Privacy Policy (Old)

We're committed to your privacy and protecting your personal information. This Privacy Policy aims to provide you with a clear explanation about how your information is collected and how we use it.

Zorin Technology Group Limited and its subsidiaries (“Zorin,” “Zorin Group,” “we,” “us,” or “our,”) collects information from you in different ways, from our websites, software (including “Zorin OS”), online applications, or other locations that refer or link to this Privacy Policy (collectively, our “Services"). Additional consent will be obtained for certain data processing activities. Information collected for or on behalf of the Zorin group of companies will be the responsibility of Zorin Technology Group Limited.

Your data controller is Zorin Technology Group Limited (591652) of the Guinness Enterprise Centre, Taylor's Lane, Dublin 8, Ireland.

This privacy policy explains how we collect, use, and share personal information in the course of our business activities, including:

• What personal information we collect and when and why we use it. Learn more
• How we share personal information within Zorin Group, with our service providers, regulators, and other third parties. Learn more
• Explaining more about Direct Marketing and Automated Decision Making. Learn more
• Transferring personal information globally. Learn more
• How we protect and store your information. Learn more
• Legal rights available to help manage your privacy. Learn more
• How you can contact us for more support. Learn more

We may amend this policy from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this policy.

You might find external links to third-party websites on our website. This privacy policy does not apply to your use of a third-party site.

What personal information we collect and when and why we use it

What information we collect and when

• Personal information. This may include your name, email address, phone number, age, IP address, and a password. We collect this when you create and register an account with us, use our forum, or when you subscribe to our newsletter or mailing lists. We keep this information as long as reasonably required to provide our Services.
• Payment information. This may include your name, email address, billing address, and credit card information. We collect this information when you purchase a product from Zorin or make a donation to us. Credit card information is only used in processing your transaction and is not stored by us. We keep order information (which does not include credit card information, which may be stored by our payment processors) as long as reasonably required to provide our Services and serve purchased products to the respective customers, to comply with the law, or until you ask us to remove it.
• Information from discussions on forums and comment threads. Any information that you disclose in these locations becomes publicly available and may be recorded, archived, and republished by anyone. We keep this information as long as you continue to consent to keep this information published.
• Information from third-party sources. We may receive information about you from publicly and commercially available sources (as permitted by law), which we may combine with other information we receive from or about you. We also may receive information about you from third-party social networking services when you choose to connect with those services. We may notify you when we receive information about you from them and the purposes for which we intend to use that information.
• Other information. You may choose to provide us with information when you contact us (by email, for example), respond to surveys, fill in forms, or use other features of our Services. We may keep a record of that information and/or correspondence. We keep this information for as long as reasonably required. We ask that you do not send us private, sensitive, or confidential information, and you agree that if you do so, it will be at your own risk.

We may also collect the following types of anonymous and non-personally identifiable information from you in order to better understand how our Services are used and how to improve them:

• Online usage logs and analytics. When visiting our websites, online applications or other Services, we may collect information about your interaction including but not limited to the device type, browser version, date & time of the site visit, referring website, pages visited on our websites, and visit duration. Please note that we may use a third-party analytics service to collect some usage information from our websites and online applications. We keep this information as long as reasonably required.
• Error reports. When you choose to send an error report in our software, it includes an anonymous unique identifier for your computer. The unique identifier does not identify you unless you (or someone acting on your behalf) discloses it separately.
• Census. When using Zorin OS, your computer may send us a ping which only includes the number of users, an anonymous identifier for the installation, Zorin OEM partner batch (if applicable), and your OS version on an hourly basis. We use this information to count the number of active users of Zorin OS. The identifier is only used for the census (to prevent double-counting) and does not personally identify you unless you (or someone acting on your behalf) discloses it separately. Below is a sample of the contents of the ping:
  {id:"68f2d95b-f51f-4a5d-9b48-a99c28691b89", usercount:"1", oembatch:"", version:"15"}
  You may choose to disable these pings by selecting the "Don't participate in the census" option in the Zorin OS installer or entering this Terminal command after installing Zorin OS: sudo apt remove zorin-os-census

The legal basis for using your personal information

We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

• you have provided your consent to us using the personal information;
• our use of your personal information is in our legitimate interest as a commercial organisation. In these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained below;
• our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you for example; and
• our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have.

The purposes for which we use your personal data, and their associated legal bases, are described below:

Sharing personal information within Zorin Group, with our service providers, regulators, and other third parties

We share your information in the manner and for the purposes described below:

1. within Zorin Group, where such disclosure is necessary to provide you with our services or to manage our business;
2. with third parties who help manage our business and deliver services. These include:
   1. IT service providers who help manage our IT and back-office systems (please note that we use DigitalOcean for web hosting services; Dropbox and Google Drive for cloud storage);
   2. service providers which process payments and/or store payments information, (please note that we use the third-party payment processors "Stripe Payments Europe, Limited" and "PayPal (Europe) Limited" to store this information and process your payments, while we use the services of "Concept Den Limited" to store order information (which does not include credit card details));
   3. customer service, communication and marketing service providers (please note that we use MailJet and Zapier for the delivery of emails; MailChimp for email newsletter/mailing list storage; Gmail for email conversations with customers; Freshdesk for our technical support helpdesk function, and Akismet to prevent spam on our forum); and with analytics service providers; and
   4. other service providers such as legal and accounting service providers, (please note that we use JPA Brenson Lawlor and Xero for our customer transaction records accounting);
3. with our regulators to comply with all applicable laws, regulations, and rules, and requests of law enforcement, regulatory and other governmental agencies;
4. we may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our affiliates or advertisers; and
5. If in the future, we sell or transfer some or all of our business or assets to a third-party, we may disclose information to a potential or actual third-party purchaser of our business or assets.

Explaining more about Direct Marketing and Automated Decision Making

How we use personal information to keep you up to date with our products and services

We may use personal information to let you know about Zorin products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

How you can manage your marketing preferences

To protect privacy rights and to ensure you have control over how we manage marketing with you:

• we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
• you can ask us to stop direct marketing at any time - you can ask us to stop sending email marketing, by following the 'unsubscribe' link you will find on all the email marketing messages we send you. Alternatively, you can contact us on this page. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email newsletter); and
• you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained above.

We recommend you routinely review the privacy policies and preference settings that are available to you on any social media platforms as well as your preferences within your Zorin account.

When and how we undertake analytics

We use data for analytics and measurement to understand how our Services are used. For example, we analyse data about your visits to our website to do things like optimise product design. We use a variety of tools to do this, including cookies, Akismet, and Plausible Analytics.

• Website cookies. We may use persistent cookies to better understand how you use our websites and to allow us to provide a better user experience. These cookies remain on your computer after you close your browser and may be used by your browser on subsequent visits to our websites. You can choose to disable some or all cookies from your browser settings. Our Cookies Policy can be accessed here.
• Forum cookies. These cookies are used to keep you logged into your account during sessions and in between sessions, if you accept this option. In addition, cookies are assigned to store some of your user preferences when using the forum.
• Akismet. This service analyses usage patterns on our forum to prevent spam and malicious content. New posts on the forum and user metadata are sent to Akismet’s servers for analysis. This data is retained by Akismet in accordance with their data retention policy. You can opt-out of the analysis of your posts and data by Akismet here. Akismet privacy information
• Plausible Analytics. This service is used to collect information about how visitors use our website, which we use to help improve it. It records information in aggregate in a privacy-friendly manner without the use of cookies. No personal data or personally identifiable information is stored. This service allows us to see the number of visitors to the site, where visitors have come to the site from and the pages they visited. You can learn more about Plausible Analytics here. Plausible Analytics data policy

Transferring personal information globally

We operate on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the EU. We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests, in particular we will either:

• only transfer your personal data to countries which are recognised as providing an adequate level of legal protection in accordance with Article 45 of the GDPR; or
• ensure that transfers outside your country are subject to additional safeguards required under local law – for example, the EU Model Clauses pursuant to Article 46(2) of the GDPR or by relying on certification schemes.

You have the right to ask us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) as mentioned above. Contact us as if you would like further information or to request a copy where the safeguard is documented (which may be redacted to ensure confidentiality).

How we protect and store your information

Security

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned. Measures we take include placing confidentiality requirements on our staff members and Service Providers; destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected.

Our Services may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by websites or other services. You should exercise caution, and review the privacy statements applicable to the third-party websites and services you use, as we do not accept any responsibility or liability for these policies.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

Storing your personal information

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this policy. In some circumstances, we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.

In specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Transparency

We have never received any court orders, warrants, or other classified requests for any user information. We have also not placed any backdoors into Zorin OS, our Services, or any of our products and have not been requested to do so.

Legal rights available to help manage your privacy

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right to access personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of:

• the source of your personal information;
• the purposes, legal basis, and methods of processing;
• the data controller’s identity; and
• the entities or categories of entities to whom your personal information may be transferred.

Right to rectify or erase personal information

You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.

You can also request that we erase your personal information in limited circumstances where:

• it is no longer needed for the purposes for which it was collected; or
• you have withdrawn your consent (where the data processing was based on consent); or
• following a successful right to object (see right to object); or
• it has been processed unlawfully; or
• to comply with a legal obligation to which we are subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

• for compliance with a legal obligation; or
• for the establishment, exercise or defence of legal claims;

Right to restrict the processing of your personal information

You can ask us to restrict your personal information, but only where:

• its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want it erased; or
• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal information following a request for restriction, where:

• we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.

Right to transfer your personal information

You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

• the processing is based on your consent or on the performance of a contract with you; and
• the processing is carried out by automated means.

Right to object to the processing of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to how we use your personal information for direct marketing purposes

You can request that we change the manner in which we contact you for marketing purposes.

You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union. We may redact data transfer agreements to protect commercial terms.

Contact us

If you would like to ask us about the Privacy Policy, Zorin's other policies, to access, remove, or correct information we have about you, or any other query relating to the Services you can do so by sending us a message on this page or write to us at the below address:

Legal, Zorin Technology Group
Guinness Enterprise Centre
Taylor's Lane
Dublin 8
Ireland

To contact your data protection supervisory authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

If you have a complaint about the use of your information, you can contact the Data Protection Commission on their website or write to them at the below address:

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2, D02 RD28
Ireland