Effective Date: June 10, 2022
Off Topic, Inc., d/b/a Zette (“we” or “Zette”) is committed to earning and maintaining consumer trust. We believe that privacy is a crucial element of such commitment, and have therefore designed our Services with privacy in mind.
Who are we?
Zette operates a business that enables users to “unlock” articles and other content on digital properties (for example, a news article that would otherwise be kept behind the paywall of a publisher’s website) so that users can access, read, and otherwise consume such articles and content.
Our Services are designed to enable users to “unlock” articles and other content on websites and other digital properties that utilize our Services (each owner and/or operator of such a website or digital property, a “Publisher”) in order to access, read, share, and otherwise consume such articles and content.
Use of our Services is also subject to the Zette Terms of Service, a current copy of which is available here and which may be updated from time to time.
Information We Collect Directly from Users
We collect an individual’s name, email address, phone number, and postal address when that individual registers for our Services. We use such names, email addresses, and other information for our operational and commercial purposes, including (i) to provide and improve our Services and (ii) for marketing and/or communications, including to provide updates about our Services.
We also collect and/or receive an individual’s demographic information (such as age, gender, education, income, and household status (e.g., number of children)), geographic information, and/or interest information (“Demographic and Interest Information”) when an individual registers for our Services or otherwise provides that information directly to Zette (Demographic and Interest Information about our “Registered Users”, collectively with the names, email addresses, and other information of our Registered Users collected during the registration process or as subsequently updated or provided by Registered Users, “Registration Data”). We may use Registration Data to provide and improve our Services, including for research, reporting, and analytics purposes in connection with our Services.
Information We Collect via the Zette Extension
We collect users’ online activity information when they use the Zette Extension, including, but not limited to, information regarding interactions with websites, applications, and content (collectively, “Extension Data”). We may use Extension Data to provide and improve the Zette Extension (to the extent necessary for the user-facing features thereof), including for functionality, performance, validation/authentication (including fraud detection and prevention) and security purposes and for research, reporting, and analytics purposes. For example, we may use Extension Data to determine what types of websites, applications, and/or content a user may be interested in and how that individual and other individuals use the Zette Extension and interact with the websites, applications, and content of our Publisher clients (collectively, “Publisher Sites”). Extension Data includes:
Additional Information We Collect on the Zette Site
In addition to Registration Data, we may collect the following information on the Zette Site:
We use Requesting Information to provide the requested materials and information, and for research, reporting, analytics, and other operational purposes.
Information We Receive from Third Parties
Zette Activity Data
When you view and interact with the Zette Site, and/or with third-party websites, apps, and other digital properties on which we may advertise (collectively, “Advertising Sites”; together with the Zette Site, “Zette Activity Sites”), we and/or our third-party vendors may collect and/or use (i) information about the interactions that you have with the Zette Site and with our advertising on the Advertising Sites, (ii) information about the Zette Activity Sites, and (iii) information that identifies your browser(s) and device(s) (collectively, “Zette Activity Data”). Zette Activity Data includes “Online Technical and Activity Information”, such as:
These technical identifiers can be used to identify an individual’s browser, mobile advertising environment, and/or device, and typically include:
Additional Technical Information
Our third-party vendors may use Online Technical and Activity Information, either by itself or together with Account Data, other Zette Activity Data, and/or other data we have collected or received (but not Extension Data), in order to help us make our advertising more useful and relevant, as well as to provide us with services designed to help us understand and improve the effectiveness of that advertising. We call this type of advertising “Tailored Advertising”, and it may also be called “Personalized Advertising”, “Interest-Based Advertising” or “Online Behavioral Advertising”. Our advertising may be delivered across computers, smartphones, and other devices, and our third-party vendors may associate information relating to browsers, environments, and/or devices that they reasonably believe belong to the same user in order to help us provide more useful and relevant advertising regardless of browser, environment, or device.
Our third-party vendors, including Google Analytics, may also use Online Technical and Activity Information to help us understand and improve the effectiveness, performance, content, and security of our Site and Services, and for administrative and other security purposes. To learn more about Google’s use of information collected on our Site through Google Analytics, please visit www.google.com/policies/privacy/partners/.
Third-Party Payment Processors, Financial Information, and Payment “Tokens”
We use one or more third-party payment processors in connection with its products and services, including the Zette Extension. If you provide your financial account number (e.g., credit card number or debit card number) in connection with your registration and/or payment for our Services, please be aware that: (i) you are providing such financial account number to the applicable third-party payment processor disclosed at the time of collection (not to Zette); (ii) Zette does not access, store, or otherwise process such financial account number; and (iii) the processing of such financial account number and any and all other data required or otherwise collected by such third-party payment processor (e.g., name, email address, phone number, postal address, commercial information, etc.) is subject to the applicable terms, conditions, and policies of such third-party payment processor (each of which may be modified from time to time by such third-party payment processor). We may receive from, and provide to, the payment processor a randomly-generated payment “token” in connection with your registration and associated payments.
Types of Data
As part of our provision of our Services, we may provide Registration Data to Publishers. In addition, we may provide Registration Data to third-party service providers that agree to use it only to provide services to us.
We also may provide Extension Data to third-party service providers that agree to use it only to provide services to us.
We may provide Requesting Information to third-party service providers that agree to use it only to provide services to us.
Zette Activity Information
We allow third-party vendors that provide us with advertising (including Tailored Advertising) services and/or marketing services to collect Zette Activity Information, and we may also disclose additional information about you (e.g., Demographic and Interest Information), and information derived from it, to those third-party vendors.
Transfer of Data in the Event of Acquisition
In the event that another company acquires all or a majority of the assets of our business through a consolidation, merger, stock purchase, asset purchase, corporate reorganization, or other transaction, we reserve the right to transfer all information that is in our possession or under our control to the acquiring party.
Transfers Legally Required; Transfers in connection with Prohibited Activities or for Security Purposes
If and to the extent we reasonably believe we are obligated by law, rule, regulation, or legal process to disclose information to a third party (including law enforcement), then we will do so. In addition, we may disclose information to a third party (including an auditor or other service provider) in order to investigate, prevent, and/or take action regarding suspected or actual prohibited activities and/or in order to review, evaluate, and/or address the integrity and security of our Site and/or Services.
Data security is important to Zette, and we implement reasonable and appropriate technical and organizational measures to protect against unauthorized access to, unauthorized or unlawful use of, and unauthorized disclosure of data, with respect to both data at rest and data in transit. Please keep in mind, however, that despite our efforts to keep data secure, no storage or transmission of information can be guaranteed to be completely secure.
Zette Account Deletion
If you are a Zette Account holder, you may “delete” your Zette Account, either via your Zette Account itself or by emailing us at firstname.lastname@example.org and expressly indicating your election to delete your Zette Account.
If you “delete” your Zette account, we will erase, de-identify, or aggregate the personal information/personal data in that account, in compliance with our obligations under applicable laws, rules, and regulations. However, if permitted, we may retain personal information/personal data that we may need, including for security and fraud prevention, to identify and repair errors in our Services, and to comply with legal and regulatory obligations.
Please note that “deleting” your Zette Account is different from “canceling” your Subscription, as described in the Zette Terms of Service.
Email and Text Marketing
If you do not want us to contact you or send you information by email, you may unsubscribe from receiving our marketing and promotional emails by following the unsubscribe link in such marketing and promotional emails. If you do not want us to contact you or send you information by text, you may unsubscribe from receiving our text message marketing and promotions by replying STOP (or CANCEL, UNSUBSCRIBE, END, or QUIT, as applicable) to any such text message.
Neither our Services nor the Zette Site is developed for or directed at children (as defined by applicable law). We do not knowingly collect information from children on the Zette Site. If you believe a child has provided us with personal information, or that we may have otherwise collected or received personal information from a child, and you would like to have such information removed, please contact us.
California Consumer Privacy Act
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of “personal information” that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. To request a list of companies, if any, to which Zette has provided personal information for its own marketing purposes, please contact us by email to email@example.com, by phone (1-877-206-1267), or by mail to Off Topic, Inc. (d/b/a Zette), 2261 Market Street #4254, San Francisco, CA 94114, USA, Attn: Privacy. Please allow 30 days for a response.
Do Not Track
California law requires us to disclose how we respond to browser “Do Not Track” signals or other choice mechanisms relating to Tailored Advertising. We have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
Our Services are currently not intended for, and we currently do not offer the Zette Extension to, individuals in the European Economic Area, the United Kingdom, and/or Switzerland (each, a “European Jurisdiction”), although we may collect email addresses of European Jurisdiction data subjects and notify them about when we may offer the Zette Extension to them and provide other information (including marketing information) about our Services. We process such personal data based on the consent of such data subjects, and we believe that we are a “controller” (as defined by applicable law) of such personal data.
If you are a European Jurisdiction data subject, you have the following data protection rights under applicable law:
If you wish to exercise one of the above-mentioned rights, please send us your request via email to firstname.lastname@example.org.
You also have the right to complain to a data protection authority about our collection and use of your personal data. (If you are a resident of the European Economic Area, you can find your local supervisory authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.) We would, however, appreciate the opportunity to address your concerns before you engage a data protection authority, and would welcome you directing an inquiry first to us at email@example.com.
Third-Party Websites and Other Digital Properties