1. Data Controller
The data controller responsible for any collection, processing and use of personal data in each of the ZenMate services is
ZenGuard GmbH Ritterstr. 12-14 10969 Berlin, Germany
- ("we" or "us").
2. Personal Data
Our objective is that no personal data is collected, processed or permanently stored. Personal data is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. Your personal data will be collected or utilized only to the extent necessary to perform our services or if you have given us your consent beforehand. This applies, for instance, in the following cases:
- When you select a certain server to use ZenMate (see below point 2)
- When you contact our customer support (regarding product-related questions or information material etc.)
- Your subscription to newsletters and sending of newsletters and mailings
- Providing further information upon your request
- Your postings in forums, communities and through comment functions
Your personal data is collected, stored and used for the respective purpose only.
3. Registration and Use of ZenMate
If you choose ZenMate and install the Plugin "ZenMate" made available by us, we kindly ask you to provide us with a valid e-mail address. We will generate a password for you which will be sent to you via e-mail. Additional personal data is not needed. In order to prevent attacks against ZenMate your IP address will be saved temporarily on the server without being stored permanently or used for any other purposes.
When using ZenMate, you will have the possibility to select the access point or the server location you want to use in order to send an encrypted request to a website. By default, we display the server closest to you first. As a general rule, this is the fastest connection. However, if wished, you can choose another server. The decision is all yours.
When choosing an access point please note that only this server will process your IP address and request for the webpage you would like to access (the "Targeted Website"). All servers displayed, are located in another country, partly outside the European Union, with the consequence that different data protection laws apply to the respective server and the processed data. Therefore, you may consider which server to choose to use ZenMate and to which country therewith you want your IP address and site request to be transmitted and possibly used and saved temporarily in order to establish a connection.
Notwithstanding your decision: on the server you selected, your site request and your IP address are received via an encrypted connection. Your site request is then forwarded to the Targeted Website without your IP address, therefore, the website operator does not receive any information on who wants to gain access to the site. The content of the Targeted Website is then received by the server you selected and returned via encrypted connection. Thus, you always send and receive websites and its content via an encrypted connection using your selected ZenMate server without any direct contact to the website operator of the Targeted Website.
Which server you are currently using, can be found out easily any time by clicking on the ZenMate Plugin. In addition to that you can change the selected server location any time and therefore, modify your consent regarding the location where your IP address shall be encrypted.
If your account's data volume is limited we will measure the data you transfer and receive. However, we will not collect or store the content of the data. We will only record the mere volume of the data.
If your account's data volume is unlimited we will not even record the volume of the transmitted data.
4. Recording and Revocation of the consent
We do not store information regarding the location you selected for the encryption of your IP address when you chose the server location for the use of ZenMate, because data minimization is the intent and purpose of ZenMate. Therefore, your IP address is processed only temporarily and only for transmission to the Targeted Website without being stored permanently in the logfiles of the server selected by you.
In case you explicitly consent to the processing of personal data (e.g. for a newsletter), we are obligated to record the given (electronic) consent according to the German Telemedia Act (Telemediengesetz - TMG). If you wish, you can access the content of the (electronic) consent as well as revoke the consent with effect for the future at any time. In such case, we kindly ask you to contact us under our postal address or e-mail address provided in the imprint.
5. E-Mail Marketing according to § 7 Abs. 3 UWG
In accordance with section 7 para. 3 of the German Act Against Unfair Competition (Gesetz gegen unlauteren Wettbewerb - UWG) we are entitled to use the e-mail address provided by you for direct marketing for its own similar products.
In case you wish not to receive any such marketing e-mails any more, you can object to the respective use of your e-mail address any time by written notice to ZenGuard GmbH, Ritterstr. 12-14, 10969 Berlin or by e-mail to firstname.lastname@example.org with the subject "objection to e-mail marketing" without costs other than the submission costs based on the basic tariffs. When contacting us via e-mail in this matter please ensure that you use the e-mail address which you provided to us or name the e-mail address in question.
6. ZenMate App
The ZenMate App compresses the data you send, e.g. uploads and requests to websites. The compression changes the data in a mere technical way. The content of the data, for example the content of a document, will not be affected.
You can activate a filter in the app which blocks malware and ads if you wish. In this case the data transmitted to you will be screened for malware and ads and they will be blocked if detected.
7. Transfer of Data
We shall not transfer any personal data which we collected and stored based on your consent or on a statutory permission to a third party. In accordance with the law, however, we are obligated to provide information on inventory data (Bestandsdaten) as defined in section 14 TMG in some cases. This also applies to data on usage (Nutzungsdaten) as well as invoicing data (Abrechnungsdaten) as defined in section 15 TMG respectively.
8. Google Analytics
We analyse the behaviour of the users in order to further optimize our services. These evaluations are carried out pseudonymized as defined in section 15 para. 3 TMG, i.e. the name and other identification features will be substituted by an identifier with the purpose to prevent the identification of a specific individual or to render such identification substantially difficult.
For statistical analysis we use Google Analytics, a web analytics service provided by the Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). Google Analytics uses so-called "Cookies", text files that are stored on your computer and permit an analysis of your use of our website and online services.
The information about your use of our websites and online services generated by the Cookie is transmitted to a server controlled by Google in the USA and stored there. ZenGuard GmbH uses Google Analytics with the extension "anonymizeIp()", sending the IP addresses which are to be transmitted to Google to a server located in Europe first, where they are shortened and processed with the purpose to prevent individuals being identified. Google uses this information to analyze your use of ZenMate or the visit of our website, to create activity reports and to provide further services related to website or internet use. Google may also transfer this information to third parties if required by law, or so far as third parties process this information on Google's behalf. Under no circumstances Google will relate your IP address to other data of Google. If desired, you may refuse the installation of the Google Analytics Cookie by changing your browser settings; please note that in this case you may not be able to make full use of all functions provided by us. You may object to the collection and storage of data on behalf of Google Analytics at any time with effect for the future by using a Google Browser-Plugin.
9. Social Networks
If you activate one of the Facebook, Twitter and/or Google+ "like buttons" on our website by clicking on them, information will be transferred to the operator of the respective service in the USA. This information might be stored and utilized there. We do not know in which exact way these providers handle this data. We are not responsible for any storage or utilization of such data, including a possible placement of a cookie by the company which operates the respective social network. You can gather further information on the exact processing of the data, storage periods and purposes of the processing at the respective company. You can revoke your consent into the data transfer at any time, to take future effect, by deactivating the respective button.
10. Third Party Content
In case you leave our website by using a link to an external website, we indicate that you are about to connect to another internet provider. These marked links lead to content that is not stored on our own servers. As far as this is not already made clear in the text, we will for example mark the link with the comment external link.
Different privacy policies may apply to the websites to which the external links lead may contain. We, therefore, recommend to check these privacy policies by visiting the homepage of the respective online service or (if necessary) contact the controller of the respective website.
11. Your Rights, esp. Right to Object
You may assert your rights of information (section 34 German Federal Data Protection Act, Bundesdatenschutzgesetz - BDSG), of correction, of erasure or of blocking (section 35 BDSG) at any time. We would like to draw your attention to the fact that you may object the data processing for commercial purposes, market research or designing of demand-oriented services at any time. You can opt-out as outlined above or - after you have transmitted your data to us - assert your aforementioned rights by mail or e-mail. Please contact us under the mail or e-mail address provided in our imprint.
As of 3/19/2014