Data Privacy Framework Statement

Zesty Tech Inc. (“Zesty”) is self-certified for compliance with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF (“UK Extension to the EU-U.S. DPF”) (collectively – “DPF Principles”), as set forth by the U.S. Department of Commerce.

If there is any conflict between the terms in this Data Privacy Framework Statement and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF Principles please visit https://www.dataprivacyframework.gov/. To view our certification, please visit https://www.dataprivacyframework.gov/list.

Zesty Tech Ltd provides cloud optimization services to its business customers. Zesty Tech Inc is a fully owned subsidiary of Zesty Tech Ltd (collectively “Zesty Group”), providing certain services to Zesty Tech Ltd. These services include, among others, marketing, sales and customer success management services. While providing these services, Zesty Tech Inc is acting as a data processor on behalf of Zesty Tech Ltd which serves as a data controller. Through these services, Zesty Tech Inc processes the following types of personal data of both EU and UK data subjects, which are representatives of Zesty Tech Ltd’s former and current customers, including of prospect customers:

  • Contact information such as name, email address, title and telephone number.
  • Location and address.
  • Correspondence records.
  • Personal Data drawn from social platforms.

Zesty may further process limited personal data related to customer’s end users, solely to the extent such was submitted by customers through the provisions of the aforesaid services.

The above-mentioned data is processed by Zesty Tech Inc for the following purposes:

  • Provide the services mentioned above to Zesty Tech Ltd.
  • Comply with legal and inter-corporate requirements and policies.

Personal data being processed by Zesty Tech Inc is very limited in scope, as most of its operations are conducted and provided by Zesty Tech Ltd. Personal data being processed by Zesty Tech Inc mostly relates to finance and sales as the company’s Chief of Revenue and sales teams operate from the US.

Our Privacy Policy available at: https://zesty.co/privacy-policy/  outlines the purposes and uses of personal data. If Zesty intends to process personal data for a purpose that differs significantly from the original purpose(s) for which it was collected, we will seek your consent and will not proceed without obtaining it.

For onward transfers of personal data to third parties, Zesty is responsible for ensuring that these third parties adhere to applicable data protection principles, including ensuring that the third parties do not process such personal data in a manner inconsistent with the DPF Principles.

In line with the DPF Principles, Zesty is committed to addressing all EU-U.S. DPF-related complaints regarding our collection and use of your personal data in accordance with the DPF Principles. EU and UK individuals with inquiries or complaints regarding our handling of personal data under the DPF Principles should first reach out to us at: privacy@zesty.co. We will investigate and strive to resolve any complaints or disputes related to the Data Privacy Framework within forty-five (45) days of receipt.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Zesty commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of personal data received in reliance on the DPF Principles.

Please note that if your complaint is not resolved through these methods above, a binding arbitration option may be available under limited circumstances. Additional information can be found here: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

Additionally, Zesty is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”), which oversees Zesty’s compliance with the DPF Principles. Under certain conditions, individuals may have the option to initiate binding arbitration for unresolved complaints concerning DPF compliance that other DPF mechanisms have not addressed. For further details, please see Annex I of the DPF Principles.

Notwithstanding the above, under certain circumstances, Zesty may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.