Privacy Policy

Last Amended: June, 2024

This Privacy Policy (“Privacy Policy”), describe how Zesty Tech Ltd., or its affiliates and subsidiaries (“Company” or “Zesty”) collect, use and disclose certain information, including Personal Data (as defined below) and the rights you have with regards to your information.

Zesty is the developer and operator of a cloud management and optimization software-as-a-service platform (“Platform” and collectively with the services therein shall be referred to as the “Services“). This Privacy Policy is an integral part of our Terms and conditions and governs the processing and transfer of information, directly or indirectly when you sign up for or use the Platform (“Customer”), when you apply for a job (“Candidate“) or merely when you browse our website available at: https://zesty.co/ (“Visitor” and “website” respectively).

Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms, unless otherwise stated herein, Visitors and Customer(s) shall be further, collectively and separately, referred to as “you“.

This Privacy Policy further explains how we safeguard your Personal Data and how you may exercise your rights related to your Personal Data, among others, and where applicable, as required according to the applicable data protection legislation.

Note you are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.

This Privacy Policy governs the use, processing and sharing of Personal Data that applies to all individuals world-wide, however, certain jurisdictions require that applicable disclosures will be provided in a certain way and format, and therefore additional notices will apply as follows:

Additional Information to California Residents: In the event you are a California resident– please also review our CCPA Privacy Notice to learn more about our privacy practices with respect to the California Consumer Privacy Act.

Additional Information to Colorado Residents: In the event you are a Colorado resident – please also review our CPA Notice to learn more about our privacy practices and your rights under the Colorado Privacy Act.

Additional Information to Connecticut Residents: In the event you are a Connecticut resident– please also review our CDPA Notice to learn more about your rights under the Connecticut Data Privacy Act.

Additional Information to Virginia Residents: In the event you are a Virginia resident– please also review our VCDPA Notice to learn more about our privacy practices and your rights under the Virginia Consumer Data Protection Act.

Additional Information to Utah Residents: In the event you are a Utah resident – please also review our UCPA Notice to learn more about your rights under the Utah Consumer Privacy Act.

(1) POLICY AMENDMENTS

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the website and the update date will be reflected in the “Last Amended” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

(2) CONTACT INFORMATION AND DATA CONTROLLER INFORMATION

Zesty, a company incorporated under the laws of the state of Israel, is the Controller (as such term is defined under the GDPR or equivalent privacy legislation).

For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact as follows:

DPO Contact Information:

By Mail: privacy@zesty.co

Zesty Tech Ltd.

20 Lincoln, Tel Aviv-Jaffa, Israel 6713412

Representative for data subjects in the EU and UK:

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/17277710417

(3) DATA PROCESSED BY ZESTY

We may collect two types of information from you, depending on your interaction with us.

The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, your action in the website or Services (such as session duration).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).

For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

The table below details the types of Personal Data we process, the purpose, lawful basis, and our processing operations:

Type of Data	Purposes of Processing	Legal Basis under the GDPR
VISITORS
Website Interaction and Marketing: When you interact with our website, we may collect your online identifiers, such as Internet Protocol (IP) address and Cookie ID, unique identifiers (“Online Identifiers”). Further, we will collect your behavior information, which is collected indirectly by our external marketing tools, or analytic tools. This information includes the referring URL (that is, the webpage directing you to our website, and other websites you visited in the session), your interests in our competitors, the web page you visited when you tapped/clicked on our ad, how you interact with our webpage, time, duration of use, pages you have viewed on our website (“Behavior Data”).	First, Online Identifiers and cookies are used, in particular to operate the website and enable its proper functionality, for example to automatically recognize you by the next time you enter the website or to confirm you are not are a real person. Second, the Online Identifiers and the Behavior Data are indirectly processed by marketing and analytic tools, for analytic and remarketing purposes. We process this data to understand how visitors use our website and to measure effectiveness of some ads we use in order to track conversions, build targeted audience, and remarket our Services to people who have taken some action on the website.	Strictly necessary cookies which are required for the proper and basic operation of the website will be processed in our legitimate interest. Other cookies, including any targeting and marketing cookies, will be processed based on your consent which we will obtain through our cookie notice and consent management. You may withdraw consent at any time by using the cookie preference settings available through the website, or by managing opt-out through your browser or device.
Contact Information: In the event you contact us with any inquiries, either through an online form available on the website (i.e., the contact us and support pages, the DSR form, etc.), or by sending us an email or by any other means, you will be requested to provide us certain information such as your name, telephone number, company name, email address (“Contact Information”).	We will use your Contact Information solely for the purpose of responding to your inquiries. The correspondence and its contents with you may be processed and stored by us in order to improve our customer services and in the event we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).	We process Contact Information subject to our legitimate interest.
Additional features: In the event you choose to provide feedback, post on our website or social media pages, participate in our webinars or events we host, you may be required to provide us with certain additional information.	We will use this information for the purpose of providing you with the services that you requested.	We process this information subject to our legitimate interest.
CUSTOMERS
Customer Account: In order to use our Services, you will be required to register and open an account or we will designate you with an account based on the information you provided us. During the registration process you will be requested to provide us with certain information such as your name, company name, email address, and other similar contact information, and you will be able to create a user name and password.	We use this information to create your account, authentication, provide account management (including billing and invoices), support and to provide the Services. In addition, we use this information for direct marketing purposes, meaning, as a Customer we may send you marketing related communications (by email or other contact details you have provided), materials and content regarding the Services you are currently using or any services we may offer in the future to keep you up to date, and for example, offers and content such as software updates, new capabilities and features, surveys, etc.	We process this information for the purpose of performing our contract with you. Processing of this information for direct marketing purposes is made subject to our legitimate interest. You can opt-out at any time using the “unsubscribe” option within the body of the message. Please note that if you choose to unsubscribe from our direct marketing, we will still retain your contact details and send you service-related emails, such as invoices.
Customer Support: When you contact us for customer support, we will process your Contact Information.	We will use the Contact Information to provide the customer support needed. We will retain such correspondence for as long as needed, and to evidence the support was provided.	We process such information to provide the support services and fulfill the contractual obligations.
Booking a Demo: In the event you choose to book a free demo you will be requested provide us with your name and company email address.	We will use this information for the purpose of providing you with the information or Services that you have requested.	We process this information for the purpose of performing our contract with you.
Payment Details: We use NetSuite as our payment processor pursuant to NetSuite Privacy Policy (“Payment Information”).	To process your payment and provide you with the service you purchased.	Processing is necessary for the performance of a contract with you.
Usage Data: When you use the Platform, information regarding such use is automatically generated and collected, which may include the click stream within the Platform, the use of the Services (i.e., accessed or used by Customer) and the time spent on those pages or features, crash data and analytics, etc. We record how you interact with our Service. We log crashes, interaction with the Services, how often you use the Service, how long you are on the Service, your purchases, etc.	We use this information to help us to understand how you are using our Services, and how to better provide and improve our Services. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers, decide how to improve the Service based on the results obtained from this processing.	We process this information subject to our legitimate interest.
Survey and Feedback: We may ask you to provide feedback on our Services, including any alpha/beta services or free demo services. If you choose to address our request for such feedback or participate in our survey, we will collect your feedback and contact information such as your name, email address, etc.	We use this information to improve, revise and enhance our Service, as well as optimize and customize the Services.	We process such information subject to your consent. You may withdraw your consent at any time by contacting us the contact information provided herein.
CANDIDATES
Career: When you apply for a job at Zesty we will process your CV (and the information included therein), as well as additional information such as your contact information (name, email address and phone number), information regarding your education and skills, employment history, and your photo (to the extent provided by you). Further, where required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender, or any disability. In addition, we may collect further information from public and online sources, referees, and former employers and combine such data with your other data (collectively, “Recruitment Information”).	We will use your Recruitment Information to process your job application and for our internal recruitment management purposes, for further recruitment steps (e.g., interview), and to enable us to comply with corporate governance and legal and regulatory requirements. Following the completion of the recruitment process, we may further retain and store the Recruitment Information (including other interactions with us under such process) as part of our internal record keeping, including for legal defense from any future claim, as well as, where we find applicable and subject to applicable law requirements, to contact you in the future for other position we believe you qualify for. If you are hired, your Recruitment Information will be kept on our HR systems as part of your employment and our corporate management. We use Hi Bob which processes your Recruitment Information on our behalf subject to this data processing agreement.	We process Recruitment Information subject to our legitimate interest. In some cases, for example, where we will ask you to provide health related information or diversity and inclusion data, we will process such data based upon your consent. You may always withdraw consent at any time. We will retain your data for records keeping and future defense from legal claims under our legitimate interest, or if you have provided consent to contact you in the future. We use third party service provider for the purpose of managing job applications, currently we are using Comeet which processes your Recruitment Information on our behalf subject to this data processing agreement.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in Section 10 “DATA TRANSFER” below, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website and Platform, as detailed above.

Note however, we will not use your Personal Data for any purpose that is materially different from the purposes for which the information was originally collected as detailed in the table above or subsequently authorized by you or required by applicable law. You may contact us directly at: privacy@zesty.co, regarding our use or disclosure of your Personal Data.

(4) HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the website and Services, we may collect information as follows:

Automatically – we may use cookies (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our website.

Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through the Services, contact us communications, registration, etc.

Provided by Third Parties. – our third parties service providers which collect personal data on our behalf, such as content enrichment service providers.

(5) COOKIES & TRACKING TECHNOLOGIES

We use “cookies” (or similar tracking technologies) when you access the website or interact with the Services we offer. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, for statistical purposes, as well as for advertising purposes. You can find more information about our use of cookies, as well as change your settings and preferences, as detailed under our cookie declaration available on our website.

(6) SHARING PERSONAL DATA

We share your Personal Data with third parties, including our partners or service providers that help us provide our Services. You can find in the table below information about the categories of such third-party recipients.

Category of Recipient	Data That Will Be Shared	Purpose of Sharing
Service providers	All types of Personal Data	We employ other companies and individuals to perform functions on our behalf. Examples include: sending communications, processing payments, analyzing data, providing marketing and sales assistance (including advertising and event management), identifying errors and crashes, conducting customer relationship management, and providing training. These third-party service providers have access to Personal Data needed to perform their functions, but they are prohibited from using your Personal Data for any purposes other than providing us with requested services.
Zesty Tech Inc.	Contact Information, prospects information, leads, and customer success.	We may share certain information with our affiliated company, Zesty Tech Inc., for sales and marketing purposes.
Any acquirer of our business	All types of Personal Data	We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Legal and Law Enforcement	Subject to law enforcement authority request.	We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.

Note, we will not share your Personal Data with additional third parties or for purposes not detailed in the table above or subsequently authorized by you or required by applicable law. You may contact us directly at: privacy@zesty.co, regarding our use or disclosure of your Personal Data.

(7) YOUR PRIVACY CHOICES

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

In the table below you can review your rights depending on your interaction with us, how you can exercise them, and appeal a decision we take in this regard, any specification per geo-location or territory are available below the table:

RIGHT TO BE INFORMED, RIGHT TO KNOW	You have the right to confirm whether we collect Personal Data about you, if you wish to know if we collect Personal Data about you, please review this Privacy Policy.
ACCESS RIGHTS	You further have the right to know which Personal Data we specifically hold about you, and receive a copy of such or access it, if you wish to receive a copy of the Personal Data or Personal Information, please submit a Data Subject Request Form (“DSR“) available here.
RIGHT TO CORRECTION	You have the right to correct inaccuracies in your Personal Data, taking into account the nature and purposes of each processing activity. Please submit a DSR as available here.
RIGHT TO BE FORGOTTEN, RIGHT TO DELETION	In certain circumstances, you have the right to delete the Personal Data we hold about you. Please submit a DSR as available here.
RIGHT TO PORTABILITY	You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. If you wish to exercise this right, please submit our DSR as available here.
RIGHT TO OPT OUT UNDER THE EU, AND SPECIFICALLY IN THE US THE RIGHT TO OPT OUT FROM: (I) SELLING PERSONAL DATA; (II) RIGHT TO OPT OUT FROM TARGETED ADVERTISING; AND (III) RIGHT TO OPT OUT FROM PROFILING AND AUTOMATED DECISION MAKING	Direct Marketing: You have the right to opt-out from Direct Marketing, by unsubscribing through the email received. Cookies: When you no longer wish for cookies to track your behavior for analytic and marketing purpose, change your preferences through the cookie settings available through the website. Sale of Personal Data for targeted advertising, monetary gain or profiling, or Share or Sale of Personal Information for analytic or marketing: If and to the extent applicable, you have the right to opt out of the sale of your Personal Data, for the purposes of targeted advertising, sale to a third party for monetary gain, analytic, etc. as detailed under the DSR or through the cookie settings available here. Last, you are able to install privacy-controls in the browser’s settings to automatically signal the opt-out preference to all websites you visit (like the “Global Privacy Control”). We honor the Global Privacy Control, where applicable, subject to your jurisdiction, as a valid request to opt-out of the sharing of information linked to your browser. Note you may have the right to authorize another person acting on your behalf to opt out (including by technical tools and opt out signals).
RIGHT TO APPEAL OR COMPLAINT	If we decline to take action on your request, we shall so inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the EU you have the right to lodge a complaint with the supervisor authority or the Information Commissioner in the UK.
NON-DISCRIMINATION	Such discrimination may include denying a service, providing a different level or quality of service, or charging different prices. We do not discriminate our customers or users.

(8) DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.

Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges; or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

(9) SECURITY

At Zesty, security is our highest priority. We design our systems with your security and privacy in mind. We have implemented physical, technical, and administrative security measures for the Services that comply with applicable laws and industry standards which you can review here.

Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.

Please contact us at: privacy@zesty.co, if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

(10) DATA TRANSFER

We may store or process your Personal Data in the EU, the United States or in other countries. Thus, any information you provide us may be transferred to and processed in countries other than the country from which you accessed our Services. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer.

Specifically, when Personal Data collected within the EEA is transferred outside the EEA, to countries or frameworks which were not granted with an adequacy decision by the European Union, and therefore do not provide an adequate level of protection to your Personal Data while it is transferred to such third-country or under such framework, such transfer is subject to and made pursuant with the standard contractual clauses approved by the European Union. Additionally, following the withdrawal of the United Kingdom (UK) from the European Union on January 31, 2020, the UK is no longer considered to be a part of the EEA and therefore, if and where Personal Data collected within the United Kingdom is transferred outside the UK, to countries or frameworks which were not granted with an adequacy decision by the UK Information Commissioner Office (“ICO”) and therefore do not provide an adequate level of protection to your Personal Data while it is transferred to such third-country or under such framework, such transfer is subject to and made pursuant with the UK standard contractual clauses. Personal Data transferred from within the EU and the UK to Zesty Tech Inc., is subject to the EU-U.S. DPF Principles, as all detailed below under Section 11 “Data Privacy Framework”.

(11) DATA PRIVACY FRAMEWORK

Zesty Tech Inc. complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce.

The terms “Zesty”, “we” or “our” as used in this Section 11, shall mean and refer to Zesty Tech Inc.

Zesty has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of Personal Data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, the EU-U.S. DPF Principles shall govern. To learn more about the Data Privacy Framework program please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Zesty commits to resolve all EU-U.S. DPF related complaints about our collection and use of your Personal Data in accordance with the EU-U.S. DPF Principles. EU and UK individuals with inquiries or complaints regarding our handling of Personal Data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, should first contact the Company at: privacy@zesty.co. We will investigate and attempt to resolve any Data Privacy Framework-related complaints or disputes 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 further commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (“DPAs”) and the ICO with regard to unresolved complaints concerning our handling of Personal Data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Complaints may be submitted to the EU DPAs or the UK ICO, as appropriate, at no cost to you.

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”), and the FTC has jurisdiction over Zesty’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

With regard to onward transfers of Personal Data to third parties, Zesty is responsible for ensuring that these third parties comply with applicable data protection principles, including ensuring that the third parties do not process such Personal Data in a manner inconsistent with the EU-U.S. DPF Principles.

(12) CHILDREN

Our website and Services are not intended for use by children and we do not knowingly collect or maintain information about anyone under the age of 16. Please contact us at: privacy@zesty.co, if you have reason to believe that a child has shared any information with us.

(13) JURISDICTION-SPECIFIC NOTICES

A. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section applies to California residents only pursuant to the California Consumer Privacy Act of 2018 as amended by the CPRA (“CCPA”).

Please see the CCPA Privacy Notice here which discloses the categories of Personal Information collected, purpose of processing, source, categories of recipients with whom the Personal Information is shared with for a business purpose, whether the Personal Information is sold or shared, the retention period, and how to exercise your rights as a California resident.

B. ADDITIONAL NOTICE TO COLORADO RESIDENTS

Under the Colorado Privacy Act (“CPA”) if you are a resident of Colorado, acting as an individual or in the household context only (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your Personal Data are described below.

Under the Colorado Privacy Act (“CPA”), Zesty is required to provide a privacy notice that identifies the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 7 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@zesty.co and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

C. ADDITIONAL NOTICE TO CONNECTICUT RESIDENTS

This section applies to Connecticut residents acting only as an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity).

Under the Connecticut Data Privacy Act (“CDPA”), Zesty is required to provide you with a clear and accessible privacy notice that includes the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 7 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising.

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 days response period, together with the reason for the extension. If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@zesty.co and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

D. ADDITIONAL NOTICE TO VIRGINIA RESIDENTS

This section applies to Virginia residents acting only as an individual or household context (and not in an employment or commercial context).

The Virginia Consumer Data Protection Act (“VCDPA”) requires Zesty to disclose the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 7 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@zesty.co and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

E. ADDITIONAL NOTICE TO UTAH RESIDENTS

This section applies to Utah residents acting only as an individual or household context (and not in an employment or commercial context).

Under the Utah Consumer Privacy Act (“UCPA”), Zesty is required to provide you with a clear and accessible privacy notice that includes the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 7 to this Privacy Policy details and discloses your rights if and to the extent applicable under the UCPA.

We will respond to your request within 45 days after receipt of your request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, we will provide with the reasoning for our refusal.

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