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Privacy Policy

Effective Date: 8/11/23

This Privacy Notice describes how Zephyr (“our,” “we”) collects, uses, and shares personal information.

In particular, this Privacy Notice applies to:

  • Our website at Zephyr-Cloud.io as available to the general public, and any of our subdomains of zephyr-cloud.io (our “Website”). This Privacy Notice applies to visitors to our Website (“Visitors”).
  • Our other online services we operate that post this Notice (“Services”). As a central part of our Services, we enable our customers and their employees (“Customers”) to track, observe and more effectively utilize software code and other developed components and content across their websites and online services. Through our Services, we may interact with our Customers’ online visitors to their websites and online services (“Customers’ Audience”).

For all Visitors, Customers, and members of our Customers’ Audience who interact with us online, we collect information you choose to give us and other information that may be collected from your use of our Website and Services, including from your device. We use that information to operate our business and for purposes set forth below. Below, we also describe choices we offer with respect to your information. This Privacy Notice does not apply to information that cannot be identified to any individual, household, or their devices, such as de-identified or anonymized information.

This Privacy Notice does not apply to third parties, including our Customers. You should contact these parties directly to understand their practices.

Information We Collect

To provide our Website and Services, we may collect data by which Visitors, Customers, and members of our Customers’ Audience may be identified. We may also collect information about the devices and equipment you use to access our Website and Services, including usage data.

We collect this information from a variety of sources, including:

  • Directly from you when you provide it to us.
  • Indirectly through our provision of Services to our Customers.
  • Automatically as you utilize the Website or Services.
  • With respect to our Website, from third parties, including analytics providers.

Personal Information Collection on our Services

Our Services are available to our Customers and their relevant employees and account managers. Through the provision of our Services to Customers, we interact with members of our Customers’ Audience. Below, we summarize our key practices for each.

Category of User Personal Information Collected Key Information Uses
Customers (and their relevant employees and account managers) First and last name, contact information (e.g., email address, phone number, mailing address), organization affiliation, role, login credentials, logging and technical usage information when interacting with a Service, support communications or other interactions with us, and any information required to provide the Services. - Manage the business relationship and Services account on behalf of our Customers.
- Permit login to the Services.
- Process transactions and payments.
- Manage the account and provide support.
- Provide information about new or related services we may offer.
Members of Customers’ Audiences IP addresses, date and time you access our services and the content you access, and other information automatically available in connection with a web browser request (such as the type of device used and the operating system on that device, or errors encountered with a request). - To deliver content to our Customers’ Audience in connection with our Customer’s use of our Services.
- To enhance, support, and manage our Services.

See “Other Ways We Use Information We Gather” for additional descriptions of how we use the information we collect.

Information Collection on our Website

If you are a Visitor on our Website, we may collect your name, email, job title, phone number and other information you choose to provide. We may collect this or other information you choose to provide when you request a service demonstration from us, fill out a form on our Website, reach out to us via email, or otherwise communicate with us. We use this information to provide our Website, to communicate with you and provide you information that you request from us, including marketing communications and promotions.

Other Information Collection, Logging, and Automatically Collected Information

In all cases, we may collect and use other information you choose to provide or with your consent.

Information we collect through automatic data collection technologies. If you are a Visitor or Customer, we may collect data regarding your use of our Website or Services through cookies, web beacons, and other automatically collected information. This data may include your IP address, date and time you access our services and the pages and content you access during your visit, websites that you link to or from, whether you receive or open an email or other communication from us, and the links you click on within those emails. We may also collect information from your mobile device or your computer about how you interact with our services, including the date of the visit, the time of arrival and length of visit to the services, the type of device used and the operating system on that device, browser type, a list of files downloaded or pages viewed, your IP address, and any errors encountered. This information helps us address customer support issues, provide you with a personalized experience, prevent fraudulent use of our services, and manage the Services we provide you, including gathering aggregated data about engagement.

Other parties may collect personally identifiable information about your online activities over time and across third-party websites when you use our services, including our Website. We do not control any personal information once collected by these parties. We do not respond to “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services.

Information we collect from third party sources. Through Visitors’ and Customers’ use of our Website and Services, we may collect information from advertisers, analytics providers, and other third parties. These third parties may collect information about our audience in connection with cookies, pixels, content, widgets, or other component provided on our Websites and Services. They may share this information with us by, for example, providing us analytical reports and insights on our audience. The information third parties collect may be associated with your personal information or they may collect information about your online activities over time. They and we may use this information to provide you with interest-based advertising or other targeted content, and for other purposes (such as to better understand our Website’s and Service’s audience).

Other Ways We Use Information We Gather

We may use data we gather to operate our business and for a variety of purposes, including the following:

  • To enhance, support, and manage our Services, including to maintain, analyze, customize, and improve your experience in connection with our Website and Services.
  • To communicate with you and provide you information that you request from us.
  • To provide customer and technical support.
  • To monitor and enforce our contracts, legal terms, acceptable use or other policies or similar terms.
  • To comply with law and satisfy our regulatory and compliance obligations. Additionally, to support compliance efforts on behalf of others and ourselves that support our provision of services to you.
  • To detect and prevent fraud and other prohibited, illicit or illegal activity, and to protect the rights and vital interests of you, others, and ourselves.
  • To address existing or anticipated disputes.
  • To otherwise operate our business, including support for transactions impacting our company as a whole (such as mergers, acquisitions, or asset purchases).
  • To fulfill any other purpose for which you provide your information to us.
  • For other purposes permitted by law, described to you when you provide your information or to which you consent.

As permitted by law, we may combine the information we gather about you in identifiable form, including information from third parties. We may use this information, for example, to improve and personalize our services, content and advertising.

How We Secure Information

We are committed to maintaining measures to protect the security of your information. Of course, despite these measures, no network or system is ever entirely secure and we cannot guarantee the security of networks and systems that we operate or that are operated on our behalf.

How We Share Information

We may share your information with third parties as reasonable to operate our business, to provide the Services to you and others, as permitted or required by law, or as directed or authorized by you. For example:

Intra-Service Sharing. If you are a member of our Customers’ Audience, your information may be accessible to the respective Customer whose site you may have visited. You should contact our Customer to understand how they use your information.

Affiliated Companies. We may share some or all of your information with our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

Third Party Sharing. We work with third party parties to help us provide and support our services and to support our internal operations, and for analytics, advertising and promotional support. In some cases, they may use your information subject to their own privacy policies and to comply with their own legal and regulatory obligations. We work with different types of third parties, presently including:

Professional Advisors, Law Enforcement and Regulators. We share your information with our professional advisors who provide legal, compliance, auditing, accounting, banking, insurance, consulting, or similar services, and with regulators, law enforcement, or government agencies to:

- comply with our legal and regulatory obligations, including those compliance obligations of federal, state or local regulators;

- conduct audits and manage financial, insurance, or other matters;

- protect our interests, property or legal rights, or those of our customers or third parties;

- respond to a subpoena, court order, or similar law enforcement request, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of this Privacy Notice or other applicable terms; and

- for other legal purposes, such as to enforce our terms and conditions, or to exercise or defend legal claims.

Corporate Transaction. In the event of a corporate transaction, we may share your personal information with companies or other entities in connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, restructuring, divestiture or dissolution of all or a portion of our business, or other similar event.

Other Disclosures. In addition to the above disclosures, we may disclose personal information in the event that we believe such disclosure is (i) necessary to provide our services or operate our business; (ii) in accordance with purposes we describe when you share it with us; (iii) permitted by law; or (iv) with your consent or at your direction. In addition, we may use and disclose aggregate data around performance, technology patterns, and overall development lifecycles to provide benchmarking and industry insights to our Customers and others.

What Choices Do I Have?

Update personal information. If you are a Customer account manager, you can update certain information that you have provided by logging into your account. As permitted by law, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or prevent the provision of our Services.

Marketing communications. You may receive marketing communications from Zephyr. You may opt out of receiving marketing emails by following the unsubscribe link in each email. Please note that you may continue to receive non-marketing emails from us after you opt-out.

Cookies. You have a number of choices regarding certain cookies. Most web browsers automatically accept cookies, but you may modify your browser’s setting to notify you of cookie placement or decline cookies. If you choose to decline cookies, certain features of our website may not function properly or at all as a result.

Updates to Our Privacy Notice

We may update this Privacy Notice from time to time in order to provide clarification or notice of changes to our practices. If we make changes, we will revise the Effective Date at the top of this Privacy Notice. Changes to this Privacy Notice will be effective once they are posted unless otherwise indicated. We may choose to notify you by email to the email address in our records.

Contact Information

If you have any questions or concern about this privacy notice or the privacy practices at Zephyr, please contact us by emailing us at

Last Updated: 4/16/2024

Additional Notice for California Residents

This Additional Notice to the Privacy Notice applies to residents of California only. California law requires businesses that determine the purpose and means of processing personal data to make certain disclosures and offer data rights. Accordingly, Zephyr offers the disclosures below to Customer account managers and Visitors to our Website. These disclosures and rights may not apply where Zephyr is processing data on behalf of its Customers (in particular, members of our Customers’ Audience). Members of our Customers’ Audience should contact the Customer directly to exercise any rights which they may have.

Collection of Personal Information

We collect personal information as necessary to operate our business, to comply with our legal and regulatory obligations, and to provide our Website and Services to you. Within the last 12 months, we have collected the following types of personal information about you:

- Identifiers, including a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name,.

- Sensitive identifiers, including a name, address, telephone number, or any other financial information,. Some personal information included in this category may overlap with other categories.

- Protected classifications under California or federal law, including age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, and genetic information (including familial genetic information).

- Commercial records, including records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies.

- Biometric information, including genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

- Internet or other similar network activity, including browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

- Geolocation, including physical location, movements, and data derived from a device and that is intended to locate a customer within a geographic area.

- Professional or employment-related information, including professional and employment-related information such as an employer’s name and employees’ names, job titles, responsibilities, practice areas, specialties, qualifications, and/or areas of focus.

- Professional or employment-related information, including professional and employment-related information such as an employer’s name and employees’ names, job titles, responsibilities, practice areas, specialties, qualifications, and/or areas of focus.

- Non-public education information, including 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, or student disciplinary records.

- Inferences drawn from other personal information, including a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

To learn more about the information we collect, please see our Privacy Notice.

Disclosure of Your Personal Information

The table below identifies how in the past 12 months we have disclosed information collected about individuals.

Personal Information Disclosed Business Purpose for Sharing Categories of Third Parties Shared With
Identifiers. To provide and manage the Website and Services
To deliver targeted advertising
As otherwise set forth in the How We Share Your Personal Information section
Advertising service providers
Marketing service providers
Data and analytic technology platforms
Other service providers or supporting professionals (e.g. IT providers, auditors, and accountants)

We may also share information to comply with law, to protect the interests of ourselves or others, and in connection with a merger, sale, or acquisition of all or part of our business. To learn more about how we share data, please see additional detail as set forth in the Privacy Notice.

How Personal Information Is Collected and Used

We collect personal information directly from the following sources:

- Directly from you. For example, when you sign up for the Services or request information on our


- Indirectly from you. For example, from observing your actions on our Website.

- From third parties. For example, from advertising and analytics providers who deploy content or tools on our Website. We may use your information for the following business purposes:

- To provide our Website and Services to you.

- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

- Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.

- Debugging to identify and repair errors that impair existing intended functionality.

- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with us.

- Performing services on behalf of our customers, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.

- Supporting our advertising and marketing services as permitted by law.

- Undertaking internal research for technological development and analytics.

- To improve, upgrade, or enhance the services.

To understand more about the purposes for which we collect personal information and the sources of our collection, see the Privacy Notice.

Sales of Personal Information

In the last 12 months, we have disclosed your personal information to third parties in connection with operating our online services, including network identifiers and inferences about your preferences to third party analytics providers. Under the definition of “sale” under California law, we are disclosing this data sharing as a “sale” of your personal information under California law. You may opt out of the sale of your personal information by visiting the Do Not Sell My Personal Information page. We do not sell the personal information of individuals who we know to be under 16 years of age.

Your California Privacy Rights

If you are a California resident, you have the following rights regarding your personal information:

− Right to Access. You have the right to access the personal information we have collected about you. If requested, we will provide you with a copy of the personal information we have collected.

− Right to Know. You have the right to request that we disclose the following about your personal

information in the preceding 12 months:

o The categories of personal information we collected;

o The categories of sources from which we collected your personal information;

o The business or commercial purposes for collecting, selling, or sharing your personal information;

o The categories of third parties to whom we disclose your personal information; and

o The specific pieces of personal information we have collected about you.

− Right to Delete. You have the right to request that we delete your personal information. Upon verifying your identity and the validity of your request, we will delete your personal information from our records and instruct our service providers, affiliates, or third parties to delete your information as required by law. We may deny your deletion request if retaining the information is permitted under law.

− Right to Correct. You have the right to correct inaccurate personal information that we maintain about you. Upon verifying your identity and the validity of your request, we will use reasonable efforts to correct your personal information as directed.

− Right to Opt-out of Selling/Sharing. You have the right to direct us to not sell your personal information at any time. To exercise the right to opt out, you may submit a request to use by visiting our Do Not Sell or Share My Personal Information page. You do not need to create an account with us to exercise your opt out rights. Your right to opt out of ‘sharing’ information is aspecific right to prevent the provision of your personal information to a third party for them to target advertising based on your behavior across unaffiliated websites.

− Right to Limit Use of Sensitive Personal Information. You have the right to limit how your sensitive personal information is used and/or disclosed to third parties. Please visit our Limit the Use of My Sensitive Personal Information page to exercise this right.

We may not discriminate against you for exercising any of your rights under the California Privacy Rights Act. This means that we may not deny you services, or charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under the California Privacy Rights Act. However, we may charge different prices or rates, or provide a different level or quality of services, where that difference is reasonably related to the value provided to us by your personal information.

You may designate an authorized agent to make a request to know, request to correct, or request to delete. An agent may be an individual or a business entity. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to verify your identity directly (subject to certain exceptions). We may refuse a request if the agent does not provide adequate proof of their authorization.

How to Exercise These Rights

You may request to exercise the foregoing rights by:

- [email protected]

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. In connection with such verification, we may ask you to provide your Zephyr Cloud username. We may limit our response to your exercise of the above rights as permitted by law.

Data Storage and Retention

We will store your personal information until the initial purpose for which we collected such data has been satisfied, including the purpose described in our How We Use Information We Collect section. If you consent to a new or additional purpose for retaining your data, your personal information may be stored for longer. We have implemented measures designed to secure your personal information against unauthorized use, loss, destruction or alteration. We cannot guarantee the security of your personal information. We retain your data according to a set retention schedule, which can be generally described as follows: until account is deleted. At the end of that retention period, all data is deleted unless subject to an exception under law.

Contact Us

If you have any questions or concern about privacy at Zephyr, please contact us at [email protected].

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Privacy Policy