Privacy Policy

This Privacy Policy was last modified on January 26th, 2018.

ZenyWay SAS ("us", "we", "our", or "ZenyWay") owns and operates https://www.zenyway.com. This domain hosts the company's website (the « Website »), on pages starting with https://zenyway.com/password-manager, and the password management application ZenyPass ("ZenyPass"), on pages starting with https://zenyway.com/zenypass/app.

This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from visitors of the Website (our "Privacy Policies").

Personal data privacy: at the core of ZenyWay's mission.

At ZenyWay, we are driven by the conviction that safeguarding online data privacy is a fundamental right, that it should be built-in by default, taken for granted, remarkably unremarkable, for everyone. In fact, we're convinced that respecting online privacy of consumers enriches their online experience.

Applications and services we provide, as well as this Website are designed to respect the personal data privacy of visitors.

Declaration to the CNIL (French Data Protection Authority)

In accordance with French data protection act of January 6, 1978, amended in 2004, this Website has been declared to the "Commission Nationale Informatique et Libertés" (CNIL, 8 rue Vivienne, CS30223, 75083 Paris Cedex 02, France – www.cnil.fr/english), which awarded the authorization number 1910777.

You have a right to access and rectify information concerning you, that you can exercise by contacting contact@zenyway.com.

Personal Data Collection And Use

Legitimate Visitors

This Privacy Policy applies to legitimate HTTP-only access to the Website, ie. standard HTTP GET access to content made publicly available on this Website, such as when following a link with a browser to a page of this Website, or standard HTTP POST command to publicly available endpoints on this Website, such as when registering to an offered newsletter.

When our servers detect non-legitimate (abnormal and abusive) interaction, such as but not limited to,

these are logged in full with all available details possibly identifying the offender, including, but not limited to, the full IP of the offender, and further access may automatically be denied.

These countermeasures are intended to help protect legitimate interaction with Visitors accessing our Website through a browser or equivalent browsing app.

Visitor information

This website does not collect any personal data about its visitors.

Visitors typically access our Website through user agents such as browsers, or browsing apps. When accessing a website, browsers commonly send information that may include elements revealing the private identity of its user, such as the IP address it is operating from.

Unlike many sites, this Website does not store any personal information, such as the full IP address of visitors. We consistently anonymise the IP sent by visitors by removing its last byte.

Anonymous Log Data

Although we do collect part of the information that browsers send under normal operation whenever visiting our Website, we consistently ignore and strip any personal information out before further processing ("Anonymous Log Data").

This Anonymous Log Data includes generic non-personal information such as

This Log Data allows us to run statistical analysis and optimize our Website to visitor expectations.

Do Not Track

Since this Website does not collect any personal data from its visitors, it complies by default with the browser's Do Not Track setting.

Newsletter and email address

This Website operates an email newsletter program, used to inform subscribers about products and services supplied by this Website. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user. Subscribers are given the opportunity to unsubscribe at any time by following the “unsubscribe” instructions in each email.

We do not sell or rent personal details, and we will not disclose users' email addresses to any third party for commercial purposes.

We use Mailjet to manage our newsletter program. Email addresses of the users who subscribed to our newsletter will be shared with Mailjet. Mailjet is a French company, with servers located within the European Union. Their personal data protection and privacy policy is available here.

Cookies

ZenyWay does not user cookies, neither for this Website, nor for the Zenypass password manager application.

Cookies are small files, sent by websites to internet browsers, and stored on the user's device. Cookies typically include information about the user or the ongoing user session, such as a unique identifier.

Scripts

Scripts are software programs that execute specific functionalities of a website. Many websites will include scripts on their pages to track user behaviour.

This Website does not require activation of scripts and can be viewed from browsers with disabled scripts. The only tracker used by this Website is the "Facebook pixel".

The ZenyPass password manager, on the other hand, is a web application that works with scripts. To use ZenyPass, it is therefore necessary to authorize the execution of scripts within the browser. However these scripts do not collect any personnal data.

Browser extensions such as Ghostery provide information about the trackers present in a web page, and can be used to check which trackers are used on this Website or in ZenyPass.

Facebook pixel

The Facebook Pixel is an analytics tool to help measure the success of an advertising campaign. This Website uses a Facebook pixel, to optimize advertising based on the activity of visitors of this Website.

This Website may contain links to other websites. We are not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our website, and review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by this Website.

Server location

Our servers are hosted by Digital Ocean. They are physically located in Digital Ocean's European data centre in Frankfurt, Germany, which is certified ISO9001:2008, ISO27001:2005, and ISO22301:2012.

Digital Ocean is committed to privacy and their services comply with EU privacy directives. Digital Ocean's privacy policy is available here.

Changes to this Privacy Policy

ZenyWay SAS may update this Privacy Policy from time to time, with or without notice. We therefore invite our visitors to review this Privacy Policy on a regular basis. Significant changes to this Privacy Policy will be sent to users who subscribed to our newsletter.