Zencity Technologies Ltd. (together with its affiliated companies – “Zencity“, “we“, “our” or “us“) makes great efforts in making sure that your personal data is kept safe and used properly and responsibly.
1. Sites Usage, Customer Relationship Management (CRM) & Prospect Data relating to visitors of our website, participants at our events, Customers, partners, and any prospective Customers, partners or candidates who visit or otherwise interact with any of our websites, online ads and content, emails or other communications under our control (“Sites“).
2. User Data relating to individuals who are employed or engaged by Zencity’s customers, such as municipalities or local councils (“Customer“) who use the Services (“User(s)“).
3. Data Collected on Behalf of Customers
3.1 Resident Data relating to individuals (“Residents“) who engage with municipal services such as resident requests submitted to city hotlines (e.g. 311 services), social-media activity involving the municipality or local council (e.g. posts, comments, interactions and tweets from different social media platforms such as Facebook, Twitter, Instagram and NextDoor);
3.2 Content Data relating to individuals referred to within Resident Data (for example, if a Resident posts about their mayor on social media, the information relating to the mayor) or local media reports (“Referred Individual(s)“); and
3.2 Survey Data relating to individuals who participate in surveys that we send on our own behalf or on behalf of our Customers.
- Data Collection
- Data Uses
- Data Location & Retention
- Data Sharing
- Cookies And Tracking Technologies
- Data Security
- Data Subject Rights
- Data Controller/Processor
- Additional Notices & Contact Details
You are not legally required to provide us with any personal data, and you are free to do so or not to do so. If you are a User who does not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please refrain from accessing, using or registering to our Services. If you have been registered to our Services, or if your personal data has been submitted to our Services by one of our Customers, we suggest that you contact your organizational account administrator with any questions or to let them know that you would not like to be registered by them to the Services.
1. Data Collection
We collect and process various types of personal data regarding Residents, Users, Customers, Prospective Customers and visitors to our Sites. Such data is collected and generated through interactions with us or with our Sites or Service, through automatic means, or directly from you, from other Users, from our Customers, or from other third parties (including social media platforms and our Service Providers, as defined below). Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as “personal data“):
1.1 Sites Usage, CRM & Prospect Data. We may collect and generate the following types of personal data concerning our website visitors, Customers, partners and prospective Customers (collectively, “Non-Services Related Data“).
1.1.1 Sites Usage Data – connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like device type, OS, device ID, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on our Sites and/or a user’s device;
1.1.2 Business Account Data – contact details, contractual and billing details relating to our Customers and partners, which may also contain the details of their internal points of contact who directly engage with Zencity on behalf of their organization (e.g. the account administrators, billing contacts and authorized signatories on behalf of the Customer or partner, as well as the needs and preferences of the Customer or partner, as identified to us or recognized via our engagement with them);
1.1.3 CRM and Prospective Customer Data – contact and business details, our communications with Customers and prospective Customers (correspondence, call and video recordings, call transcripts, and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement.
We collect the above Non-Services Related Data either automatically, through the data subject’s interaction with us or with our Sites or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.
1.2 User Data. Zencity collects data on Customer’s Users who use the Services.
1.2.1. Account Data- full name, email address, job title, municipality/local council name, telephone number, profile picture, demographic information such as location, post code and any content a User might upload to the Services.
1.2.2. Usage Information – connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, IP addresses, device and mobile app data (such as type, OS, device ID, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on the device.
1.3 Data Collected on Behalf of Customers. We process “Survey Data” as a “Data Processor”. For more information on this distinction see section 9 below.
1.3.1 Resident Data. Zencity collects or receives the following personal data relating to Residents who engage with municipal services on the following platforms:
- City hotline information (e.g. 311 reports) – full name, address and contact information such as mobile phone number and email address, demographic information such as location, contact details and details regarding the content of the report (location, subject matter and additional information provided by the Resident).
- Social media information – name, social media handle (which is later hashed), content uploaded to social media platform (e.g. posts, comments, interactions and tweets from social media platforms such as Facebook, Twitter, and Instagram, both if made publicly available on the relevant platform or if contained in a group to which Zencity is granted access), time- and date-stamps and other metadata relating to social media posts. At the direction of the applicable Customer, this may be stored in a fully anonymous manner, or it may remain linked to the original post.
1.3.2 Content Data. Zencity collects the following personal data relating to Referred Individuals from the following sources:
- City hotlines information (e.g. 311 reports), social media activity and community surveys – Name and other identifying information which is provided by Residents and contained in any Resident Data referred to in (i) above.
- Local media – Name and other identifying information contained in news publications and broadcast media (e.g. online news websites, public forums, etc.).
1.3.3. Survey Data. Zencity collects data by way of surveys sent to Residents on behalf of Customers, which includes the following personal data:
- Cookies and fingerprints – We collect cookie data and fingerprint data of respondents to surveys.
- Survey responses – We collect the answers to survey questions being asked. Note that this data is stored in an anonymous manner and is analyzed in an aggregate form for statistical purposes. Survey responses will not be linked to any identifying information.
- Email addresses – Survey respondents may choose to provide their email addresses so that we can send them additional surveys in the future, however the email addresses will not be linked to the survey responses.
When it comes to data concerning Residents or Referred Individuals, we make extensive efforts to minimize the personal data we collect, remove any personal data which we detect and determine we don’t need, and redact/hash/pseudonymized data that we analyze and share with Customers. For example, we do not display social media handles from data collected through social media. Similarly, when we process city hotline data, we do not collect the contact fields, such as email address or phone number. However, please note that in some cases we will collect personal data. For example, if the content of a message (as opposed to the information fields) sent to the city includes personal data, we are unable to detect or anonymize this information. That said, this personal data is not included in our analytics and, to the extent we process it, we do so solely on our Customer’s behalf and at its discretion as a data processor. For more information on the distinction between a data controller and a data processor please refer to section 9.
2. Data Uses
We use personal data as necessary for the following purposes and in reliance on the following legal bases:
Data processing instructions as provided by the Customer as the ‘data controller’.
|Resident Data, Content Data & User Data|
|Purpose||Legal basis for processing|
|Providing our Customers with our Services, including analysis and insights based on Residents’ feedback on various platforms.||Customer assumes the role of a ‘data controller’ and Zencity that of a ‘data processor’. As such the legal basis is established by the Customer.|
|To create aggregated data, anonymized or pseudonymized data and/or de-identified Data.||Data processing instructions as provided by the Customer as the ‘data controller’.|
|To comply with applicable laws and regulations.||Compliance with legal obligations|
|User, Sites, CRM & Prospect Data|
|Purpose||Legal basis for processing|
|To facilitate, operate, and provide our Service.|
|To authenticate the identity of our Users, and to allow them to access our Service.|
|To provide our visitors, Users and Customers with assistance and support.|
|To evaluate and develop new features, technologies, and improvements to the Service.|
|To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications.|
|To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences.|
|To contact our Site visitors, Users and Customers (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them.|
|To facilitate, sponsor and offer certain events, contests and promotions.||Depending on the event, either|
|To publish your feedback and submissions to our Sites, public forums and blogs.|
|To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.|
|To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose.|
|To comply with applicable laws and regulations.|
3. Data Location & Retention
3.1 Data Location: Your personal data may be maintained, processed and stored by us and our authorized Service Providers in multiple locations, including in Israel, the United States and Europe, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
Zencity Technologies Ltd. is headquartered in Israel, a jurisdiction which is recognized by the European Commission and the UK as offering an adequate level of protection for the personal data of UK and EEA residents. We transfer personal data from the EEA and the UK to Israel on this basis. For data transfers from the EEA or UK to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission and the UK. You can obtain a copy by contacting us at email@example.com.
3.2 Data Retention: We will retain your personal data for as long as it is reasonably necessary for us to maintain our relationship with You and provide our Customers with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from, or defend, any potential or actual disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our contractual terms and data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at firstname.lastname@example.org.
4. Data Sharing
4.1 Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement) and where such disclosure is necessary to comply with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; or (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our Services. Furthermore, amongst our Customers are municipalities and councils. Such entities may be required, due to local laws (e.g. freedom of information laws) to disclose certain information. Such requests may cover information held by us. If we receive such a request we will comply with our Customer’s instruction and applicable law.
4.2 Service Providers: We engage selected third-party companies and individuals to perform services complementary to our own. Such service providers provide hosting and server co-location services, communications and content delivery networks (“CDNs”), billing and payment processing services, data and cyber security services, fraud detection and prevention services, web and mobile analytics, e-mail, text messages and web/mobile notification distribution, monitoring and analytics services, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, call and session recording services, and our legal, financial and compliance advisors (collectively, “Service Providers“).
4.2.2 Our Service Providers are “data processors” in circumstances where we assume the role of “data controller”; and where we act as the “data processor” for our business Customer, the Service Provider is our “sub-processor” (as further described in Section 9 below).
4.4 Sharing Personal Data with our Customers: We may share a User’s personal data with the Customer who owns the account with which a User is associated, including data and communications, concerning the use of the Services or other interactions with us. In such cases, sharing this data means that the account’s administrator(s) or other individuals in the organization (e.g. the IT team) may access it on behalf of our Customer, and will be able to monitor and review data concerning your interaction with our Services, as well as access any personal data that you submitted to the Service.
4.5. Protecting Rights and Safety: We may share your personal data with others if we believe in good faith that this is necessary to protect the rights, property or personal safety of Zencity, any of our users, partners or Customers, or any members of the general public.
For the avoidance of doubt, we may share your personal data in additional manners, pursuant to your explicit approval, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
5. Cookies And Tracking Technologies
5.1 Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are “Session Cookies”. Some last for longer periods and called “Persistent Cookies”. We use both types.
5.2 We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Services. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.
5.3 Every browser allows you to manage your cookies preferences. Please bear in mind that disabling cookies may complicate or even prevent you from using certain parts of features of the Services.
5.5 If you are a User, visitor to our Sites, or a respondent to a survey, we also use analytics tools such as Google Analytics. These tools help us understand your behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of Google Analytics is available at: https://policies.google.com/technologies/partner-sites
5.6 Further information about your option to opt-out of Google Analytics services is available at: https://tools.google.com/dlpage/gaoptout
5.7 Please note that if you get a new computer or device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
6.1 Service Communications: If you are a User, we may send you notifications (through any of the means available to us, including by email, SMS and mobile notifications) of changes or updates to our Services, billing issues, service changes, etc. You can control some of these notifications settings. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to the operation of our Services and their use (like billing notices).
6.2 Promotional Communications: If you are a User or a prospective Customers or partner, we may also notify you about new features, additional offerings, better ways to use the Services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, SMS, mobile notifications or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you can notify us at any time by writing to email@example.com, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
7. Data Security
We and our hosting services implement systems, applications and procedures to secure your personal data, and to reduce the risks of theft, damage, loss of data, or unauthorized access or use of personal data. These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
8. Data Subject Rights
Individuals have rights concerning their personal data. If you wish to exercise your privacy rights under any law applicable to you, including the EU General Data Protection Regulation (“GDPR”) or the California Consumer Privacy Act (“CCPA)”, such as, to the extent applicable, the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), and rectification or erasure of your Personal Data held by Zencity, or to restrict or object to your Personal Data’s processing (including the right to direct us not to sell our Personal Data to third parties now or in the future), or to exercise your rights to portability with respect to your Personal Data or your right to equal services and prices (e.g. freedom from discrimination) (each if and to the extent available to you under the laws which apply to you) – please contact us at: firstname.lastname@example.org. Please note that in certain circumstances Zencity may be acting as a data processor on behalf of its Customer. In such a case, we will refer your request to our Customer for the fulfillment of your request. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.
8.1 Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
8.2 We may redact from the data which we will make available to you, any personal data related to others.
9. Data Controller/Processor
Data Controller/Processor. Certain data protection laws and regulations, such as the GDPR or the CCPA distinguish between two main roles of parties processing Personal Data: the “data controller” (or under the CCPA, “business“), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider“), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
9.2 Zencity is the “Data Processor” or “Service Provider” of Resident Data and Content Data, which we process on behalf of our Customer (who is the “data controller” or “business” with respect to such data); and our Service Providers and our affiliated companies who process such Customer Data on our behalf are the “sub-processors” of such data. Our activity is conducted strictly in accordance with our Customer’s lawful instructions and as further stipulated in our DPA and other commercial agreements with such Customer. The Customer, as controller of such data, will be responsible for meeting any legal requirements applicable to data controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
10. Additional Notices & Contact Details
10.2. California Requirements: This policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), our retention (Section 3), and deletion (Section 8) practices. We also included information about how we may process your information (Sections 2 through 6), which includes for “business purposes” under the CCPA. We do not sell your personal information for the intents and purposes of CCPA. We may disclose personal information to third parties or allow them to collect personal data from our Services as described in Section 4 above, if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Services, or direct us to disclose your personal data to third parties, or as otherwise described in Section 4 above. If you have any questions or would like to exercise your rights under the CCPA, you can contact email@example.com.
10.4. Our Services are not designed to be used by children under the age of 18: Our Services are not designed to be used by children under the age of 18 and we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 18 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us regarding such a child. If you believe that we might have any such data, please contact us by e-mail at firstname.lastname@example.org.
10.5. UK Representative Prighter Ltd. has been designated as Zencity’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Prighter may be contacted on matters related to the processing of personal data of residents of the UK, at https://prighter.com/q/17328186 20 Mortlake High Street, London, SW14 8JN, UNITED KINGDOM.
Effective Date: March 2023