ZENVOICE PRIVACY POLICY
ZENVOICE
Introduction
Zennio Avance y Tecnología S.L. (“Zennio“, “we/us”, “the Company”) is committed to protecting the privacy of all users (“You/r”, the “User”) of our ZenVoice Services (“ZenVoice Services“, “Service/s”). This Privacy Policy explains our practices regarding the use of personal data collected and processed through ZenVoice (“ZenVoice”) and is part of our Terms of Service.
1. DATA CONTROLLER.
The entity responsible for your data is Zennio Avance y Tecnología S.L., with Tax Number B45586724, domiciled in Río Jarama, 132. Nave P-8.11, 45007, Toledo, España. All communications regarding the processing of your personal data shall be directed to info@zennio.com.
2. PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE USE IT
For ZenVoice, we collect the following data as Data Controller:
| Data collected | Legitimate basis | Purpose |
| User Data: Username (Email) Address for User verification. We use this information to access ZenVoice Services and register your paired devices. This information is not shared with third parties without your permission. | Legitimate Interest for our business, in conducting and managing our business to give you the best service/product and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interest, and we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). | Providing services to Active Users. |
3. DATA ACCURACY
It is important that the personal data we have about you is accurate and current. You are responsible for the accuracy of the information you provide to Us, and You are expected to update the information you provide to us.
4. DATA USE
General. We use your personal data to:
- Provide ZenVoice Services.
- Perform an internal analysis of operations and users to improve our service according to the preferences of the Users using the app. This analysis is anonymous.
- Comply with the legal, administrative, or judicial obligations to which we are subject.
5. DATA DISCLOSURE
We process your personal data confidentially in accordance with the applicable legislation. Unless stated otherwise, your personal data will not be provided to third parties.
Specifically, we disclose your data as follows:
- We can give access to your personal data to our service providers under contracts for the provision of services in favour of the company.
- Refer to the corresponding Addendum for your smart speaker and/or mobile device to learn about the third parties with whom your data is shared.
- Among the others, Amazon Web Services for the provision of email service. We require that all third parties respect the security of your personal data and treat them in accordance with the law. We do not allow our external service providers to use your personal data for their own purposes and we only allow them to process your personal data for specific purposes and in accordance with our instructions.
- We can make the personal data available to any company interested in buying or buying the Company or a part of your business and, consequently, give access to any national or international auditors to carry out their “due diligence”.
- We can make the data available to the authorities to investigate suspicions of fraud, harassment or other violations of any law, rule or regulation, or the policies of the website.
6. DATA RETENTION
We only keep your personal data for as long as it is necessary to fulfil the purposes for which we have collected them, even to comply with legal, accounting or information requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, if we can achieve those purposes through other means and the applicable legal requirements.
7. INTERNATIONAL TRANSFERS (THIRD PARTY SERVICE PROVIDERS)
We use third-party technology services for providing our ZenVoice Services. These entities may be located in jurisdictions that generally do not provide adequate safeguards in relation to the processing of personal data. For all entities that are not part of the European Economic Area (EEA), we have signed contracts with those entities that do include such safeguards, including the European Commission’s model clauses.
Please refer to the corresponding Addendum for your smart speaker and/or mobile device to learn about the third parties with whom your data is shared.
We implement security measures and personal data protection schemes as required by law to maintain the confidentiality, availability and integrity of your data and protection against unauthorised access, modification, or destruction.
8. YOUR RIGHTS
You have rights under data protection laws in relation to your personal data. Specifically, you have the right to access, correct, request erasure, object to processing, request portability and restrict processing and for any processing that is based on your consent, you may withdraw that consent.
You also have the right to make any complaint to the competent authority, in this case the Spanish Data Protection Agency (AEPD), C/. Jorge Juan, 6, 28001 Madrid, Spain, but please contact us first.
The aforementioned rights may be effective by contacting us at info@zennio.com.
9. GENERAL
We reserve the right to amend the terms of this Privacy Policy and will notify you by providing a clear notice of these changes by email or on our ZenVoice service, and in this Privacy Policy. If you continue to use our Services after such update, you will be deemed to accept the new terms. If you do not accept the update, please terminate your account, or notify us and we will terminate your Account and remove any of your personal data (except as required to be maintained for legal purposes), and you will not be able to continue to use our Services.
Unless a specific local regulation sets forth to the contrary, the Privacy Policy is governed by the laws of Spain.
Version 2: June 14th 2022
Schedule I
Special Terms of Privacy Policy
ZenVoice
Amazon Alexa
1. International Transferences
Zennio uses third-party technology services for providing our ZenVoice Services. These entities may be located in jurisdictions that generally do not provide adequate safeguards in relation to the processing of personal data. For all entities that are not part of the European Economic Area (EEA), we have signed contracts with those entities that do include such safeguards, including the European Commission’s model clauses.
Amazon
The global structure of the servers and the location of the services offered by Amazon is categorized in 4 (four) different areas, where each one consists of different regions, that is, physical locations where its data centers are installed. Each region is supported by multiple edge locations, data centers that do not belong directly to Amazon, but to a trusted partner of the entity. These servers are directly connected to the Amazon Network Services.
The implementation of an Alexa skill involves the implicit use of an AWS Lambda, a server where the code is executed only when it is used. Zennio cannot be sure where Amazon stores the information, we can only know the different servers that consist and their locations. A map with the different regions and a more complete map with regions and edge locations is shown in https://aws.amazon.com/es/about-aws/global-infrastructure/?p=ngi&loc=0.
| Entity | Service | Territory | Legal |
| Amazon (Amazon EU Core Sarl) | Alexa Services (virtual assistant) Databases hosting. | EU, U.S.A. + others |
|
Schedule II
Service Information and personal data control
Amazon Alexa
1. Amazon Alexa Services
Alexa is a virtual assistant developed by Amazon; it is an Artificial Intelligence (AI) service.
Echo is the physical device used to interact with the assistant.
2. Amazon Alexa data controller
Amazon Europe Core SARL, Amazon EU SARL, Amazon Services Europe SARL and Amazon Media EU SARL, all four with addresses at 38 Avenue John F. Kennedy, L-1855, Luxembourg, and Amazon Digital UK Limited, with addresses at 1 Principal Place, Worship Street, London, EC2A 2FA, United Kingdom (collectively, “Amazon Europe”) are responsible for the processing of personal information collected and processed through the Amazon Services. More information can be found here.
3. Amazon Alexa SKILLS
Skills are voice-controlled features of Alexa. Amazon handles any personal information it receives through Alexa in accordance with Amazon’s Privacy Notice. Thus, when a User speaks to Alexa, a recording of what the User has asked Alexa is sent to Amazon’s servers so that its speech recognition and natural language understanding systems can process and respond to the request.
Accordingly, each time your ECHO device detects the activation word, a visual or audible indicator will tell you that it is recording audio to transmit to the cloud. You will be able to review and delete voice recordings associated with your account (including any audio resulting from unintentional activations) in your Voice History available in the Alexa app under Settings > Alexa Privacy or https://www.amazon.es/configuraciondeprivacidaddealexa.
4. Alexa Training
Amazon also uses your requests to Alexa to train its natural language recognition and understanding systems through machine learning. You can manage the use of your voice recordings in the Alexa app under Settings > Alexa Privacy > Manage how your data helps us improve Alexa. You can also review your voice recordings associated with your account, manage their use for new feature development, and delete them individually, by date, or all at once in Settings > Alexa Privacy in the Alexa app or at https://www.amazon.es/configuraciondeprivacidaddealexa. And you can delete all voice recordings associated with your account for each of your devices with integrated Alexa and apps at once in “Manage content and devices”.
5. Delete functionality
You can also enable the voice delete functionality for your recordings. Once enabled, you can delete the voice recording of your last request by saying “Alexa, delete what I have just said” or delete all voice recordings from your account that day by saying “Alexa, delete everything I said today”. To enable the delete by voice functionality go to Settings > Alexa Privacy > Query Voice History in the Alexa app or at https://www.amazon.es/b/?node=17136920031#nav-top. When this option is enabled, anyone with access to your devices with built-in Alexa can ask Alexa to delete voice recordings from your account.
You should also be aware that, if your request was processed by Alexa Skill ZenVoice, deleting your voice recording from Amazon does not delete the information retained by the Skill developer “Zennio” (the Skills developers do not receive voice recordings).
6. Third Party Skills (ZenVoice)
If you use a third-party service through Alexa, Alexa will exchange relevant information with those third parties so that they can provide the service to you. For example, if you interact with Alexa Skill ZenVoice, Alexa will provide the content of your request (but not the recording of your voice) to the Skill so that it can respond appropriately.
Zennio can receive from Amazon aggregated data about the use of its ZenVoice Skill. For example, Zennio can access usage information about how many users are using the application, in which geographic regions they are located and basic data, including users’ language, device type, and duration and frequency of use. None of the information Zennio receives from Amazon identifies you, nor does it reveal to Zennio what information was sent to the ZenVoice Skill or what specific responses the application sent.
IMPORTANT: BY USING THE ALEXA SKILL ZENVOICE YOU ACKNOWLEDGE AND AGREE THAT YOU ARE GIVING ALEXA ACCESS TO ALL INFORMATION THAT YOU AND THE SKILL EXCHANGE. THIS INFORMATION WILL BE PROCESSED BY ALEXA, OWNED BY AMAZON, IN ACCORDANCE WITH THE DATA PROTECTION AND PRIVACY POLICY THAT YOU AGREED TO WHEN YOU SIGNED UP FOR IT AND WHICH YOU CAN SEE AT:
Alexa Terms of Use:
https://www.amazon.com/gp/help/customer/display.html?nodeId=201809740
Privacy Notice:
https://www.amazon.com/gp/help/customer/display.html?nodeId=468496
On the other hand, the development of an Alexa Skill involves an agreement between the developer or entity and Amazon services. This contract or agreement is available on the web:
https://developer.amazon.com/de/support/legal/da
Schedule III
Special Terms of Privacy Policy ZenVoice
Google Actions
International Transferences
Zennio uses third-party technology services for providing our ZenVoice Services. These entities may be located in jurisdictions that generally do not provide adequate safeguards in relation to the processing of personal data. For all entities that are not part of the European Economic Area (EEA), we have signed contracts with those entities that do include such safeguards, including the European Commission’s model clauses.
The global structure of the servers and the location of the services offered by Google is distributed around the world, so your information may be processed on servers outside the country where you live. Google applies the same protection measures contained in its Privacy Policy.
| Entity | Service | Territory | Legal |
| Google Ireland Limited | Actions on Google (virtual assistant) | EU, U.S.A. + others |
|
Amazon
The global structure of the servers and the location of the services offered by Amazon is categorized in 4 (four) different areas, where each one consists of different regions, that is, physical locations where its data centers are installed. Each region is supported by multiple edge locations, data centers that do not belong directly to Amazon, but to a trusted partner of the entity. These servers are directly connected to the Amazon Network Services.
The implementation of an Alexa skill involves the implicit use of an AWS Lambda, a server where the code is executed only when it is used. Zennio cannot be sure where Amazon stores the information, we can only know the different servers that consist and their locations. A map with the different regions and a more complete map with regions and edge locations is shown in https://aws.amazon.com/es/about-aws/global-infrastructure/?p=ngi&loc=0
| Entity | Service | Territory | Legal |
| Amazon (Amazon EU Core Sarl) | Alexa Services (virtual assistant) Databases hosting. | EU, U.S.A. + others |
|
Schedule IV
Service Information and personal data control
Google Assistant
Google Actions Services
Google Assistant is a virtual assistant developed by Google; it is an Artificial Intelligence (AI) service.
- Google data controller
Google Ireland Limited with registered office at Gordon House, Barrow Street, Dublin 4, Ireland is the controller of the personal information collected and processed through the Google Assistant services. More information can be found here.
- Google Assistant Actions
Actions are voice-controlled features of Google Assistant. Google handles any personal information it receives through Google Assistant in accordance with Google Privacy Policy. Thus, when a User speaks to Google Assistant, a recording of what the User has asked Google is sent to Google’s servers so that its speech recognition and natural language understanding systems can process and respond to the request.
Accordingly, each time your device detects the activation word, a visual or audible indicator will tell you that it is recording audio to transmit to the cloud.
-
Delete functionality
You can review and delete the voice recordings associated with your Google Account (including any audio resulting from unintentional activations) in your Voice History available on the Assistant Activity page of your Google Account.
Find the activity you want to delete. (Tip: Filter by date at the top of the page.) Tap More More and then Delete. To delete all activity repeat the same procedure by selecting “Delete activity by” option from ever. For more information here.
5. Third Party Actions (ZenVoice)
If you use a third-party service through Google Assistant, Google Assistant will exchange relevant information with those third parties so that they can provide the service to you. For example, if you interact with ZenVoice Action, Google Assistant will provide the content of your request (but not the recording of your voice) to the Action so that it can respond appropriately.
Zennio can receive from Google aggregated data about the use of its Google Actions. For example, Zennio can access usage information about how many users are using the application, in which geographic regions they are located and basic data, including users’ language, device type, and duration and frequency of use. None of the information Zennio receives from Google identifies you, nor does it reveal to Zennio what information was sent to the Google Action or what specific responses the application sent.
IMPORTANT: BY USING THE ZENVOICE ACTION YOU ACKNOWLEDGE AND AGREE THAT YOU ARE GIVING GOOGLE ACCESS TO ALL INFORMATION THAT YOU AND THE ACTION EXCHANGE. THIS INFORMATION WILL BE PROCESSED BY GOOGLE, IN ACCORDANCE WITH THE DATA PROTECTION AND PRIVACY POLICY THAT YOU AGREED TO WHEN YOU SIGNED UP FOR IT AND WHICH YOU CAN SEE AT:
Google Assistant Terms of Use:
https://policies.google.com/terms?hl=en
Privacy Notice:
https://policies.google.com/privacy?hl=en