July, 2nd 2018
Naroomi Corporation (“Flyzoo”, or “we”, or “our”, or “us”) understands that your privacy is important to you and that you care about how your information is used and shared online.
We respect and value the privacy of everyone who visits Our Site and uses our Chat Service and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site and Our Chat Service.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site and Chat Service;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
means this website, www.flyzoo.co
means website owner’s and administrators that purchased and/or added our Chat Service to their website(s) to provide chat functionalities to their Users.
Anybody accessing Our Site or the Chat Service provided by Us
means the chat features provided by our software
means Naroomi Corporation, 2680 139th Ave SE Bellevue WA 98005 USA
2. Information About Us
2.1 - Our Site and Chat Service is operated by Naroomi Corporation, 2680 139th Ave SE Bellevue WA 98005 USA
3. Scope – What Does This Policy Cover?
It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users).
We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
4. What Data Do We Collect?
Some data will be collected automatically by Our Site and our Chat Service, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account.
Depending upon your use of Our Site, We may collect some or all of the following data:
- 4.1 - your account registration data (username, email, password);
- 4.2 - business/company name and billing information;
- 4.3 - IP address and location information as state and city (automatic)
- 4.4 - web browser type and version (automatic);
- 4.5 - operating system (automatic);
- 4.6 - a list of URLs starting with a referring site, pages visited on Our Site and pages visited on site’s running our Chat Service (automatic)
- 4.7 - Chat messages and debug information collected by the Chat Service
5. How Do We Use Your Data?
5.1 - All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 - We use your data to provide our Chat Service to you. This includes:
- 5.2.1 - Providing and managing your Account;
- 5.2.2 - Providing and managing your access to Our Site and Chat Service;
- 5.2.3 - Personalising and tailoring your experience on Our Site and Chat Service;
- 5.2.4 - Supplying Our Chat Service services to Customers and his Users
- 5.2.5 - Responding to communications from you;
- 5.2.6 - Troubleshooting, detecting and protecting against error, fraud, or other criminal activity;
- 5.2.7 - Supplying you with newsletters, alerts etc. that you have subscribed to; you may unsubscribe or opt-out at any time by opt-out link provided on communications or by contacting us at firstname.lastname@example.org
- 5.2.8 - Marketing retargeting campaigns;
5.2.9 - Compute aggregated metrics (such as pages viewed and total number of visitors) for statistical analysis including without limitation determining trends and patterns about usage and demographics for the purpose of improving the Services, by taking reasonable measures to anonymize private information whenever possible
5.3 - In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
5.4 - With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 - Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
5.6 - Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- a) you have given consent to the processing of your personal data for one or more specific purposes;
- b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- c) processing is necessary for compliance with a legal obligation to which we are subject;
- d) processing is necessary to protect the vital interests of you or of another natural person;
- e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child
6. How and Where Do We Store Your Data?
6.1 - We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.
In any event, We will conduct an annual review to ascertain whether we need to keep your data.
Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy:
- Chat messages are stored for a maximum of 6 months
- Inactive accounts are removed after a maximum of 3 years
- Billing information and invoices as long as required to fulfill Our tax obligations
6.3 - Information you provide to us is stored on our secure servers. Any payment transactions will be carried out by PayPal over encrypted connections using SSL technology.
6.4 We take security very seriously, and ‘privacy by design’ is baked into our engineering and product development principles but as with any online service, despite our use of leading security tools and techniques, the personal data we hold about you can never be 100% immune from unauthorised access.
7. Do We Share Your Data?
7.1 - We may contract with third parties to supply our services to you on Our behalf. These may include payment processing, cloud infrastructures, database-as-a-service, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.2 - We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.3 - In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 - In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data?
9.1 - The platform provides tools for Customers and their Users to manage their Account (remove messages, change password, edit username and location). You may also send a request at email@example.com to correct, amend, delete and obtain a copy of your personal data.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 - You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10.3 - You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org.
By using Our Site and/or Chat Service you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us.
- 1. We use both session and persistent cookies on Our Site and Chat Service
2. The names of the cookies that we use on Our site and Chat Service, and the purposes for which they are used, are set out below:
- we use 'fzm' to check if the chat widget is in the minimized state
we use '__fzg' on the chat widget to identify guest chat users
- we use ‘__fz*’ on the chat widget to identify authenticated chat users
- we use ‘__fzvid’ on the chat widget to recognise the pages visited by chat users
- we use 'ASP.NET_SessionId ' to handle the session on Our Site
- we use ‘__FlyzooSiteAntiForgeryToken’ as part of security mechanism for the forms Our Site
- we use ‘at’ on the chat widget to authenticate the user
- we use ‘chat-status’ and '‘lastcmd’ to synchronize the chat windows on browser's tabs
- we use ‘fz-sidebar-open’ to keep the status (open/closed) of group chats
- we use ‘fz-sound’ to keep the sound state (on/off) for chat notifications
- we use ‘hdtg’ to hide/show the widget according to owner's configuration
Third party cookies
- We use Google Analytics, Hotjar and The Facebook Pixel to analyse the use of Our Site.
- Our analytics service provider generates statistical and other information about website use by means of cookies.
The information generated relating to our website is used to create reports about the use of our website.
Our analytics service provider's privacy policies are available at:
- Our Site also uses third party cookies.
- We publish cookies from SumoMe which are used to let use share links from Our Site, SumoMe may publish cookies from various third party providers like Linkedin, Reddit and Pinterest
- We publish cookies from Hotjar which are used for analytics and tracking what users do on our website.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
- the right to request access to, deletion of or correction of, your personal data held by Us;
- the right to complain to a supervisory authority;
- be informed of what data processing is taking place;
- the right to restrict processing;
- the right to data portability;
- object to processing of your personal data;
- rights with respect to automated decision-making and profiling
14. Contacting Us
15. Privacy Shield
Naroomi Corporation is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.
In compliance with the Privacy Shield Principles, Naroomi Corporation commits to resolve complaints about our collection or use of your personal information.
EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Naroomi Corporation, Inc. at: email@example.com
Naroomi Corporation has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning personal data transferred from the EU.
EU Persons may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances.
For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework at https://www.privacyshield.gov.
Naroomi Corporation does not transfer data to third parties outside of its agents.
Naroomi Corporation will obtain assurances from its agents that they will safeguard personal information consistently with this Policy.
Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant EU-US Privacy Shield Principles,
being subject to EU Directive 95/46/EC (the EU Data Protection Directive), EU-US Privacy Shield certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada).
Where Naroomi Corporation has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Naroomi Corporation will take reasonable steps to prevent or stop the use or disclosure.
Naroomi Corporation is liable for appropriate onward transfers of personal data to third parties who do not comply with the Privacy Shield principles.
Please be aware that Naroomi Corporation may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
EU Persons whose personal information is covered by this Privacy Shield Policy have the right to access the personal information that Naroomi Corporation maintains about them to correct, amend or delete such personal information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment or deletion should be sent to: firstname.lastname@example.org.
If Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, Naroomi Corporation will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed.
To the extent required by the Privacy Shield Principles, Naroomi Corporation obtains opt-in consent for certain uses and disclosures of Sensitive Data.
We recommend that you check this page regularly to keep up-to-date.