Privacy Policy

Introduction

This privacy policy is designed to inform users of our proprietary RetroacDev tax credit calculation platform, including the web application and website available at app.retroacdev.com and retroacdev.com, respectively, all sub-sites and micro-sites controlled by us, and any related smartphone or mobile application (collectively, the “Service”) about how Zagaran, Inc. (“Zagaran”, “we” or “us”) gathers and uses personal information submitted to Zagaran through the Service. Zagaran will take reasonable steps to protect user privacy consistent with the guidelines set forth in this policy and with all applicable U.S. laws. In this policy, “user” or “you” means any person viewing the Service or submitting any personal information to Zagaran in connection with using the Service.

By accessing our website or using the Service, or by otherwise providing us with your personally identifying information, you are accepting the practices and policies described in the Privacy Policy. Our Privacy Policy may change from time to time, and any changes will be posted on this page, and if the changes are significant, we will provide a more prominent notice. If you have questions or concerns regarding the Privacy Policy, you should first contact us at info@retroacdev.com.

Our Privacy Policy does not apply to services offered by other companies or individuals, including third party services used by Zagaran. For these third party services, we encourage you to familiarize yourself with the applicable third party privacy policies.

What Information Do We Collect?

Personal Information: If you sign up to create an account, we may ask you for certain personal information for the account, including the name of the individual creating the account, business email address, business phone number, company name, and payment information such as credit card number (the “Personal Information”). In addition, if you contact Zagaran and disclose additional personal information, we may store that Personal Information.

User Data: When you use the Service, you may transmit to Zagaran certain user-specific data (collectively, “User Data”) that we use to provide the Service, including to but not limited to Import Data (as defined below) and other data relating to your operating and systems environment, your use of the Service, and any additional information that the Service allows you to input, such as data relating to your employees and contractors, questions you answer to describe your research and development projects, and any feedback or questions you send us.

Import Data: Without limiting the above, you authorize Zagaran to collect the data you import or make available from (a) the compatible online source code management platform you have provided Zagaran access to, which compatible platforms currently include GitHub and BitBucket (your “Connected Platform”), and (b) your personal computer (all such data, “Import Data”). When you link your Connected Platform account, we collect and store your username (but never your password), and the repository name and organization name of repositories you have access to. When you choose to import data from a repository, we collect and store all submitted code changes (“Commits”) including, for each commit: the author’s username and email address; the submission date and time; the Commit message; and the name of the file(s) that were changed and the number of lines added and subtracted to each file. We do not access or collect the actual source code from any repository; provided that, for BitBucket users only, we read (but do not store) the actual lines of code changed in each commit (the “commit diff”) solely for the purposes of counting the number of lines changed and of cryptographically hashing the total diff to establish whether two commits are the same.

Web Tracking Information: We, and third party service providers (including Google Analytics) that we engage to provide services to us (“Contractors”), may use web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Service efficiently and to collect data related to usage of the Service. Such collected data (“Web Tracking Information”) may include the address of the websites you visited before and after you visited the Zagaran website, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Service you visit and what links you clicked on, and whether you opened email communications we send to you. In order to collect Web Tracking Information and to make your use of the Service more efficient, we may store cookies on your computer. We may also use web tracking technologies that are placed in web pages on the Service or in email communications to collect information about actions that users take when they interact with the Service or such email communications, and our Contractors may also do so. We do not correlate Web Tracking Information to individual user Personal Information. Some Web Tracking Information may include data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Service, but this may affect the performance of the Service.

How Do We Use the Information We Collect?

Personal Information: We will use and store Personal Information for the purpose of delivering the Service (including to establish or renew your RetroacDev account), and to analyze and enhance the operation of the Service. We may also use Personal Information for the internal operational and administrative purposes of the Service. We may enter Personal Information into our contact management database, and may use such database to send you marketing materials and to contact you regarding your interest in Zagaran products and services.

User Data: We will use the User Data (including the Import Data) to provide the Service. We may aggregate User Data across all or a subset of users to create statistical information relating to the use of the Service, as described in “Aggregate Information” below.

Aggregate Information: We will also create statistical, aggregated data relating to our users and the Service for analytical purposes. Aggregated data is derived from Personal Information and User Data but in its aggregated form it does not relate to or identify any particular client or individual or any specific user’s data. This data is used to understand our customer base and to develop, improve and market our services.

Web Tracking Information: We use Web Tracking Information to administer the Service and to understand how well our Service is working, to store your user preferences, and to develop statistical information on usage of the Service. This allows us to determine which features users like best to help us improve our Service, to personalize your user experience, and to measure overall effectiveness.

Legal Exception: Notwithstanding the above, Zagaran may use Personal Information and User Data to the extent required by law or legal process, or if in Zagaran’s reasonable discretion use is necessary to investigate fraud or any threat to the safety of any individual, to protect Zagaran’s legal rights or to protect the rights of third parties.

What Information Do We Disclose to Third Parties?

Zagaran’s Disclosure of Personal Information: Zagaran will not disclose Personal Information to any third party except to our Contractors who are bound by written obligations of confidentiality, or as described under “Permitted Disclosures” below.

User Data: We only disclose User Data to any of the user accounts for your company that you establish via your account. Except as described above, we disclose User Data only to you, the user who submitted the User Data to Zagaran, to our Contractors who are bound by obligations of confidentiality, and as described under “Permitted Disclosures” below.

Web Tracking Information: We disclose Web Tracking Information to Contractors, in order to analyze the performance of the Service and the behavior of users, and to operate and improve the Service.

Aggregate Information: We may disclose aggregated data that does not contain Personal Information that identifies any particular user or person to any third parties, such as potential customers, business partners, advertisers, and funding sources, in order to describe our business and operations.

Permitted Disclosures: Notwithstanding the foregoing, Zagaran reserves the right to disclose any information Zagaran collects in connection with the Service, without further notice to you (a) to any successor to Zagaran’s business as a result of any merger, acquisition or similar transaction; and (b) to any law enforcement, tax, or regulatory authority to the extent required by law or if, in Zagaran’s reasonable discretion, disclosure is necessary to investigate fraud or any threat to the safety of any individual, to protect Zagaran’s legal rights or to protect the rights of third parties.

How Can You Opt Out of Use and Disclosure of Your Information?

If you would like your Personal Information removed from our mailing list or database, please contact us at info@retroacdev.com. In the event of any such removal, Zagaran may retain copies of information for its archives.

Access and Updating of Information

You can update your Personal Information by using the profile editing tools on the Service. Zagaran will respond to any reasonable request by a user to review or amend his or her Personal Information held in our mailing list or database. Zagaran reserves the right to verify your identity in order to provide such access. Please contact us by sending an email to info@retroacdev.com.

Security: We use reasonable security precautions to protect the security and integrity of your Personal Information and User Data in accordance with this policy and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

Links: The Service may contain links to other websites. Zagaran is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our site and review the privacy statements of each Web site they visit that collects information. This Privacy Policy applies solely to personal information collected by Zagaran.

Amendments: Zagaran may modify or amend this policy from time to time. If we make any material changes, as determined by Zagaran, in the way in which Personal Information or User Data is collected, used or transferred, we will notify you of these changes by modification of this Privacy Policy, which will be available for review by you at the Service.

Service Visitors from outside the United States: Zagaran and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access the Service, you consent to the use and disclosure of information in accordance with this privacy policy and subject to such laws.

Terms of Use: This policy forms part of, and is subject to, the provisions of Zagaran’s Terms of Service.

Effective Date of this policy: July 20, 2017




Privacy Policy ©2016-2018 Zagaran, Inc.