Last Updated 22.10.25
Zeroma Inc. ("Zeroma" "we" "us" or "our") is committed to maintaining the accuracy, confidentiality, and security of personal information that we collect from our customers, users of the Zeroma platform and website (zeromadata.com) and participants in Zeroma’s marketing surveys ("you" "your" or "user"). Personal information means information about an identifiable individual, or any other similar definition provided in privacy or data protection laws applicable in the relevant jurisdiction and includes, without limitation, offline identifiers and online identifiers associated with devices.
INTRODUCTION
Zeroma is a survey-powered audience platform that connects brands and audiences. Our business relies on a consent-based identity framework that enables companies to activate their data across multiple channels for marketing purposes by turning real-time survey responses into multilayered audience segments. Zeroma is powered by technology that allows audiences to choose what data they share in the digital advertising space and facilitates the collection, use and transfer of data in a transparent and privacy compliant way.
Zeroma designs and distributes marketing surveys on behalf of its customers (an “Advertiser”). Users who agree to participate in a Zeroma marketing survey (a “Survey”) can access these surveys either: (i) by going directly to the Zeroma platform (the “Platform”); (ii) by clicking on a survey code embedded on an Advertiser’s website or app; or (iii) by clicking on an advertisement on a social media platform. In all cases, users will be directed to a Zeroma landing page that expressly references and provides a link to this Policy. To participate in a Survey, users will be required to read and agree to this Policy and any accompanying terms and conditions.
Zeroma facilitates and augments an Advertiser’s use of online identifiers for targeted digital advertising purposes by constructing audience segments, but does not itself provide targeted or behavioural advertising as a service.
WHAT THIS PRIVACY POLICY IS ABOUT
This Privacy Policy (the "Policy") describes how Zeroma collects, uses and shares personal information when you:
We will only use your personal information in accordance with this Policy unless otherwise permitted or required by applicable law.
Please read this Policy carefully. If you do not agree with our policies and practices, do not use the Services. By using any of our Services, you indicate that you understand and consent to the practices described in this Policy. This Policy is effective as of the date noted above and supersedes previous versions.
This Policy may change from time to time. Your continued use of the Services after we make changes indicates that you consent to those changes, so please check the Policy periodically for updates. We will notify you in advance of any material changes to this Policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.
Please note that this Policy does not apply to any products, services, websites, or content that are offered or hosted by third parties which are governed by their respective privacy policies.
HOW WE COLLECT PERSONAL DATA ABOUT YOU
We collect information that is relevant for the purpose of providing the Services, meeting our legal obligations, advertising and marketing our Services, and researching and developing new products and techniques to improve our Services and business.
Your personal information may be collected directly from you through:
We may also collect personal information about you from Advertisers and other third party partners that we work with in delivering our Services. This information may be combined with other information that we collect and use for the purposes described in this Policy.
WHAT PERSONAL DATA WE COLLECT
The personal information we collect depends on how you use our Services and may include:
HOW WE USE YOUR PERSONAL DATA
We use information that we collect about you or that you provide to us, including any personal information as described below.
HOW WE SHARE YOUR INFORMATION
We may share personal information that we collect or you provide as described in this Policy as follows:
Legal Disclosures. We may disclose your information (including personal information) where we believe that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a warrant or administrative request, a court or regulatory order, or other valid legal processes. We may also disclose personal information to carry out our obligations and enforce our rights arising from any contracts with you, to detect fraud, for assistance with a delinquent account, as evidence in litigation in which we are involved, or to protect the safety and/or security of our users, the Service or the general public. We may make other types of disclosures as permitted or required by applicable law.
Affiliates and Business Partners. We may share your information, such as your email address, with our subsidiaries and affiliates, which includes Mobi Plus Ltd. (trading as “mplus”).
Business Transaction. In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers and users is among the assets transferred.
Service Providers. We may transfer your information to contractors, service providers, and other third parties we use to support our business (such as marketing enrichment and data analysis service providers, hosting service providers, and advertising technology infrastructure partners such as demand-side platforms and data marketplaces (for example, The Trade Desk, Inc.) for the purpose of providing pseudonymized segment activation and audience analytics services to our advertiser customers , and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this Policy. For example, when you respond to one of our Surveys, we will share your Hashed Email Address with an advertising platform partner which provides programmatic marketing automation technology services and assists us with data analysis and audience segmentation.
Aggregated and De-Identified Information. We may also aggregate, anonymize or de-identify Personal Data we receive and use this information about aggregated user behaviour and the Service for marketing and research purposes. For example, we might inform third parties, such as Advertisers and clients of Zeroma and its affiliates and subsidiaries, regarding the number of unique users who use the Service, and the demographic breakdown of our registered users of the Service.
THIRD PARTY LINKS
Content and information posted by us or our users may contain links to other sites, including those of our business partners or affiliates. While we seek to link only to sites that share our high standards and respect for privacy and security, we are not responsible for the privacy practices used by other sites.
INFORMATION WE COLLECT THROUGH COOKIES AND OTHER AUTOMATED DATA COLLECTION TECHNOLOGIES
Our Services (in particular our website and Zeroma Plugin) utilizes cookie technology to allow us to improve the functionality of the service and improve your user experience. Your browser or device may allow you to block or delete cookies from our site, however, this may interfere with the functionality of our Services. Cookies collect information automatically even when a user is not logged into their account. The information collected may include information about the platform and operating system you are using, your browser type and version, computer and connection information, and what time you accessed the site. This information will be collected any time you access the website or the application unless you opt out.
What are cookies?
Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to "remember" you and your preferences, either for a single visit (through a "session cookie") or for multiple repeat visits (using a "persistent cookie"). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as "first party cookies"), or by third parties, such as those who serve content or provide advertising or analytics services on the website ("third party cookies").
Both websites and HTML emails may also contain other tracking technologies such as "web beacons" or "pixels." These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.
Which cookies do we use?
Anytime you visit and use our website or the Zeroma Plugin, we (first-party) or a third-party places cookies in your browser. Certain cookies are specific to features or specific preferences, and certain cookies will be used all the time. We use four different types of cookies.
Essential Cookies. These are cookies are placed in your browser by our website and are also known as "strictly necessary" cookies. These are necessary to allow you to move around the site and use its features, such as "Save and View Favorites."
Analytics Cookies. Also known as "performance cookies," analytics cookies collect information about visits to our sites and how the services we offer are being used. We use this data to make improvements and report our performance. For example, these cookies collect information about how visitors use our sites, which site the visitor came from, the number of each user's visits and how long a user stays on the site. We might also use analytics cookies to test new ads, pages, or features to see how users react to them. Analytics cookies are primarily third-party cookies.
Functionality Cookies. Sometimes called "preference cookies," these first-party cookies allow us to remember information you have entered or choices you have made (such as your username, language, region, and marketing preferences) on our sites, so the next time you visit the site you will not have to set them again. These cookies also allow us to provide a better user experience on our website.
Targeting Cookies. Alongside our advertising partners or other third-party partners, we may use these types of cookies, also known as "advertising cookies," to deliver advertising and track ad performance, and enable advertising networks to deliver ads that may be relevant to you based upon your activities (this is sometimes called "behavioral" or "targeted" advertising) on our sites.
How can you manage and delete cookies?
Almost all browsers use cookies to track your internet use automatically. However, these browsers also allow you to change the settings in your browser to manage your cookie settings to delete any previously sent cookies and to not accept new cookies. Again, please keep in mind that disabling cookies will negatively impact your user experience with our site. Please review your browser's settings and preferences for more information on how to manage and delete cookies. Browsers on mobile devices may have different ways to manage cookie settings.
Technology used on the Internet is constantly changing. The company uses technology standard to the Internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to our website and application.
HOW DO WE RESPOND TO "DO NOT TRACK" SIGNALS?
We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions. You can change your privacy preferences regarding the use of cookies and similar technologies through your browser. For more information on Do Not Track please visit https://www.allaboutdnt.org/.
TRANSFERRING YOUR PERSONAL INFORMATION
We collect, use, and store your personal information in Canada. However, we may use service providers and other third parties we use to support our business who process or store information outside of Canada, including the United States. In accordance with the laws of those countries, in certain circumstances your personal information may be accessible by foreign law enforcement, regulatory bodies or other authorities. These service providers are third parties are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this Policy. Whenever we engage such a service provider or third party, we require that its privacy and security standards adhere to this Policy and applicable Canadian privacy legislation. Please note that we may also transfer your personal information outside of Quebec, including within and outside Canada, depending on the purpose for which we collected it.
CHILDREN'S PRIVACY
We do not knowingly collect any information from children under the age of 18. In addition, our Website and Platform is not designed for use by individuals under the age of 18. If we learn we have collected personal information from a child under 18, we will delete that information, unless we are legally obligated to retain such data. If you have any reason to believe we may have unknowingly collected data from a child under the age of 18, please contact us at privacy@zeromadata.com
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
By law you may have the right to request access to and to correct the personal information that we hold about you.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at: privacy@zeromadata.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
If you have opted in to receive certain emails from us but no longer wish to have your contact information used by Zeroma to promote our own or third parties' products or services or to receive updates regarding our business, you can opt-out by checking the relevant box located at https://zeromadata.com/optout or at any other time by sending us an email stating your request to privacy@zeromadata.com. This opt-out does not apply to information provided to Zeroma as part of a product purchase, warranty registration, product service experience, or other transactions.
If you no longer want your personal information to be included as part of modeled audience segments that Zeroma provides to Advertisers or in any identity graphs under Zeroma’s control, you can opt out by visiting Zeroma’s opt-out page located at: https://zeromadata.com/optout
It may be possible that you have more than one online identifier associated with each browser or device. You can learn more about your options to opt-out of targeted advertising from other identifiers by following the links below:
For UID2: transparentadvertising.org
For The Trade Desk: https://adsrvr.org/
DATA PORTABILITY
You may have the legal right to request that we transfer your personal information to any person or organization authorized by law to collect such information. To request the transfer of your personal information, if applicable, contact us at: privacy@zeromadata.com.
SECURITY OF TRANSMISSION OF PERSONAL DATA AND RISKS RELATED TO THE INTERNET
Our Website and the Platform have security measures in place to help protect against the loss, theft, misuse and unauthorized access, disclosure, alteration and destruction of the information under the company's control.
We seek to use reasonable organizational, technical and administrative measures to protect personal information under our control.
Unfortunately, no data storage system or data transmission over the Internet can be guaranteed to be 100% secure. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures.
ADDITIONAL RIGHTS FOR NEVADA USERS
Under the Nevada Privacy Law (SB220), certain Nevada residents may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.
Zeroma does not sell your personally identifiable information. However, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us at privacy@zeromadata.com.If our policy on selling personal identifiable information changes, we will honor your request.
HOW CAN I CONTACT YOU REGARDING THIS POLICY?
If you have any questions about this Policy, our privacy governance, or our security measures at Zeroma, please contact our Privacy Officer using the information below. You can also reach out to our Privacy Officer if you would like to exercise your rights under applicable privacy law.
Privacy Officer
77 King St West, Suite 400
Toronto, ON M5K 0A1
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