Zywave Website Privacy Statement

Last updated March 1, 2017

Zywave is committed to controlling the collection, use and disclosure of your personal information. This Privacy Statement describes how Zywave may collect and handle your non-personal and personal information in connection with your activities with Zywave, including those related to Internet services controlled by Zywave, including websites and FTP servers. You should read this Privacy Statement before using this website and before engaging Zywave for products or services.

Collection and Use of Personal Information

Zywave collects two types of information about our users: Non-Personal Information and Personal Information.

Non-personal information is the anonymous information that is automatically collected when you use any of Zywave’s Internet services. Non-personal information includes, but is not limited to: IP (Internet Protocol) address; server IP address; server port; domain used to access a Zywave Internet service; referring domain or website; type and version of operating system and web browser; search query (keywords entered into a search engine); the date and time the access occurred; which resources were accessed. Non-personal information is only used in aggregate form in order to track and improve the efficiency of Zywave’s Internet services or as part of the investigation of a suspected data event.

Personal information means any information about an identifiable individual, and may include, but is not limited to: (i) your name, address, phone number, fax number, or email address; and (ii) credit and/or billing information. Personal information is collected by Zywave when you voluntarily give it to Zywave. We may also receive personal information from our business partners and other third parties, provided that such parties confirm to us that you have consented to the disclosure to Zywave of your personal information.

Zywave collects and uses personal information to provide you with the products and/or services you requested or a Zywave customer has requested on your behalf from Zywave and to contact you in order to provide you with product-related information, including: news; training and support; customized services; product documentation; promotional materials; market research; or product application feedback. You may at any time withdraw your consent to any further collection, use or disclosure of personal information by giving us reasonable notice.

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. The use of cookies is an industry standard to provide useful features to our customers. Zywave’s cookies do not contain any personally identifying information, but they do enable Zywave to provide features such as administrative guides and e-client. Your web browser may or may not be set to notify you when you are about to accept a cookie. If you refuse to accept a cookie while on Zywave’s websites, you will not be able to access portions of the site. Your use of the website indicates your consent to Zywave’s use of cookies. If you do not consent to Zywave’s use of cookies, you should not use any Zywave website. A list of Zywave’s cookies are available at http://www.zywave.ca/cookie-usage/.

Disclosure of Personal Information

To enable Zywave to efficiently provide the products and services you have requested or received through a customer of Zywave, Zywave may share your personal information with third parties who are acting on Zywave’s behalf as agents, suppliers or service providers. Such third parties are only provided with such information as is necessary for the purpose stipulated by Zywave and are subject to confidentiality. Zywave will not otherwise disclose your personal information to any person or any organization, and Zywave will never sell your personal information to anyone. Advicent may, however, sell all of its data, including your Personal Information, to an acquiring party as part of a merger or sale of substantially all of Advicent’s assets or stock.  If you have questions or concerns about the disclosure of your personal information, or if you believe your information has been improperly disclosed by Zywave, contact our Privacy Officer at the address contained at the end of this Privacy Statement.

Maintenance and Accuracy of Information

Zywave will try to ensure that information about you is accurate, complete and up-to date. Zywave will document and archive your information for as long as we have an ongoing business relationship and will use the information collected only for the purpose for which it was collected. At the time that our business relationship is terminated, we will maintain copies of all information collected as required by applicable law. At the end of the retention period, your information will be destroyed or your personal information will be deleted and the sum of the information (which would now be anonymous) will be added to a permanent archive of business statistical information for our use.

Zywave is dedicated to keeping its records up to date. As long as we have a business relationship, we will periodically verify that our records are accurate with you. When you engage us for services, we will request that you provide us with authorization to contact you periodically in this regard. If at any time you feel that our records are inaccurate, or that your information has been used for a purpose other than that intended, please contact our Privacy Officer at the address contained at the end of this policy.

Security

Zywave is committed to the security of your personal information and Zywave has policies and procedures in place to protect the privacy of your personal information. Personal information shall be protected in a manner commensurate with its sensitivity and reasonable steps will be taken to prevent it from being stolen, lost, accessed, copied, used or modified without permission.

Confidentiality

When you download, view or send to Zywave documents of a confidential nature, we offer the use of a secure server. The secure server software (SSL) encrypts any information that is sent to you and protects against unauthorized access.

Access to Information

Customers in certain jurisdictions may have the right to access the information that we collect about them. Customers may request at any time that they be given access to view the information, and recommend to us any corrections that should be made. After receiving a request, and subject to any applicable laws preventing Zywave from providing access, we will contact the requesting customer within a reasonable amount of time to arrange a date and method for providing the access that has been requested.

If you believe that there is an error in the information we have on file about you, you can request, in writing, that our Privacy Officer review and correct the information as necessary. When you file your submission you should include a copy of the updated, correct information. The Privacy Officer will verify the authenticity of the submitted documents, as well as their validity for our purposes prior to updating our records.

Zywave’s Privacy Statement is not intended to create any contractual or other legal rights in or on behalf of any party. Zywave reserves the right to change this Privacy Statement at any time by posting revisions on its websites.

If you have questions or concerns about the security of your personal information, or if you believe your information has been improperly released, contact Zywave’s Privacy Officer at the email address or the mailing address contained at the end of this Privacy Statement.

Contact Information

You may contact Zywave as follows:
Zywave, Inc.
Attn: Privacy Officer
10100 Innovation Dr., Ste. 300
Milwaukee, WI 53226

support@zywave.com

Zywave Privacy Shield Policy

Zywave adheres to the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce concerning the collection, use, and retention  of personal data transferred from the European Union (“EU”) to the United States of America. Zywave has certified to the Department of Commerce that it adheres to the Privacy Shield Principles (“Principles).  This Privacy Shield Policy (“Policy”) outlines Zywave’s general policy and practices for implementing the Principles, including the types of information gathered, how it is used and the notice and choice affected individuals have regarding the use of and their ability to correct that information.  In the event this Policy conflicts with the Principles, the conflicting Principle shall govern.  More information about the Privacy Shield program can be found at https://www.privacyshield.gov/ .

Principles

Notice
Zywave shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which Zywave discloses or may disclose that Information. Zywave shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Zywave, or as soon as practicable thereafter, and in any event before Zywave uses or discloses the Information for a purpose other than for which it was originally collected.

Application
Zywave commits to apply the Principles to all EU Personal Information it receives in reliance on the Privacy Shield program.

Choice
Zywave will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a non-agent third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorised by the individual. For Sensitive Personal Information, Zywave will give individuals the opportunity to affirmatively or explicitly (opt in) consent to the disclosure of the information to a third party or use for a purpose other than the purpose for which it was originally collected or subsequently authorised by the individual.  Sensitive Personal Information means personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information about an individual’s sexual life.

Onward Transfers
Prior to disclosing Personal Information to a non-agent third party, Zywave shall apply the notice and choice principles. Zywave shall ensure that any third party acting as an agent for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles, or that the third party has agreed in writing to provide a level of privacy protection equal to that required by the relevant principles.  Zywave acknowledges that it is liable for ensuring compliance of personal information transferred on to third parties for use within its Product Applications.

Data Security
Zywave shall take reasonable steps to protect the Information from loss, misuse and unauthorised access, disclosure, alteration and destruction. Zywave has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorised access or disclosure, alteration or destruction.

Data Integrity
Zywave shall only use Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorised by the individual. To the extent necessary for those purposes, Zywave shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access
Zywave shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated, or as otherwise prohibited by law.

Dispute Resolution
Zywave shall investigate questions and complaints about this Privacy Policy and its contents and is committed to resolve privacy concerns of individuals regarding this policy.  Zywave has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the Principles.  After submitting an inquiry to Zywave, a resident of the European Union (EU) may contact the EU DPAs should Zywave not address the inquiry.   An EU Resident may contact the EU DPAs panel at ec-dppanel-secr@ec.europa.eu or individual EU DPAs using the information found at http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm.

Enforcement
Zywave uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. Zywave is subject to the investigatory and enforcement powers of the Federal Trade Commission and any other applicable U.S. authorized statutory body.

Amendments
This Policy may be amended from time to time consistent with the requirements of the Privacy Shield Framework. We will post any revised policy on this website.

Required Disclosure

Zywave may, upon request from public authorities, be required to disclose Personal Information for lawful requests.  This includes, but is not limited to, requests to meet national security, law enforcement, court proceeding, and government requests.