Privacy Policy

Kazoo Privacy Policy

Last updated: April 3, 2019

 

Introduction

Kazoo, Inc., a Delaware corporation, including its affiliates (collectively, “Kazoo,” “us,” or “we”), respects your privacy and is committed to protecting it. This Privacy Policy describes our privacy practices as it relates to websites operated by Kazoo that link to this Privacy Policy (collectively, the “Website”) and the applications, mobile applications, and services offered by Kazoo (collectively, the “Kazoo Services”).

Information Collected and How We Use It

On the Website

When expressing interest in learning more about our offerings, you may provide us with personal information such as your full name, email address, phone number, employer, and job title. When using our Website we may also collect information about how you use our Website using cookies, pixel tags, and other similar technologies (collectively, “Cookies”). To learn more about our use of Cookies, please see our Cookie Policy.

We use the information you provide us to send you information that may be of interest to you, such as information about our products and details on upcoming events. We may use the information we collect about your usage of the Website to improve our Website or personalize your experience on the Website.

On the Service

Your employer or an entity with which you have a relationship may subscribe to the Service (“Customer”). Kazoo may receive information about you from the Customer or collect information from you under the direction of the Customer. In relation to personal information provided by a Customer or collected under the direction of a Customer, Kazoo is the data processor and the Customer with is the data controller. If you are a user of the Service, you or Customer may provide us with information such as your name, a photo, email address, shipping address, job title, employment start date, birthday, and other information you may share in your profile or that you may post to the Service. Some users of the Service may also provide Kazoo with credit card or other payment information for billing purposes.

When using our Service, we may also collect information about your use of the Service using cookies, pixel tags, and other similar technologies (collectively, “Cookies”) for user authentication purposes, to understand how users use the Service, and to provide technical support. To learn more about cookies and your options to delete or disable them, please see our Cookie Policy.

We use the information you provide to Kazoo as a user of the Service solely for the purposes of providing the Service and fulfilling our obligations under the agreement we have with the Customer with which you have a relationship or as may otherwise be required by law. We may use the information collected about how you use the Service for purposes of improving the Service.

We will retain your information collected on the Service only as long as for as long as your account is active or as long as necessary to fulfill its obligations under its agreement with the Customer with which you have a relationship or other legal obligations.

Your Control Over Your Information

If at any time after providing personal information to Kazoo via the Website, you wish to update, change, or request deletion of such information, please contact us at [email protected] with a detailed request. If you wish to unsubscribe from communications, please follow the instructions shown in each email communication or contact us at [email protected].

If you are a user of the Service, you can update or change your information within the Service on your profile page. If you wish to remove or delete your information from the Service, please request such deletion from your administrator at the Customer with whom you have a relationship. We will work with your administrator to respond to such request within 30 days.

If you would like to download all of your personal information and information about your activity on the Service you can do so by going to your profile edit page and clicking the link to download a copy of your Kazoo data. Downloading such data will not remove it from the Service; please contact your administrator if you wish to remove your information from the Service.

Sharing of Information with Third Parties

We may utilize contractors, technology vendors, or other entities (“Agents”) to assist us in communications or in providing the Service. Agents will only have access to, and the right to use, information as necessary to carry out the services they are performing for Kazoo or as otherwise required by law.

If Kazoo should ever merge with or get acquired by another organization, file for bankruptcy, or sell our assets or capital stock, we may transfer information collected to a third party or the acquirer and such entity may continue to use the information in accordance with this Privacy Policy.

Security

We maintain industry-standard physical, technical, and administrative safeguards designed to protect the information collected from the risk of accidental or unlawful destruction or accidental loss, alteration or unauthorized disclosure or access.

Third-Party Websites and Services

This Privacy Policy applies only to Kazoo’s Website and Service. We may provide links to third-party websites on the Website or in other communications to you. Additionally, you may use third party application or services in conjunction with our Service. This Privacy Policy does not cover third party websites or services that are not under our control. We encourage you to carefully review the terms of use, privacy policies, and any other legal documents applicable to such third-party websites, applications, or services before using them.

International Transfers of Information

Information collected may be stored and processed in the United States or any other country in which Kazoo or its Agents maintain facilities. By using the Service, you consent to any such transfer of information outside of your country. European Union or Swiss individuals may refer to the Privacy Shield Statement below with regard to the transfer of their personal data.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time by posting a new version of this Privacy Policy on the Website. When we do change the Privacy Policy, we will also revise the “last updated” date at the top of the Privacy Policy and may notify you or post a message on the Website and/or through the Service. Your continued use of the Service constitutes your agreement to the current version of the Privacy Policy.

Contacting Kazoo

For questions, complaints, or comments regarding this Privacy Policy, please contact Legal by (i) emailing [email protected] or (ii) sending postal mail to: Kazoo, Inc., 206 East 9th Street Suite 1502, Austin, TX 78701.

Privacy Shield Statement

Kazoo, Inc. (“Kazoo”) complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Kazoo has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov> Privacy Shield.gov

This Privacy Shield Statement outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This Privacy Shield Statement applies to all personal information received by Kazoo whether in electronic, paper or verbal format.

Privacy Shield Definitions

“Personal Data” means information that (1) is trans­ferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosoph­ical beliefs, trade union membership or that concerns an individual’s health.

Privacy Shield Principles

Notice. Kazoo shall inform an individual of the purpose for which it collects and uses the Personal Data and the types of non-agent third parties to which Kazoo discloses or may disclose that Personal Data. Kazoo shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to Kazoo, or as soon as practicable thereafter, and in any event before Kazoo uses or discloses the Personal Data for a purpose other than for which it was originally collected. Kazoo may be required to disclose Personal Data in response to lawful request by public authorities, including to meet national security or law enforcement requirements.

Kazoo may collect your first and last name, shipping address, email address and Kazoo password, age, and credit card or other payment information that you choose to provide to Kazoo. We may ask you to provide Personal Information that will enable us to enhance your use of the Service, or for purposes such as facilitating correspondence with you or your company, registering your entitlement to access certain special features, or to complete transactions. We also collect information on the pages you access and other information you may volunteer, such as survey information. It is always your choice whether or not to provide that Personal Information to us and this is not a requirement for the use of the Service. Choice. Kazoo will offer individuals the opportunity to choose (opt out) whether their Personal Data is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, Kazoo will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the informa­tion for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Kazoo shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

Agents, technology vendors and/or contractors of Kazoo may have access to your Personal Data on a need to know basis for the purpose of performing services on behalf of Kazoo or providing or enabling elements of the Service. All such agents or contractors who have access to such information are required to keep the Information confidential and not use it for any other purpose than to carry out the services they are performing for Kazoo or as otherwise required by law.

Accountability for Onward Transfer. Prior to disclosing Personal Data to a non-agent third party, Kazoo shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Kazoo shall ensure that any third party for which Personal Data may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection. Kazoo may be held responsible in cases of onward transfers to third parties.

Data Security. Kazoo shall take reasonable steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. Kazoo has put in place appropriate physical, electronic and manage­rial procedures to safeguard and secure the Personal Data from loss, misuse, unauthorized access or disclosure, alteration or destruction. Kazoo cannot guarantee the security of Personal Data on or transmitted via the Internet.

Data Integrity and Purpose Limitation. Kazoo shall only process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Kazoo shall take reasonable steps to ensure that Personal Data is accurate, com­plete, current and reliable for its intended use.

Access and Recourse. Kazoo acknowledges the right of Swiss and/or EU individuals to access their personal data. Individuals shall be allowed access to their Personal Data and be permitted to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Enforcement and Liability. The Federal Trade Commission has jurisdiction with enforcement authority over Kazoo’s compliance with the Privacy Shield. In compliance with the Privacy Shield Principles, Kazoo commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact at:

Kazoo, Inc.
Attn: Legal
206 East 9th Street, Suite 1502
Austin, Texas 78701 USA
E-mail: [email protected]

Kazoo has committed to refer unresolved privacy complaints under the Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Kazoo, to file a complaint please visit

Please note that if your complaint is not resolved through any of the above channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Kazoo has further committed to cooperate with EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship. If your complaint is not satisfactorily addressed, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”), and for Swiss Data Subjects, the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work.  Kazoo agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel and the FDPIC. The services of EU DPAs and Swiss FDPIC are provided at no cost to you.

Amendments to Privacy Shield Statement

This Privacy Shield Statement may be amended from time to time consistent with the requirements of the Privacy Shield frameworks. We will post any revised statement on this website.