Privacy Policy

Last Updated: May 5, 2023

Alphabet®, the entity behind Zembaly (“Zembaly”, “us”, “we”, “our”), is committed to protecting your privacy. We own and operate the website located at (“Website”), the Zembaly campaign management platform (the “Platform”) and provide the Zembaly services described on the Website (collectively with the Website and Platform, the “Services”).

This privacy policy (“Privacy Policy”) describes how we collect, store, use, and distribute information about identifiable individuals and information which can be used to identify an individual (“Personal Information”) via the Services. The Services are provided to Zembaly customers who have registered for a Zembaly account and paid for Platform access (“Customers”), and to all other users who may access, browse and use the Services (together with End Users, “Users”). The terms “you” and “your” refer to Customers and Users collectively.

We may change this Privacy Policy from time to time at our sole discretion. We encourage you to review this Privacy Policy each time you use the Services to see if the Privacy Policy has been changed, as indicated by the “Last Updated” date set out above. Zembaly may require you to provide consent to the updated Privacy Policy before further use of the Services is permitted.

  1. Privacy Practices of Customers. Customers may use the Services (including but not limited to Third-Party Integrations (as defined below)) to connect or interact with their own user or member base (each such user, an “End User”). This Privacy Policy will apply to any User Personal Information shared with us via the Services, including any End User Personal Information shared with us by a Customer. However, this Privacy Policy does not govern the privacy practices of Customers, including the collection, storage, use and disclosure of End User Personal Information by Customers. Customers may have their own privacy obligations that govern how they collect, store, use, and disclose an End User’s Personal Information, and as such we encourage End Users to contact the applicable Customer to find out more about the Customer’s privacy practices.
  2. Consent. By using the Services, you consent to the collection, use and disclosure of your Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be collected, stored, used, or disclosed for any other purpose without your consent. We will not actively collect Personal Information for the purpose of the sale or marketing of such Personal Information in a way that specifically identifies an individual. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using all or part of the Services.
  3. Information Provided to Us. We may collect Personal Information disclosed to us as follows:
    1. By Submitting Information via the Services. You may choose to provide us Personal Information when using the Services. For example, you may submit Personal Information on the Website to create a Platform account. Further, Users and End Users may submit Personal Information to us when accessing a Platform campaign landing page. The Personal Information we collect may include your name, email address, phone number, postal code, billing information, and any other Personal Information you choose to submit to us. We ask that you do not disclose sensitive Personal Information (including, without limitation, medical information) when you submit information to us.
    2. By Submitting Content via the Platform. Customers may submit and make available content via the Platform (“Content”). For example, Customers may submit URLs and images via the Platform when creating a Platform campaign loading page. Any Personal Information contained in Content will be subject to the terms of this Privacy Policy. We ask Customers not to disclose sensitive Personal Information (including, without limitation, medical information) in any Content they choose to submit to us.
    3. Third-Party Integrations. We may integrate with, rely on, or contain links to third-party platforms and services in order to provide the Services to you (“Third-Party Integrations”). We also offer Customers the option to enable certain Third-Party Integrations when using the Platform, some of which may allow Customers to share End User Personal Information with us via the applicable Third-Party Integration. Any Personal Information submitted to us via Third-Party Integrations that we can access will be subject to this Privacy Policy, but please note that such Personal Information will also be subject to the terms of the applicable Third-Party Integration.
    4. By Contacting Us. You may contact us via email. We also provide links to our social media accounts on our Website and you may choose to contact us via our social media accounts. Any Personal Information you submit to us via email or our social media accounts will be processed in accordance with this Privacy Policy, but please note that the applicable social media platform may have access to your Personal Information. Please consult the relevant social media platform’s privacy policy to see how they process your Personal Information.
    5. By Applying to Work with Us. If you would like to work with us and submit hiring materials to us, we collect any Personal Information in your hiring materials, such as your resume, cover letter, transcripts, or certifications. If you submit hiring materials to us, we ask you to only include information relevant to the position you’re applying for, and your employment history and education (including, without limitation, certifications and/or degrees obtained, previous work experience, relevant awards, etc).
  4. Information We Collect When You Use the Services.
    1. Cookies. When you use the Services, Zembaly may collect certain information through technologies such as cookies and other automatic data collection technologies (“Cookies”). We may use Cookies for authentication and to compile aggregate statistics about usage of the Services, such as how long Customers spend using the Services, and what parts or pages of the Website are viewed most often. This information is used to improve the content and operation of the Services. We may also use Cookies to promote the Services through marketing and advertising. These Cookies may be accessed or disclosed to third parties for the purpose of serving you relevant advertisements. You may opt out of Cookies or prevent third-party websites from accessing our Cookies by adjusting your privacy settings on your browser. However, opting out of Cookies may disable some features of the Services and may prevent us from providing you with the information and services you have requested.
    2. Device and Location Information. When you use the Services, Zembaly may collect information about your device (“Device Information”). Some Device Information, such as unique device identifiers, may constitute Personal Information. The Personal Information we collect from Device Information can depend on the individual settings of your device and software that you use to access the Services. We recommend checking the policies of your device manufacturer or software provider to learn what Device Information may be shared with Zembaly. Furthermore, certain aspects of the Services may require you to share Personal Information such as your geo-location data. You may disable the sharing of Device Information or geo-location, but doing so may disable some features of the Services and may prevent us from providing you with the information and services you have requested.
  5. How We Use Information We Collect. We use Personal Information in the following ways:
    1. To authenticate and onboard you, and provide you access to the Services;
    2. To provide, maintain, improve, and enhance the Services;
    3. To develop new Zembaly products, features, and services;
    4. To communicate with you, provide you with updates and other information relating to the Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
    5. For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you, where you have subscribed to receive them;
    6. To find and prevent fraud, and respond to trust and safety issues that may arise;
    7. For compliance purposes, as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
    8. For other purposes for which we provide notice at the time the Personal Information is collected.
  6. Who We Share Your Information With. We may share your Personal Information with third parties, such as selected business partners, suppliers, sub-contractors, and our affiliate company, Alphabet Creative, while performing our contractual obligations. These third parties may include web hosting partners, IT service providers, and advertisers.

    We have put in place contractual and other organizational safeguards with such third parties to protect your Personal Information from unauthorized uses and disclosures. Such third parties have limited access to Personal Information solely for the purposes described herein, and they will be subject to contractual restrictions prohibiting them from using such Personal Information for any other purpose.

    In addition, we may disclose your Personal Information to third parties:
    1. In connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or shares, including any due diligence exercise carried out in relation to the same, provided that the Personal Information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the Personal Information;
    2. If we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Users or Customers, or anyone else (including the rights or property of anyone else) that could be harmed by such activities; or
    3. If we believe in good faith that such disclosure is required by and in accordance with the law.
    Our servers and those of third parties who may receive your Personal Information may be located outside of Canada. Accordingly, your Personal Information may be available to foreign governments or their agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.
  7. Third Parties. The Services may contain links to third-party websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to the collection, storage, use, and disclosure of your Personal Information by such third parties.
  8. Data Retention and Deletion. We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. All retained Personal Information will remain subject to the terms of this Privacy Policy. You have the right to ask us to remove your Personal Information from our databases, and we will do so to the best of our ability, but it may not be possible to completely delete all of your Personal Information due to technological and legal constraints (for example, when your Personal Information pertains to another Customer or User).
  9. Access and Accuracy. You may access the Personal Information we hold about you to verify accuracy of your Personal Information, to have a general account of our uses of your Personal Information, and to correct your Personal Information as appropriate. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant Personal Information available to you (for example, where that Personal Information also pertains to another Customer or User). In such circumstances, we will provide reasons for the denial to you upon request. We will make every reasonable effort to keep your Personal Information accurate, and to respond to your in a timely manner.
  10. Security. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff and third parties as are reasonably necessary to carry out the stated purposes we have communicated to you.
  11. Contact Us. If you want to enforce any of your rights under this Privacy Policy or if you have any questions regarding this Privacy Policy or your Personal Information, please contact our Data Protection Officer per the information below:
    1. Via email: Email us at using the subject line “Re Privacy Policy”.
    2. Via mail: Mail us correspondence to 20 James Street, Unit 300, Ottawa, Ontario K2P 0T6, Canada