Zighra Inc. (“Zighra”, “We”, “Us”) has created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through the Zighra developer portal and related services (the “Developer Services”) as well as personal information we process on behalf of our clients ( “Clients”) who employ our artificial intelligence software. Zighra’s software development kit allows our Clients to integrate the Zighra solutions into their existing applications to allow them to monitor their customers’ (“Customers”) behavioural patterns in real-time for verification and identification purposes.

The privacy of our users is of great importance to us. By visiting our website located at www.zighra.com (the “Website”) or using the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

  1. WHAT DOES THIS PRIVACY POLICY COVER?

    This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals (“Personal Information”). This Privacy Policy does not apply to the practices of companies that we do not own or control, including practices of our Clients who employ Zighra’s SensifyID. Our Clients are responsible for maintaining their own privacy policies governing the collection, use and disclosure of Customer Personal Information. We do not knowingly collect or solicit Personal Information from anyone under the age of 18 or knowingly allow such persons to register for the Developer Services.

  2. COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA

    2.1. Zighra Account Information

    In order to use our Developer Services, users must have a valid Zighra account to log in to the Platform (“Account”). When you register for the Developer Services, Zighra collects your Account username and password in order to authenticate Your Account access and provide you with access to the Services. Zighra also collects the developer’s company name and contact information, namely email and telephone number.
    Zighra will use the contact information provided to notify users of important information that is relevant to the Developer Services. Despite your indicated e-mail preferences, we may send you notices of any updates to our Terms of Service or Privacy Policy.

    2.2. Customer Data Collected Through SensifyID

    Zighra’s clients have the option of using Zighra’s cloud services to store their Customer data that is collected through SensifyID. In order to provide the cloud storage services to our Clients, Zighra collects and processes Personal Information about end Customers from our Clients including, but not limited to, Customer behavioral trends and patterns, recording Customer’s physical interactions with the Customer’s device (swiping, tapping, which hand Customer uses), type of Customer device, and device usage patterns (“Customer Data”). This information is used by Clients to identify and authenticate Customers in order to prevent fraud. Zighra only collects this Personal Information to process it on behalf of Clients who use SensifyID.

    2.3. Usage Data

    Zighra may also collect certain information users of the Website and Developer Services, such as Internet addresses, time spent logged into the Developer Services and other usage data (“Usage Data”). This Usage Data is logged to help diagnose technical problems, and to administer our Website and Developer Services in order to constantly improve the quality of the Developer Services. Zighra uses the Usage Data that we collect to provide the Services and to continuously improve the Developer Services.

    2.4. Cookies

    Technologies such as cookies, beacons, scripts and tags are used by us and our third party partners. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the website, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.

    Standing alone, cookies do not identify you personally. They merely recognize your browser. Cookies come in two flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you’ve closed your browser or turned off your computer.

    Zighra uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Zighra to process online transactions and requests. Session cookies help us make sure you are who you say you are after you’ve logged in and are required in order to use the Service.

    Zighra uses persistent cookies that only Zighra can read and use, to identify the fact that you are a Zighra user. We are especially careful about the security and confidentiality of the information stored in persistent cookies. Users who disable their web browser’s ability to accept cookies will be able to browse our Website but may not be able to use all features of our Developer Services.

    Our third party partners may employ cookies, images, and scripts that help them better manage content on our site. We do not tie the information gathered to any Personal Information.

  3. SECURITY AND STORAGE

    3.1. Storage Location

    Zighra stores its data, including Personal Information, on servers located in Canada and the United States. By submitting any Personal Information or using the Developer Services, you agree to this transfer, storing or processing of your Personal Information in Canada and the U.S. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in those countries under lawful access regimes or court order.

    3.2. Security

    The security of your Personal Information is important to us. 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 as are reasonably necessary to carry out the stated purposes we have communicated to you.

    You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information for the Services to third parties password.

  4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

    4.1. Disclosure of Statistical Data

    Zighra may disclose aggregate statistical data to its business partners, who may use the data for business purposes. This information does not include any Personal Information or otherwise identify any individual Customers.

    4.2. Service Providers and Business Partners

    We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Developer Services and SensifyID. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our products and services, including the provision of maintenance services, database management, customer relationship management, Web analytics and general improvement of the Developer Services, and businesses who engage our Developer Services (to the extent provided for above).

    4.3. Business Transfers

    If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

    4.4. With Your Consent

    If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain your express consent as required under applicable privacy laws.

  5. RETENTION

    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. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

  6. ACCESS, CORRECTION AND ACCURACY

    You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

    We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

  7. CHANGES TO THIS PRIVACY POLICY

    We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website after such changes have been first posted.

  8. ADDITIONAL INFORMATION

    You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your Personal Information, if you have any questions, comments or suggestions about our Privacy Policy or practice, or if you find any errors in our Personal Information about you, please contact us at: feedback@zighra.com

Last Updated: January 11, 2018