Zumigo IDV Builder Privacy Policy

Effective Date: December 1, 2025

This Zumigo, Inc. (“Zumigo,” “we”, “us”, or “our”) Privacy Policy applies to our business customers (“Customers”) and visitors to our website (the “Site”).

California Customers and visitors to our Site can find specific disclosures, including “Notice at Collection” details, by clicking here.

Privacy Policy applicable to Customers and Site visitors

The Personal Data we collect depends on how you interact with us and the services you use.

We collect information about you from different sources and in various ways when you use our services, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.

Information you provide directly. We collect Personal Data you provide to us. For example:

Name and contact information. We collect name, username or alias, and contact details such as email address, postal address, and phone number.
Demographic data. In some cases, such as when you register or participate in surveys, we request that you provide age, gender, marital status, and similar demographic details.
Payment information. If you make a purchase or other financial transaction, we collect credit card numbers, financial account information, and other payment details.
Content and files. We collect the photos, documents, or other files you upload to our services; and if you send us email messages or other communications, we collect and retain those communications.

Personal Data Classification

General Personal Data (PI): IP address, contact info, usage data, communications, etc. This is covered by our standard privacy rules.
Highly Sensitive Prefill Data: Specifically: Full Name, Address, SSN, and Date of Birth.

Highly Sensitive Data, will be stored and processed within the United States.

Information we collect automatically. When you use our services, we collect some information automatically. For example:

Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the Cookies, Mobile IDs, and Similar Technologies section below, our websites and online services store and retrieve cookie identifiers, mobile IDs, and other data.
Geolocation data. Depending on your device and app settings, we collect geolocation data when you use our apps or online services.
Usage data. We automatically log your activity on our websites, apps and connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website. We also use tools on certain pages of our services to record and analyze your interaction with our services, including tools to track cursor movements and clicks, and record your screen while you’re on our website, to help us improve your experience.
Content of Zumigo communications. We collect recordings or transcripts of audio and video communications you have with us, as well as the contents of your communications with us via our website or use our services, such as through our website, forms, applications, surveys, chat features, and other channels.

Information we create or generate. We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.

Information we obtain from third-party sources. We also obtain the types of information described above from third parties. These third-party sources include, for example:

Data brokers. Data brokers and aggregators from which we obtain data to supplement the data we collect.
Third party partners. Third party applications and services, including social networks you choose to connect with or interact with through our services.
Co-branding/marketing partners. Partners with which we offer co-branded services or engage in joint marketing activities.
Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.
Publicly available sources. Public sources of information such as open government databases.

When you are asked to provide Personal Data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

Cookies, Mobile IDs, and Similar Technologies

We use cookies, web beacons, mobile analytics and advertising IDs, and similar technologies to operate our websites and online services and to help collect data, including usage data, identifiers, and device information.

For more information about what cookies and similar technologies we use and how we use them, see Zumigo’s Privacy Policy.

How we use Personal Data

We use the Personal Data we collect for purposes described in this Privacy Policy or otherwise disclosed to you. For example, we collect and use the sies of Personal Data described above for the following purposes:

Product and service delivery, including to provide and deliver our services, including troubleshooting, improving our services, and Personalizing our services;
Business operations, including to operate our business, such as billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations;
Product improvement, development, and research, including to develop new services or features, and conduct research;
Personalization, including to understand you and your preferences to enhance your experience and enjoyment using our services
Customer support, including to provide customer support and respond to your questions;
Communications, including to send you information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
Marketing, including to communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners (see the Choice and Control section of this privacy policy for how to change your preferences for promotional communications); and
Advertising, including display advertising to you (see our Privacy Policy for information about Personalized advertising and your advertising choices).

How we disclose Personal Data

We disclose Personal Data with your consent or as necessary to complete your transactions or provide the services you have requested or authorized. In addition, we disclose each of the categories of Personal Data described above, with the types of third parties described below, for the following business purposes:

Public information. You may select options available through our services to publicly display and share your name and/or username and certain other information, such as your profile, demographic data, content and files, or geolocation data.
Service providers. We provide Personal Data to vendors or agents working on our behalf for the purposes described in this policy. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to Personal Data to provide those functions.
Financial services & payment processing. When you provide payment data, for example to make a purchase, we will provide payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services.
Affiliates. We enable access to Personal Data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access is needed to provide our services and operate our business.
Corporate transactions. We may disclose Personal Data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
Legal and law enforcement. We will access, disclose, and preserve Personal Data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
Security, safety, and protecting rights. We will disclose Personal Data if we believe it is necessary to:
- protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
- operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
- protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies.

Third party analytics and advertising companies may also collect Personal Data through our website and apps including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, usage data, and inferences based on and associated with that data, as described in our Cookie Policy.

Please note that some of our services include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide Personal Data to any of those third parties, or allow us to share Personal Data with them, that data is governed by their privacy statements. Finally, we may share de-identified information in accordance with applicable law.

Some of the data disclosures to these third parties may be considered a “sale” or “sharing” of Personal Data as defined under the laws of California and other U.S. states. Please see the Choice and Control and the California Privacy Rights sections for more details.

Data Retention

We retain Personal Data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and our legal or contractual obligations.

Choice and Control of Personal Data

We provide a variety of ways for you to control the Personal Data we hold about you, including choices about how we use that data. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law. Access, portability, correction, and deletion. (i) If you wish to access, correct, or delete Personal Data about you that we hold, you may email privacy@zumigo.com to make your request.

Communications preferences. You can choose whether to receive promotional communications from us by email, and telephone. If you receive promotional email from us and would like to stop, you can do so by following the directions in that message or by contacting us as described in the Contact Us section below. If you receive a sales call from us, you can ask to be placed on our do-not-call list. These choices do not apply to certain informational communications including surveys and mandatory service communications.

Choices for Cookies and Similar Technologies. See our Privacy Policy for choices about cookies and other analytics and advertising controls.

Data sales and targeted advertising. Some privacy laws define “sale” broadly to include some the disclosures described in the How we Disclose Personal Data section above.

Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the Personal Data. Further, we may decline a request where we are unable to authenticate you as the person to whom the Personal Data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you receive a response from us informing you that we have declined your request, in whole or in part, you may appeal that decision by submitting your appeal as described in the Contact Us section below.

European, UK, Swiss Data Protection Rights

If the processing of Personal Data about you is subject to European Union, United Kingdom, and/or Swiss data protection laws, you have certain rights with respect to that data:

You can request access to, and rectification or erasure of, Personal Data;
If any automated processing of Personal Data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the Personal Data in a usable and portable format;
If the processing of Personal Data is based on your consent, you can withdraw consent at any time for future processing;
You can object to, or obtain a restriction of, the processing of Personal Data under certain circumstances; and
For residents of France, you can send us specific instructions regarding the use of Personal Data after your death.

To make such requests please contact us as described in the Contact Us section below. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We rely on different lawful bases for collecting and processing Personal Data about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

California Privacy Rights

If you are a California resident and the processing of Personal Data about you is subject to the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), you have certain rights with respect to that information.

Notice at Collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of Personal Data, the purposes for which such information is collected or used, and how long such information is retained. You can find those details in this policy by clicking on the above links.

Right to Know. You have a right to request that we disclose to you the Personal Data we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such Personal Data. Note that we have provided much of this information in this privacy policy. You may make such a “request to know” by emailing us at privacy@zumigo.com.

Rights to Request Correction or Deletion. You also have rights to request that we correct inaccurate Personal Data and that we delete Personal Data under certain circumstances, subject to a number of exceptions. To make a request to correct or delete, email us at privacy@zumigo.com.

Right to Opt-Out / “Do Not Sell or Share My Personal Information”. You have a right to opt-out from future “sales” or “sharing” of Personal Data as those terms are defined by the CCPA.

The CCPA/CPRA requires us to describe the categories of Personal Data we sell and/or share to third parties and how to opt-out of future sales or sharing. The CCPA/CPRA defines “sell,” “share,” and “Personal information” very broadly, and some of our data sharing described in this privacy policy may be considered a “sale” or “sharing” under those definitions, such as disclosing Personal Data to third parties for our own advertising purposes. We let advertising and analytics providers collect IP addresses and cookie IDs along with associated device and usage data when you access our website, but we do not “sell” or “share” any other types of Personal Data.

If you do not wish for us or our partners to “sell” or “share” Personal Data relating to your visits to our websites for advertising purposes, email us at privacy@zumigo.com. If you opt-out using these choices, we will not share or make available such Personal Data in ways that are considered a “sale” or “sharing” under the CCPA. However, we will continue to make available to our partners (acting as our service providers) some Personal Data to help us perform advertising-related functions. Further, using these choices will not opt you out of the use of previously “sold” or “shared” Personal Data or stop all interest-based advertising.

We do not knowingly sell or share the Personal Data of minors under 16 years of age.

Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to limit our use of sensitive Personal Data for any purposes other than to provide the services or goods you request or as otherwise permitted by law. Note that we do not use Sensitive Personal Data for any such additional purposes.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA/CPRA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Further, to provide, correct, or delete specific pieces of Personal Data will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account. For some types of Personal Data we may have, there may be no reasonable method by which we can verify your identity as the person to whom that data relates.

Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA/CPRA.

Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided Personal Data to a business with which the individual has established a business relationship for Personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed Personal Data to any third parties for the third parties’ direct marketing purposes.

Please be aware that we do not disclose Personal Data to any third parties for their direct marketing purposes as defined by this law.

California Customers may request further information about our compliance with this law by e-mailing zumigo@privacy.com. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated e-mail address.

Location of Personal Data

The Personal Data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data. Currently, we primarily use data centers in the United States. For clarity, any Highly Sensitive Data we collect will remain in the United States. The storage location(s) are chosen to operate efficiently and improve performance. We take steps designed to ensure that Personal Data is processed and protected as described in this policy wherever the data is located.

Location of Processing European Personal Data. We transfer Personal Data from the European Economic Area (EEA), United Kingdom (UK), and Switzerland to the United States. When we do so, we use legal mechanisms, including contracts, to help ensure your rights and protections.

Compliance With Data Privacy Framework Principles. Zumigo complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Zumigo has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Zumigo has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. If third-party agents process Personal Data on our behalf in a manner inconsistent with the Data Privacy Framework Principles, we remain liable unless we prove we are not responsible for the event giving rise to any damages. If you have a question or complaint related to our compliance with the Data Privacy Framework Principles, please contact us as described in the Contact Us section below.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Zumigo commits to refer unresolved complaints concerning our handling of Personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF as described in our privacy policy.

Finally, under limited circumstances and after other available dispute resolution mechanisms have been exhausted, binding arbitration is available to address certain residual complaints under the EU-U.S. Data Privacy Framework Principles, Swiss-U.S. DPF Principles, and the UK-Extension Framework not resolved by other means.

Security

We take reasonable and appropriate steps to help protect Personal Data from unauthorized access, use, disclosure, alteration, and destruction.

To help us protect Personal Data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

Changes to the Privacy Policy

We will update this Privacy Policy when necessary to reflect changes in our services, how we use Personal Data, or the applicable law. When we post changes to the Privacy Policy, we will revise the “Last Updated” date at the top of the Privacy Policy. If we make material changes to the Privacy Policy, we will provide notice or obtain consent regarding such changes as may be required by law.

Contact Us

If you have a privacy concern, complaint, or a question for Zumigo, please contact us via email at privacy@zumigo.com.

Our postal address is Zumigo, Inc., 1187 Starling Ridge Court, San Jose, California 95120, United States.

Updated December 1, 2025

Zumigo IDV Builder Platform Privacy Policy