ZeeQuest

ZeeQuest Privacy Policy

Effective August 1, 2018

1. Imprint

ZeeQuest, Inc.
16192 Coastal Highway, Lewes, Delaware 19958

2. Privacy Policy

This privacy policy (hereinafter: “Privacy Policy”) provides information about how your personal data are processed by ZeeQuest, Inc. and/or, if applicable, its affiliates (companies that control, are controlled by, or are under common control with ZeeQuest, Inc.) (hereinafter: “we” or “us” or “company” or “ZeeQuest”).

Personal information is data that can be used to identify or contact a single person.
Please note our website may include hyperlinks to other websites neither owned nor managed by us. ZeeQuest may not be associated with these third-party websites and does not review their privacy policies. We cannot guarantee the privacy of any information that may be obtained by third parties at these other websites.

2.1 General information

2.1.1 What personal data do we collect and when?

a) In general
ZeeQuest collects certain personal information through its website when you choose to submit such information to us through email, an online form, or other method or that is supplied to us in conjunction with your use or potential use of our website and/or any of the products and services owned or marked or presented by ZeeQuest, including products and services like ZeeQuest Navigator Platform (former BaziWay), ZeeQuest Vitality and Appeal product line of natural herbal-based nutritional supplements (formerly known as VitaLeaf) and any of the ZeeQuest’s physical goods and/or digital products, packages or subscriptions or pre-enrolment forms or questioners or similar (hereinafter: the “Service”). For example, you may provide ZeeQuest with information in order to request information about our or third-party product or service, business opportunities, press inquiries, or for any other purposes.

ZeeQuest may also collect the content you create, upload, or receive from others when using website or Services. This includes things like emails you upload from others, massages and e-mails you write and receive, photos and videos you save, docs you create, and comments you make in conjunction with our website or Services. ZeeQuest may also collect information about the apps, browsers and devices you use to access Services which will help us provides features like automatic updates. Such information may include unique identifiers, browser type and settings, device type and settings, operation system, mobile network information including carrier name and phone number and application version number. We may also collect information about the interaction of your apps, browsers, and devices with our Services, including IP address, crash reports, system activity, and the date, time, and referrer URL of your request. We may also collect information about your activity in our website or Services, which we use to do things like recommend you how to improve the quality of your life. This activity information we collect may include: term you search for, content you watch, views and interactions with content and adds, purchase activity, people with whom you communicate and share content, etc. In some circumstances, we may collect information about your location when you use our Services, which help us to offer features like recommendations in conjunction with our Services on specific location. In some circumstances, ZeeQuest may also collect information about you from publicly accessible sources and from legitimate sources. We may also collect information about you from trusted partners, including marketing partners who provide us with information about potential customers of our Services, and security partners who provide us with information to protect against abuse. We may also receive information from advertisers to provide advertising and research services on their behalf.

ZeeQuest also collects information about website users through “cookies”. Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page. For further information about Cookies, please see our "Cookies and tracking" section below. By providing us with your information, using the site, app or any of these communication tools, you consent to ZeeQuest use of your information in a manner consistent with this Privacy Policy. ZeeQuest may also maintain a log of certain information concerning visitors to its website, including but not limited to a visitor's IP address (a computer's numerical internet address), the websites from which visitors access the website, the type of web browsers used to access the website, and the pages viewed. Such information may be treated as personal information about the visitor in accordance with applicable local law.

b) In the pre-enrollment process
If you enter the pre-enrollment process or apply for receiving news letters or similar communication (hereinafter: the “pre-enrolment”), you provide us with the following information:
- contact details including name, surname and email,
- personal details including gender, place of birth and date of birth, and
- your sign in location data.
You may also provide us with the following information:
- level of education data and data about your personal schooling experience,
- data about your relationship with your family,
- data about your health in childhood.
Information provided in the pre-enrolment stage are aimed mostly to provide you with the information of the current and potential Services, to give you your Success Profile, to provide you with the newsletters and similar marketing material and to provide you with information to the services in products in the field of personal development, vitality and beauty.
2.1.2 Why and how do we use your personal data?
a) To provide Services and the features of the website
We use your information to deliver our Services. When you use our website or app, we will use your personal data (including, but not limited to, the first and last name, e-mail address, gender, place and date of birth, sign-in location, level of education data, schooling experience, data about your relationship with my family and data about my health in childhood) in order to provide any of Services available on the website, app or otherwise. For example, with respect to Pre-Enrolment we will use your information to create your personal Success Profile. In the Pre-Enrolment process we may also use your basic information in the links available for others, such as your user name on a special moving screen.

b) To communicate information about our latest Services, events and for other promotional and marketing purposes
We may also use your information to send you marketing communications and news concerning ZeeQuest’s latest Services, events and other promotions, including the advertising of products or services of our trusted partners, with the aim of communicating information in relation to the services and products in the field of personally development, vitality and beauty. You can opt-out at any time after you have given your consent.
We may display advertising on our website and partner with third parties to manage advertising on other websites for our Services. We may also partner with third parties, including business partners, advertising networks, and other advertising service providers, who gather information about you on our website and other sites to provide you with advertisements on the website and elsewhere online based on your browsing history and tailored to your interests, preferences, and characteristics. Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

c) To operate, improve and maintain our business and Services
We may use the personal data you provide to us to operate our business. For example, when you make a purchase, we use that information for accounting, audits and other internal functions.
We may use your personal information to make improvements to our Services, for example we may use personal data about how you use our Services to enhance your user experience. We also use your information to ensure our Services are working as intended, such as tracking outages or troubleshooting issues that you report to us.
d) For profiling
In the course of our Services and pre-enrolment, we may analyze your information to build individual profiles. These profiles will be used to predict future interests and display targeted (online) advertisement. The aim is to provide you with offers that are relevant and interesting for you.
e) To measure performance
We may use data for analytics and measurement to understand how our Services are used. For example, we analyze data about your visits to our site, app or otherwise to do things like optimize product design. And we also use data about the ads you interact with to help advertisers understand the performance of their ad campaigns.
f) To set a direct communication with you
We may use information we collect, like your email address, to interact with you directly. For example, we may send you a notification if we detect suspicious activity, like an attempt to pay for our Services from an unusual location or credit card.
g) To protect our or others rights, property or safety
We may also use your personal data about how you use our site and app to prevent or detect fraud, abuse, illegal use, violations of our terms of use, and to comply with court orders, governmental requests or applicable law. In individual cases, data may be processed to safeguard or defend legal claims on the basis of our legitimate interests.
h) Develop new services
We may use the information we collect in existing services to help us develop new ones.
i) Provide personalized services, including content and adds
We may use the information we collect to customize our Services for you, including providing recommendations, personalized content, and customized search results. We may also show you personalized ads based on your interests.
j) Other purposes
We may combine the information we collect among our Services and across your devices for the purposes described above. We may use information collected through our website to respond to specific requests for information about our service and other inquiries. We may also use your information to inform you about other services that might be of interest to you and to gather feedback from you on our site, through email or other method. We may provide your information to trusted partners who work on behalf of or with us under confidentiality agreements. These companies may use your personal information to help ZeeQuest to provide the Services or to upgrade the Services or to provide you other information in the field of personal development, vitality and beauty. They may also assist us in communicating with you about the service and offers from us and our marketing partners, where you have given us the appropriate permissions as required by applicable law. ZeeQuest may also share your personal information with its existing and possible affiliates in order to provide or improve the service. They may also combine it with other information to provide and improve our Services. We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.

You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

2.1.3 European requirements
If European Union (EU) data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to request access to, update, remove, and restrict the processing of your information. You also have the right to object to the processing of your information or export your information to another service. Please note that a more detailed description of the rights that belong to EEA residents can be found in the Attachment A.

We process your information for the purposes described in this policy, based on the following legal grounds:

a) General
The specified data processing for each Service is necessary to provide a service used by you in fulfilment of a contract (performance of a contract with you or in order to take steps at your request prior to entering into a contract (Art. 6, para. 1, sub-para. 1b) GDPR). In individual cases, data may be processed to safeguard or defend legal claims on the basis of our legitimate interests (Art. 6, para. 1, sub-para. 1f) GDPR.
b) With your consent
We ask for your agreement to process your information for specific purpose and you have the right to withdraw your consent at any time.
c) Legitimate interest
We process your information for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:
providing, maintaining, and improving Services to meet the needs of our users;
developing new products and features that are useful for our users;
understanding how people use Services to ensure and improve the performance of Services;
customizing Services;
to provide you with a better user experience;
marketing and advertising to inform users about our Services and products and services in the field of personal development, vitality and beauty;
providing advertising to make many of Services freely available for users;
detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with Services;
protecting against harm to the rights, property or safety of ZeeQuest, our users, or the public as required or permitted by law;
performing research and analysis that improves Services for our users;
fulfilling obligations to our partners like developers, rights holders, sellers, re-sellers, distribution providers and other partners (such as marketing);
enforcing legal claims, including investigations of potential violations.
d) Services
We process your data to provide a service you’ve asked for under a contract.
e) Complying with legal obligations
We will process your data when we have a legal obligation to do so, for example, if we are responding to legal process or any enforceable governmental request.
2.1.4 Sharing your information
We may share you information in compliance with applicable law and for the purposes as stipulated above and especially in the following cases:
a) With your consent
We process your data based on your consent. For example, we will get your permission to store, process and dispose your personal data for advertising and marketing purposes with the aim of communicating information in relation to the services in products in the field of personally development, vitality and beauty.
b) For external processing
We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer support. We may also share your information with administrators and resellers who manage your account and with other persons in the ZeeQuest subscription structure who may have access to your account.
c) For legal reasons
We will share personal information outside of ZeeQuest if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:
meet any applicable law, regulation, legal process, or enforceable governmental request;
enforce applicable terms of service, including investigation of potential violations;
detect, prevent, or otherwise address fraud, security, or technical issues;
protect against harm to the rights, property or safety of ZeeQuest, our users, or the public as required or permitted by law.
2.1.4 How long will your data be stored?
We store your data as long as required to provide Services to you or we have a legitimate interest in continuing to store them, particularly to correct faults or to optimize Services. We only store the data that we need for the relevant purpose, or we create an alias or anonymize the data processed beyond what we require for the provision of Services to the extent possible.

Under certain circumstances, your data may also need to be stored longer, e.g. if a so-called legal hold or litigation hold is ordered in connection with official or judicial proceedings (i.e. a prohibition against deleting the data for the duration of the proceedings).

3. Truthfulness of the information entered

The customer is responsible for the truthfulness of the information entered in the user’s profile in our online store and accepts material and criminal liability in the event of misrepresentation of information or its abuse. The customer is also responsible to have a legitimate title for the content created, uploaded, or receive from others when using website or Services.

4. Security

We take reasonable steps to ensure that the personal information we collect about you remains accurate, timely and secure. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure and while we strive to protect your personal information, we cannot guarantee or warrant its complete security.

5. Data transfers
We may maintain servers around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we will try to apply the same protections described in this Privacy Policy. We will also try to ensure to comply with certain legal frameworks relating to the transfer of data, such as the EU-US and Swiss-US Privacy Shield Frameworks.
When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
6. Cookies and tracking
We use cookies, web beacons and other similar technologies for various purposes, including to analyze trends, administer the website, track user’s movements around the website and to gather demographic information about our user base as a whole. Cookies are small pieces of information that are stored on computer hard drives. A cookie enables the entity that put the cookie on your device to recognize it across different websites, services, devices, and browsing sessions. For example, we may use cookies to recognize you when you return to the websites in order to provide you with a better user experience. We may allow third parties to use cookies on the websites but we do not control the use or contents of third party cookies. Web browsers often allow you to configure the browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. If you elect to reject cookies, please note that you may not be able to take full advantage of the features and functions of the Sites. Web beacons and similar technologies are small bits of code, which are embedded in web pages, advertisements, and e-mails, that communicate with third parties. Web browsers may allow you to send “Do Not Track” requests. We do not currently take actions to respond to Do Not Track signals because there is no current industry standard concerning what, if anything, websites should do when they receive such signals. We continue to review new technologies and may adopt a standard if and when one is created.
7. Dispute resolution
ZeeQuest does not commit to nor is it obliged to participate in the alternative dispute resolution for consumer disputes in front of a consumer dispute resolution entity.
8. Whom can I contact if I have questions?
If you have any data protection concerns, you can contact our data protection office:
- Phone No.: 833-LUV-VITA

- E-mail: info@zeequest.com

Attachment A:

1. Rights of individuals

If you are a resident of the European Economic Area (“EEA”), you may have all the rights as described below.

1.1 What rights do you have?

As an affected person, you generally have the following data protection rights:

a) Information

You have the right to receive information about the data stored about you at ZeeQuest as well as the scope of the data that is processed and shared, and to obtain a copy of your personal data that we have on file.

b) Correction

You have the right to request immediate correction of information related to you that is incorrect as well as completion of incomplete personal data that ZeeQuest has on file for you.

c) Deletion

You have the right to request immediate deletion of the personal data on file for you at ZeeQuest if the statutory requirements for doing so have been met.
This is the case in particular if:
your personal data are no longer needed for the purposes for which they were collected;
your consent formed the sole legal basis for processing the data and you have revoked this consent;
you object to processing for personal reasons on the legal basis of a weighing of interests and we cannot prove that there are overriding legitimate interests in favor of the processing;
your personal data have been unlawfully processed; or
your personal data must be deleted in order to comply with statutory requirements.

If we have incorrectly disclosed your data to third parties, we will inform such third parties about the deletion if this is required by law.

Please note that your right to deletion is subject to restrictions. For example, we must or may not delete any data that we are required to retain on the basis of statutory retention periods. Data that we need to assert, exercise or defend legal claims is also exempt from your right to deletion.

d) Limitation of processing

Under certain conditions you have the right to request that the processing of your personal data be limited (i.e. the designation of stored personal data with the aim of limiting future processing of it). These conditions are:
The accuracy of the personal data is disputed and ZeeQuest must review the accuracy of the personal data;
The processing is unlawful, but you do not want the personal data deleted and instead request that the use of the personal data be limited;
ZeeQuest no longer needs your personal data for the purpose of processing, but you need the data to assert, exercise or defend legal claims;
You have objected to the processing of your personal data, but it is still not clear whether the legitimate interests of ZeeQuest outweigh your interests.

If the processing is limited, your data will be designated accordingly and will – apart from being stored – only be processed with your consent or to assert, exercise or defend legal claims or to protect the rights of natural persons or legal entities.

e) Data transferability

If we process the personal data that you have provided us on the basis of your consent or a contract (including your employment contract) in an automated manner, you have the right to receive the data in a structured, commonly used and machine-readable format, and to transmit these data to another data controller without being prevented from doing so by ZeeQuest. You also have the right to request that the personal data be transmitted directly from ZeeQuest to another data controller if this is technically feasible and provided that doing so does not affect the rights and freedoms of other persons.

f) Objection

If we process your personal data on the basis of legitimate interests or in the public interest, you have the right to object to the processing of your data for personal reasons. You also have an unlimited right to object if we process your data for our direct advertising.

g) Revocation of consent

If you have granted consent for the processing of your personal data, you can revoke this consent at any time. Note that such revocation only applies to future processing. Any processing carried out before the revocation is not affected.

1.2 More information about your right to object

a) The right to object for personal reasons

You have the right to object to the processing of your personal data for reasons arising from your particular situation. The prerequisite for this is that the data processing is carried out in the public interest or on the basis of a weighing of interests. This also applies for profiling.

If we process your personal data on the basis of a weighing of interests, we generally assume that there are compelling legitimate reasons for doing so, but we will of course review each individual case.

If we receive an objection, we will no longer process your personal data, unless:
we can demonstrate compelling legitimate reasons for processing these data that outweigh your interests, rights and freedoms; or
your personal data help us to assert, exercise or defend legal claims.

b) Object to the processing of your data for our direct advertising

If we process your personal data for direct advertising purposes, you have the right to object to the processing of your personal data for such purposes at any time; this also applies for profiling, if the profiling is connected with such direct advertising.

If you object to the processing of your personal data for the purpose of direct advertising, we will no longer process your personal data for this purpose.

c) Exercising the right to object
The objection does not require the use of a form; it should be sent to the address specified in this data protection notice.

2. Will your data be transmitted to a third country?

Data may be transmitted to third countries (i.e. countries that are not members of the European Union or the European Economic Area) if doing is required for the provision of services to you, if it is required by law or you have given us your consent. In addition, we may also forward your personal data to processors in third countries.

Please note that not all third countries have a level of data protection recognized as adequate by the European Commission. If data is transmitted to third countries where the level of data protection is not adequate, we will try to ensure that the recipient either has an adequate level of data protection (e.g. through self-certification by the recipient as part of the EU-US Privacy Shield, or the agreement of the European Union’s so-called EU standard contractual clauses with the recipient) or the express consent of our users.

You can obtain from us a copy of the specifically applicable or agreed rules ensuring an adequate level of data protection.

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