This privacy policy for ZEIL Limited (CRN 3304176) (‘Company’, ‘we’, ‘us’, or ‘our’,), describes how and why we might collect, store, use, and/or share (‘process’) your information when you use our services (‘Services’), such as when you:

• Download and use our mobile application ("ZEIL"), or any other application of ours that links to this privacy policy.
• Engage with us on our website
• Engage with us in other related ways, including any sales and marketing events such as trade shows and careers fares.
• Engage with us directly to process any queries or expedite any requests.

In this Privacy Policy, “You’” or “Users” refers to users of ZEIL or the Website (“ZEIL Platform”), across both a registered and unregistered account, or anyone else that interacts with our business.

We encourage you to review this privacy policy periodically so that you are updated on any changes.

We may collect and retain your personal information in the following circumstances:

• when you register, modify or use any accounts on the ZEIL app or Platform
• when you complete forms on the ZEIL app or Platform
• if you have a subscription, when you provide us information during the ZEIL onboarding process
• in the course of receiving questions, comments or other communications from you

The personal information and sensitive information that we collect depends on the context of your interactions with us, the choices you make, and the products and features you use. The information we collect may include the following:

• Names
• Contact details
• Profile information
• CV details
• Achievements
• Unique Identifiers
• Photos and Videos
• Answers to surveys or questionnaires

Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations of memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

We may provide you with the option to register with us using your existing social media account details, like your Google or LinkedIn, or other social media account. If you choose to register this way, we will collect the information described in the section called “How do we handle your social logins” below.

We may also collect the following data from the use of ZEIL if you choose to provide us with access or permission:

• Geolocation information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile device access. We may request access or permission to certain features from your mobile device, including your mobile device’s calendar, camera, contacts, microphone, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Push notifications. We may request to send you push notifications regarding your account or certain features of the applications. If you wish to opt out from receiving these types of communications, you may turn them off in the application settings.

This information is primarily needed to maintain the security of your data and the operation of ZEIL to provide Services to you, for troubleshooting, and for our internal analytics and reporting purposes.

We automatically collect certain information when you visit, use, or navigate the Services through various technologies, including through a third-party service provider, Smartlook. This information does not reveal your specific identity but may include device and usage information such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our application, for troubleshooting, and for our internal analytics and reporting purposes.

Smartlook helps us understand how our users interact with our Services by recording user sessions and replaying them to identify potential usability enhancements. This data is aggregated and anonymised to protect your personal information.

We also collect information through cookies and similar technologies. You can find more about this in our Cookies and Tracking section below. The information we collect includes:

• Log and usage data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports and hardware settings.
• Mobile device data. By using ZEIL, we may also automatically collect device information about the phone network associated with your mobile device, your mobile device’s operating system or platform, type, unique device ID, model, and manufacturer.
• Location Data. We collect location data such as information about your device’s location, which can either be precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services.

Where you are a resident of New Zealand, all personal data we collect, and process is handled in compliance with the Privacy Act 2020 of New Zealand.

Where you are a resident of Australia, all personal data we collect, and process is handles in compliance with the Privacy Act 1988 (Cth) of Australia.

We use Google's Application Programming Interface (API) Service to leverage Google's Vertex AI capability for our job matching algorithms and other user facing features of our applications. To do this, we will provide anonymised data to Google Vertex AI via an API into our own private Google Cloud Instance, and using large language models to deliver the best and most relevant jobs to candidates based on the data they have provided to us.

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements (set out in the Google API Services User Data Policy).

You can read more about how Google handles your personal information by visiting the Google Privacy Policy.

We process your personal information for a variety of reasons, depending on how you interact with ZEIL and our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account up to date.
• To deliver and facilitate delivery of services to you. We may process your information to provide you with the requested service.
• To send administrative information to you We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To send marketing and promotional communications to you. We may process your information to send you marketing and promotional information, newsletters or job specific notifications and reminders. You may ‘opt-out’ of receiving promotional emails from ZEIL in the ‘Settings’ area of the application, otherwise you may opt out by clicking ‘unsubscribe’ in the footer of an email received or replying STOP to SMS text messages. ZEIL will continue to send you non-promotional emails and SMS text messages concerning the management and security of your ZEIL account.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To protect our Services. To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

We may disclose your personal information if you have authorised us to do so, or if we have told you about the intended disclosure and you have not objected to that disclosure.

We may also disclose your personal information in any of the following circumstances:

• in the case of information provided by advertisers, we publish the information on ZEIL as part of advertising any job;
• your prospective employers;
• if required for third parties to provide services to us in connection with our website;
• if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser's advisers and may be among the assets transferred;
• we believe disclosure is necessary to protect our rights or property (including, without limitation, our employees or contractors), or enforce any legal rights we may have
• we believe disclosure is necessary to protect the rights, property and safety of you, us or others
• we believe disclosure is necessary to assist a law enforcement agency or an agency responsible for national security in the performance of their functions
• we are required or permitted by law to disclose the information

We may also disclose your Personal Information to our service providers, contractors and partners from time to time for the purpose of:

• assisting us to deliver the products and services we offer to you
• enabling you to access the products or services they offer, or
• conducting research

Where you have consented to us doing so, we will pass the information provided to us to a contractor or partner, or contacts in your network and in some circumstances, we may also receive information back from them about you (for example, where via our Services you are referred to or participate in an activity operated by a third party, then the results of your activity may be shared with us.

We may also need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us. required. Any information shared with affiliates strictly consists of anonymised and/or aggregated data. No personal information or Personally Identifiable Information (PII) will be shared or transferred unless legally required.
• Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions. Any information shared with business partners strictly consists of anonymised and/or aggregated data. No personal information or Personally Identifiable Information (PII) will be shared or transferred unless legally required.
• Contacts or Users on ZEIL: Where consented by you, we may share your information to other users on ZEIL, for example, sharing your CV to another user.
• Other users or services: When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter or TikTok account to share content from our Services into these other services, or your email provider may give you the option to upload your ZEIL contacts into its own service. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts by removing them from your profile.

Overseas disclosure

Australian Residents: We may store personal information overseas, including in New Zealand and the United States of America. Where we disclose your personal information to third parties, those third parties may also store, transfer or access personal information outside of Australia. We will only disclose your personal information in accordance with the Australian Privacy Principles.

New Zealand Residents: Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of New Zealand, including but not limited to, Australia and the United States of America, which may not have an equivalent level of data protection laws as those in New Zealand. Before disclosing any personal information to an overseas recipient, we will comply with Information Privacy Principle 12 and only disclose the information if:

• you have authorised the disclosure after we expressly informed you that the overseas recipient may not be required to protect the personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020;
• we believe the overseas recipient is subject to the Privacy Act 2020;
• we believe that the overseas recipient is subject to privacy laws that, overall, provide comparable safeguards to those in the Privacy Act 2020;
• we believe that the overseas recipient is a participant in a prescribed binding scheme;
• we believe that the overseas recipient is subject to privacy laws in a prescribed country; or
• we otherwise believe that the overseas recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020 (for example pursuant to a data transfer agreement entered into between us and the overseas recipient).

We may use cookies and other similar tracking to access or store information. We also use it to provide users with a better browsing experience and help us provide additional functionality to you and help us analyse application usage more accurately. These cookies collect details such as preferences and click activity for measurement and for features such as remembering previous search criteria.

Please note that if you limit the ability for ZEIL to set cookies and similar technologies, there may be an impact to your overall user experience, and some features and services may not function properly if you disable cookies.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Google or Apple logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but may include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive on for the purposes that are described in this privacy policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

We keep information you provide to us and which we collect about you, including Personal Information and Personal Data, for so long as you have an account with us and we continue to provide Services to you or specifically until such time as you request us to delete your Personal Information and Personal Data.

If you would at any time like to review or change the information in your account, deactivate or delete your account, you can:

• Log in to your account settings and update or delete the information you have provided us
• Contact us at support@zeil.com to deactivate or delete your account

Upon request to delete your account, we will remove your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

When we have no ongoing legitimate business need to process your information, we will either delete or anonymise such information, or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

You have the right to ask for a copy of any personal information we hold about you, and to ask for it to be corrected if you think it is wrong. If you’d like to ask for a copy of your information, or to have it corrected, please contact us at privacy@zeil.ai. We may charge you a reasonable amount for such requests as we deem appropriate.

We will take every reasonable precaution to ensure your personal information is secure. This includes keeping your information safe by storing it in encrypted databases and files and only allowing access to staff who have authorisation and require it for the job.

However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, therefore we cannot guarantee that the data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards by malicious persons or unauthorised third parties. Although we do our best to protect your personal information, transmission of personal information to you and from our Services is at your own risk. You should only access the Services within a secure environment.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities tracked. At this stage no uniform technology or industry standard for recognising and implementing DNT signals has been adopted. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy.

We may, at any time and at our discretion, vary this privacy policy by publishing an amended privacy policy on our website. We recommend you check our website regularly to ensure you are aware of our current privacy policy.

We value your comments, feedback and ideas about all aspects of the Services we provide, as well as the any questions or complaints about this privacy policy.

You also have the right to contact the Office of the New Zealand Privacy Commissioner (if you are a New Zealand Resident), or the Office of the Australian Information Commissioner (if you are an Australian Resident).

If you have any feedback or questions about this policy, the practices of our mobile application and Website, or your dealings with ZEIL, you can contact us via:

Post:
Unit 1201-04, Energy Plaza, 92 Granville Road
Tsim Sha Tsui East
Kowloon
Hong Kong