Privacy Policy

Zenovay Inc. ("Zenovay", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website zenovay.com (the "Site") and use our analytics platform and related services (the "Services"). This Privacy Policy is designed to comply with the General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (nDSG), as well as other applicable data protection laws.

Please read this Privacy Policy carefully. This Privacy Policy is provided for informational purposes and describes our data practices. By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy. If you have questions, please contact us at privacy@zenovay.com.

Information We Collect

We collect information about you in various ways when you use our Services. The information we collect falls into the following categories:

Information You Provide Directly

We collect information that you provide directly to us, including:

• Account Information: When you create an account, we collect your name, email address, company name, and password.
• Payment Information: When you subscribe to a paid plan, our payment processor (Stripe) collects your payment card information, billing address, and related payment details. We do not store complete payment card numbers on our servers.
• Profile Information: You may choose to provide additional information such as your job title, phone number, profile picture, and company website.
• Communications: When you contact our support team or communicate with us, we collect the content of your messages, support tickets, and any attachments you send.
• Survey Responses: If you participate in surveys or provide feedback, we collect your responses and any personal information you choose to share.

Support Communications

When you contact our support team or use our AI support assistant:

• Chat History: We store chat conversations to improve support quality and train our AI assistant. Chat transcripts may be retained for up to 2 years.
• Support Tickets: Ticket content, attachments, and metadata are retained for 2 years to provide consistent support and track issue resolution.
• Project Access: If you grant support access to your project, our support team may temporarily view your analytics data, configurations, and activity logs to diagnose and resolve issues.
• AI Processing: Your support messages may be processed by AI systems (via Cloudflare AI Gateway and OpenAI) to provide faster responses and categorize issues. You can always request human support at any time.
• Attachments: Files you upload (screenshots, logs, etc.) are stored securely and retained for the duration of ticket resolution plus 90 days.

Information Collected Automatically

When you access or use our Services, we automatically collect certain information, including:

• Usage Data: We collect information about your use of our Services, including the pages you view, features you use, links you click, searches you perform, and the date and time of your visits.
• Device Information: We collect information about the devices you use to access our Services, including device type, operating system, browser type and version, screen resolution, IP address, unique device identifiers, and mobile network information.
• Location Data: We may collect approximate location information based on your IP address (using IPwho.is as a fallback geolocation provider) to provide region-specific features and comply with local regulations.
• Cookies and Similar Technologies: We use essential cookies, including analytics cookies, to collect information about your browsing behavior. See our Cookie Policy for more details. An informational cookie notice appears on your first visit and is accessible at any time via the "Cookie Settings" link in the footer.

Cookies and Local Storage

The following table describes the cookies and local storage items used by our Services:

Information From Third Parties

We may receive information about you from third-party sources, including:

• Authentication Services: If you sign up or log in using a third-party service (Google OAuth, GitHub OAuth), we receive basic profile information from that service.
• Data Enrichment Services: We may use third-party data enrichment services to enhance analytics insights for business intelligence purposes.
• Bot Protection: Cloudflare Turnstile may be used to verify that interactions are from legitimate users.

Analytics Data We Process on Behalf of Customers

As an analytics platform, we process data about visitors to our customers' websites on their behalf. This section describes the data we collect and process when you visit a website that uses Zenovay analytics. Our customers (the website operators) are the data controllers for this data, and we act as their data processor.

Visitor Data Collected

When you visit a website using Zenovay analytics, we may collect:

• Network Information: IP address, approximate geographic location (country, region, city)
• Device Information: Device type, browser, operating system, screen resolution, viewport dimensions
• Page Information: URLs visited, page titles, referrer URLs, time spent on pages
• Behavioral Data: Scroll depth, click counts, form interactions, engagement time
• Campaign Data: UTM parameters and advertising platform click identifiers (e.g., Google, Facebook, TikTok)
• Conversion Data: Custom conversion events, goal completions, and associated values as defined by the website operator
• Session Information: Session duration, pages viewed per session, returning visitor status

Automated Decision-Making and Profiling

Our Services include automated visitor value scoring that assigns a score between 0 and 100 to website visitors based on factors including geographic location, device type, browsing behavior, and session characteristics. This scoring is used to help our customers prioritize visitor engagement and understand visitor quality. The scoring is performed automatically without human intervention.

Under GDPR Article 22 and nDSG Article 21, you have the right to:

• Obtain information about the logic involved in automated decision-making
• Express your point of view and contest decisions based solely on automated processing
• Request human review of automated decisions that significantly affect you

To exercise these rights, contact privacy@zenovay.com.

Optional Analytics Features

Website operators may enable additional features that collect more detailed data:

• Session Replay: When enabled, we record user interactions including mouse movements, clicks, and page content to help website operators understand user behavior. Sensitive form fields (passwords, credit cards) are automatically masked.
• Heatmaps: Aggregated visualization of where users click and scroll on pages.
• User Identification: Website operators may choose to associate analytics data with user identifiers (name, email, company) that they provide to us through their implementation.
• Business Intelligence: For B2B analytics, we may use third-party data enrichment services to identify the organizations visiting a website based on network information.
• AI-Powered Insights: Analytics data may be processed through AI models (via Cloudflare AI Gateway) to generate automated insights and recommendations for website operators.

IP Address Handling

We collect IP addresses to determine geographic location and for security purposes. IP addresses are:

• Stored to enable geographic analytics and fraud prevention
• Retained according to the data retention period configured by the website operator (see Data Retention section)
• Not shared with third parties except as described in this policy
• Used for B2B company identification when this optional feature is enabled

First-Party Tracking

Some customers may configure Zenovay to operate through their own domain (first-party tracking). In this configuration:

• Analytics requests appear to originate from the customer's domain rather than Zenovay's domain
• This may affect how ad-blockers and privacy tools interact with the tracking
• The customer is responsible for disclosing this practice in their own privacy policy

How We Use Your Information

We use the information we collect for various purposes, including:

• Provide and Maintain Services: To create and manage your account, process transactions, provide customer support, and deliver the features and functionality of our Services.
• Improve and Develop Services: To understand how users interact with our Services, identify trends, diagnose technical issues, and develop new features and improvements.
• Communicate With You: To send you service-related notifications, respond to your inquiries, provide customer support, and send marketing communications (with your consent).
• Personalization: To personalize your experience, provide relevant content and recommendations, and remember your preferences.
• Security and Fraud Prevention: To detect, prevent, and respond to fraud, abuse, security risks, and technical issues.
• Legal Compliance: To comply with legal obligations, respond to legal requests, enforce our terms and policies, and protect our rights and the rights of others.
• Analytics and Research: To conduct research, create statistical and aggregated data, and analyze usage patterns to improve our Services.
• Marketing and Advertising: To send you promotional materials and measure the effectiveness of our marketing campaigns (with your consent where required).

Legal Basis for Processing

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, our legal basis for collecting and using your information depends on the specific processing activity:

How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Cloud Infrastructure: Cloudflare for edge computing, content delivery, and security services
• Database Services: Supabase for data storage, real-time synchronization, and authentication
• Payment Processing: Stripe for processing payments and managing subscriptions
• Email Services: Resend for transactional email delivery
• Geolocation: Mapbox for map visualization and geographic data
• Geolocation Fallback: IPwho.is for IP geolocation lookups when primary service is unavailable
• AI Services: OpenAI for AI-powered analytics insights (optional feature)
• AI Routing: Cloudflare AI Gateway for AI model routing and caching
• Authentication: Google OAuth for social sign-in
• Authentication: GitHub (Microsoft) OAuth for social sign-in
• Bot Protection: Cloudflare Turnstile for CAPTCHA and bot protection

These service providers have access to your information only to perform tasks on our behalf and are obligated to protect your information. For a complete list of our subprocessors, please see our Subprocessors page.

Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your information is transferred and becomes subject to a different privacy policy.

Legal Requirements and Protection

We may disclose your information if required to do so by law or if we believe such action is necessary to:

• Comply with legal obligations, court orders, or governmental requests
• Enforce our Terms of Service or other agreements
• Protect and defend our rights or property
• Prevent fraud or abuse of our Services
• Protect the safety of our users or the public

Data Security

We implement appropriate technical and organizational security measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL
• Encryption of sensitive data at rest
• Periodic security reviews leveraging infrastructure provider certifications
• Access controls and authentication requirements
• Employee training on data protection and security
• Incident response and breach notification procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify the relevant supervisory authority (including the EDOEB for Swiss residents and the competent EU Data Protection Authority for EU residents) without undue delay and, where feasible, within 72 hours of becoming aware of the breach, in accordance with GDPR Article 33 and nDSG Article 24
• Communicate the breach to affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms, in accordance with GDPR Article 34
• Document all breaches, including facts, effects, and remedial actions taken

Data Protection Impact Assessment

We conduct Data Protection Impact Assessments (DPIAs) for processing activities that are likely to result in a high risk to the rights and freedoms of individuals, including visitor value scoring and AI-powered analytics processing, in accordance with Art. 35 GDPR.

Data Retention

We retain your information for as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods depend on the type of information:

Account Data

• Account Information: Retained for the duration of your account plus 90 days after account closure
• Payment Records: Retained for 7 years to comply with tax and accounting requirements
• Communications: Support tickets and communications retained for 2 years
• Logs and Security Data: Retained for 90 days for security and troubleshooting purposes

Analytics Data

Analytics data (visitor records, page views, and behavioral data) is retained based on your subscription tier:

• Free Plan: 1 year (365 days)
• Pro Plan: 2 years (730 days)
• Scale Plan: 4 years (1,460 days)
• Enterprise Plan: Custom retention period as agreed

Data Retention Lifecycle

When data exceeds your plan's retention period, we use a two-phase process to ensure you have time to take action:

• Phase 1 - Soft Hide (Day 0): Data older than your retention period is hidden from analytics views but remains in our systems. Your current analytics continue working normally.
• Phase 2 - Grace Period (30 days): You receive email notifications about the hidden data. During this period, you can upgrade your plan to recover the data.
• Phase 3 - Permanent Deletion (Day 30+): After the grace period, hidden data is permanently deleted and cannot be recovered.

If you downgrade to a lower tier, any data exceeding your new plan's retention period will immediately enter Phase 1 (soft hide), giving you 30 days to upgrade and recover your data.

Aggregated daily statistics follow the same retention lifecycle as your plan. You can request deletion of your information at any time by contacting us or deleting your account through the Services.

International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have data protection laws that are different from the laws of your country.

When we transfer personal information from the EEA, UK, or Switzerland to other countries, we use appropriate safeguards, including:

• EU-US Data Privacy Framework (DPF): Where our service providers are certified under the EU-US DPF, we rely on this framework as a valid transfer mechanism.
• Swiss-US Data Privacy Framework: For transfers from Switzerland, we rely on the Swiss-US DPF where applicable.
• Standard Contractual Clauses (SCCs): We use European Commission-approved Standard Contractual Clauses as a fallback transfer mechanism.
• Transfer Impact Assessments: Transfer Impact Assessments conducted for each data transfer to evaluate the legal framework in the recipient country.
• Adequacy Decisions: Where applicable, we rely on adequacy decisions by the European Commission.
• Supplementary Measures: We implement additional technical measures including encryption in transit and at rest, access controls, and data minimization to supplement transfer safeguards.

Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

Access and Portability

You have the right to access your personal information and request a copy in a portable, machine-readable format.

Correction

You have the right to correct inaccurate or incomplete personal information. You can update most information through your account settings.

Deletion

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., legal obligations, legitimate business purposes).

Objection and Restriction

You have the right to object to certain processing of your information or request that we restrict processing in certain circumstances.

Withdraw Consent

Where we process your information based on consent, you have the right to withdraw consent at any time.

Opt-Out of Marketing

You can opt out of marketing communications by clicking the "unsubscribe" link in our emails or updating your communication preferences in your account settings.

California Privacy Rights (CPRA)

If you are a California resident, you have rights under the California Privacy Rights Act (CPRA, formerly CCPA):

• Right to Know: You have the right to request information about the personal information we collect, use, and disclose about you.
• Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: You have the right to opt out of the "sale" or "sharing" of your personal information. We do not sell or share personal information for cross-context behavioral advertising.
• Right to Limit Use of Sensitive Information: You have the right to limit our use of sensitive personal information to purposes necessary to provide the Services.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

Global Privacy Control (GPC): We honor Global Privacy Control (GPC) signals. When we detect a GPC signal from your browser, we treat it as a valid opt-out request under CCPA/CPRA and will not load analytics tracking cookies.

To exercise these rights, please contact us at privacy@zenovay.com.

European and Swiss Privacy Rights (GDPR and nDSG)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (nDSG):

• Right of access to your personal information
• Right to rectification of inaccurate information
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent
• Right not to be subject to solely automated decision-making
• Right to lodge a complaint with a supervisory authority, including the Swiss Federal Data Protection and Information Commissioner (EDOEB) for Swiss residents or the competent EU Data Protection Authority for EU residents

To exercise these rights or if you have questions about our data processing, please contact us at privacy@zenovay.com. You also have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities is available at edpb.europa.eu. For Swiss residents, contact the EDOEB at www.edoeb.admin.ch.

Children's Privacy

Our Services are not directed to children under the age of 16 in the European Economic Area and Switzerland (pursuant to GDPR and nDSG), or under the age of 13 in the United States (pursuant to COPPA). We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at privacy@zenovay.com, and we will take steps to delete such information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last update" date at the top of this page
• Notify you via email or through a prominent notice in our Services
• Obtain your consent if required by applicable law

We encourage you to review this Privacy Policy periodically.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: