Last Revised: June 2, 2023
EZADA is committed to improving the lives of those with disabilities. Central to this mission is our commitment to transparency about the data we collect, how it is used, and with whom it is shared. Safeguarding the personal information of visitors to our website and websites using the EZADA products and services is extremely important to us.This Privacy Policy sets out the principles governing our use of Personal Information that we might obtain about you when you visit
EZADA’s website or visit another website that uses EZADA technology. This Privacy Policy also addresses the Personal Information that we might obtain from our Clients when they or their employees contact EZADA for the purposes discussed herein.For purposes of this Privacy Policy:
“Personal Information” means any information relating to an identified or identifiable natural person.
“Client” means someone who uses our Services on their website.
“Services” means EZADA’s products and services, including our technology that may be used on a Client’s website(s) or their web application(s). Services also include the use of our website.
“We”, “us”, “our” and “EZADA” means EZADA, Inc. and its other brands.In addition, to comply with privacy requirements in the European Union, European Economic Area, United Kingdom (collectively “Europe” or “European”) and California, we have provided additional details about our privacy practices as outlined below.
COLLECTION OF INFORMATION
When you use the Services, we may collect various categories of Personal Information. This includes information that you provide to us directly (such as manually entering the information or using your browser to help complete a form) as well as information that we collect automatically.Information You Provide Directly
Via our Website, EZADA Help Desk or Generally
When you use the Services, we collect information that you directly provide to us via the website and via any agreements that you complete with respect to the Services. This information may include, for example, your name, residence address, phone number, e-mail address, and other information, some of which is optional and some of which is required for us to complete your request.For example, when you interact with EZADA’s Help Desk function on our website or a website of one of our Clients, such as by using EZADA’s Visual Toolkit, we will collect information that you directly provide us and which is necessary to assist you with your query, such as your name, your comments/questions, and your e-mail address. You may also optionally provide your phone number and relevant information relating to any assistive technology that you might use in connection with the Services. Similarly, when you contact us for information, such as by completing the contact-us form at www.ezada.com/contact-us, we will collect information that you directly provide us, such as your name, job title, e-mail address, phone number, company/government agency name, and website URL. You may also optionally provide information regarding a referral source and any other information you choose to provide. As another example, if you request an accessibility analysis or request a demo, we may collect your name, job title, e-mail address, phone number, company/government agency name, and website URL.Information from External Sources
We may receive Personal Information from publicly available databases, joint marketing partners and event sponsors, our Clients, and social media platforms. With respect to Personal Information we receive from our Clients or third parties, we may be subject to agreements governing our use of the Personal Information, such as confidentiality agreements or data processing agreements.Information We Collect Automatically
When you use our website or our Client’s websites, we use functional cookies and similar technologies to collect data to recognize you and your device(s) to apply your personalized settings during your session and across different websites. We also collect information through cookies and similar technologies about your network and device, such as your proxy server, web browser, operating system, IP address, device identifiers, ISP, or your mobile carrier, so we can maintain the quality of our Services. We do not use cookies or similar technologies for browser “fingerprinting.”Cookies
Generally speaking, a computer cookie, or “cookie,” is a small file, often including unique identifiers that web servers send to browsers. These cookies then can be sent back to the server each time your browser requests a new page.
Your web browser uses the information stored in the cookie to make navigating the Internet easier, such as automatic login and other functions and preferences. Cookies come in many flavors. Functional cookies ensure that certain parts of websites work properly. By using functional cookies, we make it easier for you to visit our Website and use the Services. We only put functional cookies on our Clients’ websites. Analytical cookies are used to optimize our Services for our Clients and Users. Through the use of analytical cookies, we receive insight into the usage of our Services. By using our Services or website, you give us permission to place analytical cookies on your device.Other Technologies
We may use clear GIFs, pixel tags, and other such cookie-like technologies to track the activities of users of our Services and to compile statistics about the use of our Services and/or e-mail response rates.
Additionally, our Services are continuously evolving. We often introduce new features to our Services which may require the collection of new information. If we collect materially different Personal Information or materially change how we collect, use, or share your Personal Information, we will update this Privacy Policy as needed.
We Do NOT Collect Accessibility Data
We do NOT collect, use, or share Personal Information as it relates to a potential disability or other accessibility need.USE OF INFORMATION
How we use your Personal Information will depend on how you interact with EZADA, how we collected the Personal Information and the type of Personal Information. We may use the Personal Information detailed above for a variety of purposes, including: managing and improving our internal business operations, providing our Services to you, managing Client relationships and relationships with you, responding to your inquiries, enforcing our Terms of Service, personalizing the Services and your experience on our website, providing information regarding careers with us, and engaging in marketing activities, such as providing newsletters, publications, updates, and other information that we believe might be of interest to you.Sharing of Information
We do not sell, exchange, transfer, or give your Personal Information to any other company or individual except as follows:
We may share, on a limited basis, Personal Information with our service providers, suppliers, subcontractors, and similar third parties so that they can assist us in the maintenance of our website and provision of Services or our marketing of our Services to you (but not third-party Services). We may also share Personal Information with financial institutions in connection with invoicing and payments.
There is a possibility that EZADA will need to disclose some Personal Information about you when legally compelled by subpoena or other legal process. We may also share your Personal Information with third parties if we have a good faith belief that disclosure of Personal Information is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government agencies; (2) enforce our agreements, including for billing and collection purposes; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services; or (5) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ourselves, users of our Services, our Clients or others.
Marketing Activities
With respect to marketing activities, certain information that you provide to us, such as your name, job title, e-mail address, phone number, company/government agency name, and website URL, may be aggregated with other data in one or more contact lists. We may then use these contact lists to send you information regarding our Services such as via an automated mailing or emailing system and/or to send you surveys via an automated survey generation system. These contact lists may be integrated into our client relation management (CRM) system and/or our internal e-mail contact lists. We may also use this marketing data to produce and share insights about our Clients and users of our website or our Client’s websites. We may also use the data and its Personal Information to market directly to you via our website. Specifically, we may use your data to generate statistics about our website users and Clients’ website users, as well as their usage of our platform. In addition, if you don’t want to receive marketing emails from us you can “opt out” at any time by clicking the “unsubscribe” link at the bottom of any marketing email. Once you “opt out”, you will no longer receive any marketing emails from us. We may continue to email you regarding your service billing and support.We do not share your Personal Information with, or sell your Personal Information to, any advertisers or ad networks that might market non-EZADA Services.
Services Development
We may use Personal Information to conduct research and development in order to improve our Services. We anonymize this information to make it unidentifiable and then use it to provide users and Clients with a better, more personalized experience, as well as drive membership growth and engagement with our Services.ADDITIONAL INFORMATION RELEVANT TO PERSONAL INFORMATIONAccess to Information
You may access and update your Personal Information that we hold by sending a request to the e-mail address listed below under Contact Us.
Third Party Websites and Links
We may provide links to third-party websites, plug-ins, content, and applications that are not operated by us. This Privacy Policy does not apply to those third parties’ collection and use of your Personal Information. Be sure to review the legal notice and privacy policy of those third parties, such as social media sites, because the policies of those sites may be different from our Privacy Policy or Terms of Service.Information Security
We employ reasonable organizational, technical, and administrative safeguards to help protect your Personal Information against unauthorized access, improper use or disclosure, and unauthorized or unlawful destruction or accidental loss. Our security and privacy policies are periodically reviewed and enhanced and are designed to allow only authorized individuals to have access to the information you provide. Further, all of our employees and any third parties that process your Personal Information on our behalf are obligated to respect the confidentiality of your Personal Information. However, data transmitted over the Internet cannot be guaranteed to be completely secure from people who might attempt to evade our security measures, and we cannot guarantee that our safeguards will always protect your Personal Information against unauthorized access, improper use or disclosure, and unauthorized or unlawful destruction or accidental loss. Your email is a non-encrypted form of Internet communication, which may be accessed and viewed by other Internet users without your knowledge or permission while in transit to us. For that reason, in order to protect your privacy, please do not use email to communicate confidential information beyond that which is necessary for us to perform our Services or if you are not comfortable with the risk of exposure. Users and Clients are responsible for maintaining the secrecy of their own passwords. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised) or if you would like an alternative method of engaging with us, please immediately notify us by contacting us at privacy@ezada.com.
Retention of Personal Information
We retain Personal Information we collect for the duration needed to provide our services to you, and thereafter in accordance with our records retention policy and applicable data protection laws.
Change in Ownership or Sale of Company
Should EZADA decide to reorganize or divest part or all of our business or a line of our business, including our information databases and websites, through a merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we reserve the right to share your Personal Information with a third party. In such circumstances, we will seek written assurances that your Personal Information collected through the Services will be protected consistent with this Privacy Policy.Sensitive Information
To protect your privacy, we ask that you not send us, and you not disclose, any sensitive Personal Information. Examples of sensitive Personal Information that you should not disclose to us include:disability status;social security numbers;criminal background;personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs;trade-union membership;genetic data, biometric data processed solely to identify a human being;health-related data; ordata concerning a person’s sex life or sexual orientation.
Your Privacy Choices and Rights
You may contact us to update or correct your Personal Information and your preferences provided to us through the Services or opt out of receiving mailings or other communications in which you previously chose to participate. Different programs and services may offer different phone numbers, links, or preference managers that allow you to inform us of your updates and choices, including opting out of particular communications. You may also contact our Privacy Office for assistance at privacy@ezada.com if you have difficulty finding these tools or otherwise updating your data or preferences. We may need to retain certain Personal Information for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. We will endeavor to comply with your request as soon as reasonably practicable.If you no longer wish to receive promotional emails from us on a going-forward basis, you may opt out of receiving such emails by following the “unsubscribe” directions on the emails or by changing your preference settings.Our websites do not currently respond to web browser "do not track" signals or other mechanisms that provide a method to opt out of the collection of information across websites or other online services.
ADDITIONAL INFORMATION RELEVANT TO CERTAIN JURISDICTIONS
Residents of the European Economic Area
We only require the minimum amount of Personal Information that is necessary to fulfill the purpose of our interaction with you. Residents of the EEA have the following rights with respect to their Personal Information:the right to be informed of how your Personal Information is being used;the right to access to your Personal Information;the right to rectification of data discrepancies;the right to delete your Personal Information;the right to restrict processing of your data;the right to data portability;the right to object to processing; andthe right to avoid automated profiling.In the sections above, we describe the categories of Personal Information collected and explain various ways that we process your Personal Information. We rely on the following legal bases to process your Personal Information, as applicable:consent,performance of a contract between you and us,compliance with a legal obligation, orour legitimate interest to do so, balancing this interest against your interests and fundamental rights.Where our processing is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.We do not use automated decision-making, including profiling, to make decisions with legal or similarly significant effects.If you are in the EEA and you would like to contact us regarding your possible rights under the GDPR, please contact us at privacy@ezada.com.You can also submit a request at our Privacy Hotline at: (866) 541-0080.Additionally, residents of the EEA have the right to lodge a complaint with your local data protection authority if you believe that we have not complied with applicable data protection laws in the EEA.You are not required to provide your Personal Information to us. However, if you decline to do so, we may not be able to provide all or part of our Services to you.Finally, Personal Information we collect from and about you may be transferred outside of your country of residence, including to the U.S. and other countries that may not provide the same level of data protection as your country of residence. We will nonetheless process your Personal Information in accordance with this Privacy Policy and applicable privacy laws. When we receive or transfer Personal Information from or to our processors and third parties, we implement appropriate safeguards to facilitate such transfers where required by applicable law. For more information about and/or a copy of the safeguards we have implemented to facilitate cross-border transfers of Personal Information, please contact us at privacy@ezada.com.Privacy Notice for California Residents
This notice describes our practices regarding the collection, use, disclosure, and sale of Personal Information and provides instructions for submitting data privacy requests.
California Residents Under Age 18
If you are a resident of California under the age of 18 and a registered user of the Services, you may ask us to remove content or data that you have posted to the Services by contacting us at privacy@ezada.com.You can also submit a request at our Privacy Hotline at: (866) 541-0080.Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.
California Consumer Privacy Act Notice for California Residents
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their Personal Information, and of the rights and choices we offer California residents regarding our handling of their Personal Information. For purposes of this section of our Privacy Policy, “Personal Information” means information that identifies, relates to, or could reasonably be linked with you or your household.We provide the following details regarding the categories of Personal Information about you (excluding business-to-business data) that we may have collected or disclosed within the preceding 12 months:identifiers, such as name and government-issued identifier (e.g., Social Security number);Personal Information, as defined in the California safeguards law, such as contact and financial information;characteristics of protected classifications under California or federal law, such as age, gender, race, medical conditions, and marital status;commercial information, such as transaction information and purchase history;internet or other electronic network activity information, such as browsing history and interactions with our websites;geolocation data, such as device location;audio, electronic, visual, and similar information, such as call and video recordings;professional or employment-related information, such as work history and prior employer;education information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information; andinferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.We may collect this Personal Information directly from California residents, as well as from joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, people with whom you are connected on social media platforms, companies and other third parties that help us screen and onboard individuals for hiring purposes, and other third parties when they share the information with us.
We may have disclosed this Personal Information to our affiliates and trusted third parties, such as our service providers, for our business operational purposes. We may use this Personal Information to operate, manage, and maintain our business, to provide our Services, for our employment purposes, and to otherwise accomplish our business purposes and objectives. Our business purposes and objectives include, as examples:Developing, improving, repairing, and maintaining our Services; personalizing, advertising, and marketing our Services;Conducting research, analytics, and data analysis;Maintaining our facilities and infrastructure; undertaking quality and safety assurance measures;Conducting risk and security controls and monitoring;Detecting and preventing fraud;Performing identity verification;Performing accounting, audit, and other internal functions, such as internal investigations;Complying with law, legal process, and internal policies;Maintaining records; andExercising and defending legal claims.We have not sold Personal Information about California residents. For purposes of the CCPA, “sold” or “sale” means the disclosure of Personal Information to a third party for monetary or other valuable consideration.If you are a California resident who has provided us with your Personal Information during the creation of or during the course of establishing a business relationship that is primarily for personal, family, or household purposes, you may, once per calendar year, request information regarding our disclosure of certain categories of your Personal Information. Specifically, California residents may request that we:Disclose the sources, categories, and specific pieces of Personal Information we have collected about them and how that information is used, including the purpose;Disclose any “sales” of Personal Information (if any);Delete their Personal Information;Opt them out of “sales” of their Personal Information (if any); andProvide a copy of their Personal Information in a readily usable format that allows the information to be transmitted to others.California residents may not be discriminated against for exercising any of the rights described above. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your rights under the CCPA. We may ask you to provide additional information that will enable us to verify your identity. In some instances, we may decline to honor your request if an exception applies, such as when the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident. We will respond to your request consistent with applicable law.Children’s PrivacyOur Services are not directed to children under the age of 13. We do not knowingly collect Personal Information from children under the age of 13. If we receive Personal Information that we discover was provided by a child under the age of 13, we will promptly destroy such information, and this information will not be used for any purpose. If you believe that a person under 13 years of age has provided us with his or her personal information, please notify us so that we can take reasonable steps to remove the information from our database. If you would like to learn more about the Children’s Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission home page at http://www.ftc.gov.
Do-not-track Signals
Our Services do not respond to do-not-track signals. For more information about do-not-track signals, please see https://securiti.ai/what-is-do-not-track-dnt.
Revisions to our Privacy Policy
We reserve the right to revise this Privacy Policy or any part of it from time to time. Please review this Privacy Policy periodically for changes. If we make material changes, we will endeavor to provide notice ahead of such changes, such as by email or through a notice at our Website. You should check this page periodically for any changes.Contact UsIf you have any questions about this Privacy Policy or your possible rights, please contact us at: (866) 541-0080 or privacy@ezada.com.
