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Privacy

Introduction

e-Zassi, LLC, (“e-Zassi,” “we,” “us,” or “our”) is strongly committed to protecting the privacy of the non-public personal information of each Subscriber (as hereinafter defined) and providing a safe and secure online environment when using our Web site: www.e-zassi.com and its sub-domains or such other URLs or domain(s) as e-Zassi determines from time to time (collectively, the “Site”).

The purpose of this Privacy Policy (this “Policy”) is to provide an understanding of our practices regarding the information collected when the Site is accessed by a Subscriber, how we may use and/or disclose the information and how corrections and/or updates may be made to the information. Please note that accessing the Site reaffirms consent to and agreement with the terms of this Policy. If the terms of this Policy are not agreed with, please do not access the Site.

Definitions

Initially capitalized terms not defined herein shall have the meanings ascribed to such terms in the Terms of Use or e-Zassi Subscription Agreement, as applicable.

Agreement” means, collectively, the Terms of Use or e-Zassi Subscription Agreement (individual Subscriber or enterprise Subscriber, respectively, as applicable) as amended by e-Zassi from time to time, and any information available on the Site and incorporated therein by reference.

Subscriber’s Personal Information” shall mean information about a Subscriber, including a Subscriber’s name, mailing address, e-mail address, telephone number, credit card account and billing information, contact information, and other related information disclosed and delivered to e-Zassi by Subscriber via the Internet by means of the browser interface to the e-Zassi System and from which Subscriber’s identity is discernible.

Subscriber(s)” means a registered account holder with the Site who enters into the Terms of Use agreement as an individual Subscriber or an e-Zassi Subscription Agreement as an enterprise Subscriber.

 

Information Collection, Processing, and Use

  • When a Subscriber registers with the Site, such Subscriber will be asked to provide Subscriber’s Personal Information.
  • If, at the time of registration, a Subscriber elects to pay subscription fees by credit card, we receive and record the Subscriber’s name, mailing address, billing address, telephone number, and the credit card number provided for payment of the annual subscription fee and any other fees.
  • When the Site is accessed we may also collect technical information about such accessing computer hardware and software such as the IP address, browser type, domain names, referring Web site addresses, pages visited on the Site, and time spent on the Site. e-Zassi uses Genius.com Web Analytics to analyze traffic to the Site Genius.com does not create individual profiles for visitors, but only collects aggregate data.
  • We require that Subscribers provide a valid e-mail address on the e-Zassi System “Help” page of the Site so that we are able to respond to question(s) pertaining to the functionality of the e-Zassi System by e-mail.
  • If consent for us to do so is provided, we may use the information we gather on the Site, including contact information to inform Subscribers via e-mail or other communications regarding the following: additional and/or new products or Services available from us or our affiliated companies, updates at the Site, or requests for opinions on current products and Services or potential new products and Services that may be offered. If a Subscriber no longer wishes to receive such information from us, such Subscriber can opt-out by (i) following the instructions provided in the initial or billing e-mails, as applicable; (ii) sending an e-mail requesting such to support@e-zassi.com with the subject E-Mail Remove. Notwithstanding anything contained in this Policy or the Agreement to the contrary, e-Zassi may use, as its deems appropriate, statistical data generated through the use of Subscriber’s Personal Information provided that neither such use nor such statistical data shall result in the disclosure of any Subscriber’s Personal Information that will directly or indirectly identify any Subscriber.
  • We may have an area on the Site where Subscribers can submit feedback for the products and Services we provide. Any feedback submitted on the Site becomes our sole property, and we can use such feedback as we deem appropriate, including, but not limited to marketing purposes.

Information Sharing and Disclosure

e-Zassi will not share, sell, or rent e-mail addresses, passwords, first or last names, mailing addresses, telephone numbers, credit card and billing information, or other Subscriber’s Personal Information provided on the Site with anyone, except as stated below:

  • We may disclose Subscriber’s Personal Information as legally required in order for us to respond to subpoenas, court orders, warrants, or other legal process.
  • We may disclose Subscriber’s Personal Information (i) with such Subscriber’s consent or (ii) where disclosure is necessary in order to complete a transaction to which the Subscriber has consented.
  • e-Zassi offers a feature through the Site that publishes a Subscriber’s profile to the public Internet, which public profile shall include among other items, portions of Subscriber’s Personal Information, such as the Subscriber’s name, title, company name, city, and state (but not the Subscriber’s email address, mailing address, physical street address, or credit card information), however, e-Zassi does not warrant how often third-party search engines will update their cache to include such public profile. A Subscriber may turn off the public profile feature by editing its account settings.
  • We may partner with third parties to obtain specific services or employ companies or individuals to perform functions on our behalf. Examples include hosting our Web servers, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. These third parties, companies, and individuals may have access to a Subscriber’s Personal Information as necessary to perform their functions, but they may not share the information with any other third party.
  • A Subscriber’s credit card information is used by credit card authorization processors or third-party financial institutions to verify the credit card numbers and process credit card payment transactions.
  • Where required to do so pursuant to contractual obligations, we may disclose information about a Subscriber’s e-Zassi account and account usage (except for credit card information) on a confidential basis to third-party auditors and to measurement and analysis firms. These parties are not permitted to use personally identifiable information except for the purpose of providing their services to e-Zassi.
  • In order to register as a Subscriber, the potential registrant must opt in and provide e-Zassi with consent to share Subscriber’s Personal Information with third parties for purposes of performing the above-referenced functions.
  • Should e-Zassi transfer Subscriber’s Personal Information to a third party that is acting as an agent, e-Zassi shall make certain that the third party subscribes to the safe harbor principles or is subject to The European Commission’s Directive on Data Protection or another adequacy finding. As an alternative, e-Zassi may enter into a written agreement with such third party requiring that the third party provide at least the same level of privacy protection as is required by the relevant principles.
  • The information we gather on the Site may be shared with our affiliated companies in order to deliver the products and Services we offer or in order to undertake analysis of our database such as aggregate profiling of our registered Subscribers.
  • In the event that we are, or substantially all of our assets are, acquired (whether by merger, consolidation, or purchase), Subscriber information, including Subscriber’s Personal Information will be transferred. In addition, if we become the subject of a bankruptcy proceeding (whether voluntary or involuntary), we or our trustee in bankruptcy may sell, license, or otherwise dispose of such information in a transaction approved by the bankruptcy court. In such circumstances, Subscribers will be notified via e-mail or through a prominent notice posted on the Site.

Management of Personal Information

Subject to certain exceptions, upon receipt of written request from a Subscriber and provided such Subscriber provides us sufficient information to confirm such Subscriber’s identity, we will provide the Subscriber’s Personal Information that we have collected about such Subscriber for the purposes of enabling such Subscriber to correct, amend, or delete any inaccuracies. Subscribers may make this request to us via e-mail at support@e-zassi.com or visit the “Help” page of the Site. If we are unable to provide the requested information within thirty (30) days after receipt of written request for same, we will provide a timeline for providing the requested information. If we deny access to a Subscriber’s Personal Information, we will explain why access was denied and give contact information for further inquiries regarding the denial of access.

 

Security of Personal Information

  • e-Zassi maintains security procedures and internal controls to protect the confidentiality of Subscriber’s Personal Information in accordance with commercially reasonably prudent practices in the application service provider industry.
  • e-Zassi has implemented commercially reasonable security measures to protect Subscriber’s Personal Information from unauthorized access, disclosure, use, alteration, unlawful destruction, or accidental loss. We do not, however, guarantee that unauthorized third parties will never be able to defeat these measures or use such information for improper purposes.
  • Industry-standard encryption, such as the Secure Socket Layer (“SSL”) protocol, protects data transmissions to and from browsers, including transmissions of credit card numbers. SSL makes it difficult for credit card information to be intercepted or stolen while being transmitted. e-Zassi utilizes VeriSign Extended Validation Secure Sockets Layer (EV_SSL) Certificates for encryption services on our production servers. We use a third party transaction processing company to process our credit card transactions on the Site. For information on this company’s privacy and security practices, please go to http://www.verisign.com/verisign-business-solutions/commerce-enablement-solutions/index.html.
  • e-Zassi shall not disclose or use Subscriber’s Personal Information for any purposes other than to carry out the purposes for which Subscriber disclosed the information to e-Zassi, or as permitted by the Agreement. In addition, e-Zassi will take reasonable measures to protect the integrity, delivery, and security of any transmissions it initiates containing Subscriber’s Personal Information; however, e-Zassi assumes no liability for such information once transported onto a non-e-Zassi managed communication network, including, but not limited to, the Internet.
  • Subscribers may be asked for authentication, in some cases, before certain account transactions are performed.

IP Addresses; Information Collection and Use Practices

  • e-Zassi receives an IP address each time a Web page from the Site is viewed. IP address, however, are not linked to an e-mail address, password, or User Name. IP addresses may be used for various purposes, including to diagnose reported service or technical problems associated with IP addresses, or to estimate the total number of users visiting the Site from specific locals, countries, or regions of the world.

Log Files

  • When a Web page on the Site is requested, that request (including the date and time) is logged on our servers with information, including the IP address of the computer that requested the page.
  • We use log files for debugging and troubleshooting purposes. IP addresses and access times are not linked to e-mail addresses, passwords, or User Names.

Cookies

  • Certain services requested from e-Zassi, may result in our attempt to set cookies on the requesting computer and later access those cookies to help personalize and maximize the online experience and time online.
  • A “cookie” is a small amount of data that often includes a unique identifier that is sent to a browser requesting to view a Web page from a Web site’s computers and then stored on the requesting computer’s hard drive. Cookies are only used as an option selected by the user that allows us only to recall an e-mail address from the cookie that we sent to the computer. The only personal information about a Subscriber that is associated with the cookie is the Subscriber’s e-mail address.
  • The purpose of a cookie is to tell the Web server that a visitor has returned to a specific page. For example, when a Subscriber registers for Services, a cookie helps us to recall specific information (such as User Name, password, and browser preferences).
  • Normally, preferences in a Web browser can be set to accept all cookies, reject all cookies, or notify the user when a cookie is set and permit the user to accept or decline cookies on an individual basis. If all cookies are rejected, it may hinder performance and negatively impact the experience on the Site.

Links; Other Companies’ Cookies on the Site

  • The Site may contain links to other Web sites. We have no access to or control over cookies used by our business partners or other Web sites to which we link, if any.
  • In the event that a banner ad is provided by a third-party, it is possible that the third-party advertiser may attempt to store a cookie on the accessing computer’s hard drive.
  • Advertisers’ and other Web sites’ use of cookies is subject to their own privacy policies, not the e-Zassi Privacy Policy. e-Zassi is not responsible for the privacy practices of such other Web sites. We encourage you to check the privacy policies of those Web sites before disclosing any non-public personal information. This Policy applies solely to information collected by the Site.

Access upon Termination

  • Upon the expiration or earlier termination of the Agreement, a Subscriber will no longer have access to or use of the e-Zassi System, however, any Subscriber’s Personal Information shall continue to be treated confidentially by e-Zassi pursuant to the terms of the Agreement.

Changes to this Privacy Policy; Notification of Changes

  • e-Zassi may amend this Policy from time to time without prior notice. If we decide to change this Policy, we will post the changes to this Policy, the homepage of the Site, and other places we deem appropriate so our Subscribers are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Any such amendments, changes, deletions, modifications, revisions or updates will be effective immediately upon publication on the Site.
  • If, however, we are going to use Subscriber’s Personal Information in a manner different from that stated at the time of collection, we will notify users by posting a notice on the Site for thirty (30) days.
  • Continued access to and use of the Site after any such amendments, changes, deletions, modifications, revisions or updates will constitute such Subscriber’s acknowledgement and agreement to be bound by such amendments, changes, deletions, modifications, revisions or updates. Because of the possibility that this Policy could change between visits to the Site, we recommend that checking this Policy each time the Site is visited.
  • We will use information collected through the Site only in accordance with the current Policy in effect.

Questions or Suggestions/Privacy Policy Complaints

For reporting suspected problems or violations of this Policy, or for questions, suggestions, or concerns about this Policy, please feel free to e-mail us at support@e-zassi.com or call us at 1-866-369-5170 and speak to one of our representatives. We may also be contacted at the following mailing address: 1886 South 14th Street, Suite Six, Fernandina Beach, Florida 32034.

 

Effective Date: December 14, 2009