date. Your continued use of our Website and Services following the posting of changes constitutes your acceptance of such changes.

Contact Information

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

Help@zebit.com

or via our toll-free number:

855-449-3248

Zebit, Inc.

Attn: Customer Service

9530 Towne Centre Drive, Suite 200

San Diego, CA 92121

 

Privacy Notice for California Residents

Effective Date: June 30, 2020

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.

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. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). 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. Internet or other similar network activity. 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. No
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 (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information. No
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes.

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

  • Directly from you. For example, from forms you complete to apply for credit or when you purchase good and services using such credit.
  • From third-party data providers, including those defined as Consumer Reporting Agencies under the Fair Credit Reporting Act, for the purposes of identity validation, fraud prevention, and underwriting related to your application for credit.
  • From advertising and social networks.
  • From data analytics providers.
  • Indirectly from you. For example, from observing your actions on our Website.

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. For example, if you fill out our credit application, we will use that information to run the necessary checks on your credit history and validate your identity. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • 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.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers who provide good and services to use and are limited in their use of personal information through agreements with us
  • Advertising networks and data analytics providers
  • Government agencies
  • Internet service providers, operating systems and platforms
  • Product vendors that drop-ship our products
  • Consumer Reporting Agencies

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.
  • Government agencies
  • Internet service providers, operating systems and platforms
  • Advertising networks and data analytics providers
  • Product vendors that drop-ship our products
  • Consumer Reporting Agencies

 

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold any of the preceding categories of personal information.

 

 

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide access and data portability rights for B2B personal information under the current CCPA exception.

Deletion Request Rights

You have the right to request that we delete personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at 855-449-3248
  • Emailing us at help@zebit.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative under California law.
    • In general, we will verify your request and your identity when you log-in to your account, provide your name, address, account number and other information so that we may match it to information that we maintain about you and/or [through a third-party identity verification service]. If you have questions or concerns about our privacy practices, you may [Contact Us].
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Fees

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not collect or sell the personal information of consumers we actually know are less than 18 years of age.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing Help@zebit.com or via our toll-free number: 855-449-3248.

 

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not currently disclose information to third parties for their direct marketing purposes.

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. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

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

Phone: 855-449-3248

Website: www.zebit.com

Email: help@zebit.com

Postal Address:

Zebit, Inc.

Attn: Customer Service

9530 Towne Centre Drive, Suite 200

San Diego, CA 92121