Privacy Policy

Effective as of July 1, 2020

Welcome to  Zestful, Inc. (“Company,” “us,” or “we”) takes the privacy and protection of personal information very seriously. This privacy policy (“Privacy Policy”) discloses Company’s privacy practices for information collected by Company through (the “Site”), the mobile application (the “App”), and the services offered via the Site and the App (collectively, the “Services”). The Services provide companies (“Employers”) a simple and fun way to keep its employees connected and engaged through the development of team-based goals (each a “Goal”) and awarding points when employees complete such goals that can be redeemed by employees for prizes (each a “Prize”). Your Account (defined below) may be connected to your existing Zestful account. For more information on our privacy practices with respect to Zestful Services, see Some points and Prizes may be redeemable for different products and services provided and/or fulfilled by various third-party merchants (“Merchants”).  

What This Privacy Policy Covers

This Privacy Policy covers our collection, use and disclosure of the Personal Information and Anonymous Information we collect through the Services.

Personal Information We Collect

Information You Provide to Us

Information We Obtain from Your Employer

We will collect your full name, date of birth, work anniversary, and the group or team you are a part of (if applicable) from your Employer to verify your Account and optimize your use of the Services.

Information We Obtain from Social Media Platforms

We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your Personal Information. You or the platforms may provide us with Personal Information through the platforms, and we will treat such Personal Information in accordance with this Privacy Policy.

We offer the ability to sign into our Services via Facebook Single Sign-On. This service will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and e-mail address to pre-populate our sign-up form. We may add this information to the information we have already collected from you via the Services.

Information Collected via Technology

As you use the Services through our Site and/or App, certain information may also be collected passively about you, your computer, or mobile device, and activity occurring on or through the Services, including but not limited, your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), mobile network information which may include your mobile phone number, browser type, screen resolution, Internet Protocol (IP) address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. This information may be associated with your Account and used to customize the Services for you. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

Company also stores a small text file called a “Cookie” on your computer to store your login information (if any) and your personal preferences for the Services. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). In our App, we may collect this information directly or through our use of third-party software development kits (“SDKs”). A SDK is third-party computer code that we may incorporate into our App that may be used for a variety of purposes, including to provide us with analytics regarding the use of our App, to integrate with social media, add features or functionality to our App, or to facilitate online advertising. SDKs may enable third parties to collect information directly from our App.

Since the foregoing information may be collected when you are signed into the Services, this information may be associated by us with Personal Information that we have collected from you.

Our third-party advertising and web analytics partners use Cookies as well as a software technology called clear gifs (a.k.a. Web beacons/Web bugs), that help us better manage content on our Site by informing us what content is effective as well as managing our advertising on other websites. Clear gifs are tiny graphics with a unique identifier, similar in function to Cookies, and are used to track the online movements of website users. In contrast to Cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on website pages and are about the size of the period at the end of this sentence. The information gathered by clear gifs is not tied to your Personal Information.

We also have third parties, with whom we partner to provide certain features on our Site or to display advertising based upon your browsing activity, that use Flash Cookies to collect and store information. Flash Cookies are different from browser Cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies click here.

Our advertising partners may use Cookies and Web beacons to collect information about your activities on this Site and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for advertising associated with your mobile device.

Use of Information We Collect

We use the Personal Information you provide to:

We may create Anonymous Information records from Personal Information by excluding information (such as your name) that makes the information personally identifiable to you. We may also create Anonymous Information regarding how you use the Services. We may use this Anonymous Information for internal purposes, such as analyzing usage patterns so that we may enhance the Services and promote our business, and we also reserve the right to use and disclose any Anonymous Information at our discretion.

If you provide feedback, such as questions or comments about the Services, to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy.

Disclosure of Personal Information

Except as otherwise stated in this Privacy Policy, we do not disclose to, or share your Personal Information with third parties, unless you ask or authorize us to do so. We do not sell, rent or otherwise provide your Personal Information to any third parties for their marketing purposes.

We may provide your Personal Information to third party service providers and suppliers who work on behalf of or with us to provide you with some of the services and features of the Services and to help us communicate with our users (such as the processing of payments, the submission of e-mail communications on Company’s behalf and the providing of customer service). However, these service providers and suppliers do not have any independent right to use this information except to help us provide the Services.

Employers will be able to track your use of the Services. Account administrators (“Administrator(s)”) are able to assign you to certain teams (each a “Team”) within the Services. When you use the Services, the information you provide may be shared with the third parties that you, your Employer, or Administrators designate to receive such information in accordance with your Account settings (which may be set by Administrators). You may change your Account settings at any time by going to your Account and changing the settings or contacting an Administrator.

Without limiting the foregoing, your Employer, Administrators, and any member of your Team(s) may be able to see any content you post to the Services, Goals you complete, points you have earned, and Prizes you have received, and the Merchants from whom you have redeemed Prizes, in each case depending on your Account settings, which may be set by your Employer and/or an Administrator. As a result, you should be cognizant of what content you post to the Services.  Team level data will be displayed to the Employer (and Administrator), but the Employer can also compare individuals to their Team. Administrators will be able to see and edit information in your Account and/or content posted by you to the Services, change your Account privileges, and observe your Account activity. Your Employer and/or the Administrator(s), and not, Company is responsible for any use by the Employer or the Administrator(s) of your information.

We may share information with Merchants as reasonably necessary for the fulfillment of prizes and any use by such Merchant’s of your information will be subject to the Merchant’s privacy policy.

We may share information with third parties who are not Merchants or Employers. For example, to process our payments with Merchants, we may share some of your information with the Merchants’ payment processing companies.

If you have enabled features or functionality that allow you to sign-up for the Services to a third-party platform or social media network (such as by utilizing single sign-on authentication), we may disclose the Personal Information with such third-party platform or social media network that you authorize us to share. We do not control such third-party platform’s or social media network’s use of your Personal Information.

Although we currently do not have a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), we may in the future. We may share some or all of your Personal Information with these Affiliates, in which case we will require our Affiliates to honor this Privacy Policy.

In the event Company goes through a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition by another company, sale of all or a portion of its assets, reorganization, or in the event of bankruptcy or dissolution, we may sell, transfer or otherwise share some or all of your Personal Information, in connection with a business transaction.

We may disclose your Personal Information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

We may also disclose Personal Information: as required by law, such as to comply with a subpoena, or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights, protect your or others’ rights, privacy, safety, or property (including by making and defending legal claims); to enforce our Terms of Service; to protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; to respond to a government request; or to any other third party with your prior consent to do so.

With your consent we may post your testimonial along with your name on our Site.

Access and Choices Regarding Personal Information

Individuals who seek access to, or seek to correct, amend, or delete inaccurate information should review their Account information or direct their query to Company by emailing us at

Your Information Choices

You can:

Because your Employer and/or Administrators might have control over your Account information, Account settings, and/or content you post to the Services, you should contact your Employer and/or Administrator in the event you want to request any change to these items that you are not able to do via the Account settings or your Account page.

Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us through the Site or App, or by emailing us at

We may send you service-related announcements (such as, but not limited to, notice that we have changed the Services, our Terms of Service, or our Privacy Policy) when we believe it is necessary to do so. You may not opt-out of these communications, which are not promotional in nature, but if you do not wish to receive these announcements, you have the option to close your Account.

You understand that any termination of your Account may involve deletion of your Account information from our live databases and all the information and data stored for such Account in the Services. If you are a resident of the European Union and you terminate your Account, upon your written request, we will delete your contact information from our records, and retain only Anonymous Information about your use of our Services.

When we delete information that we have collected from or about you, it will be deleted from our active databases but may remain in our archives as Anonymous Information.

Most browsers let you remove or reject Cookies. To do this, follow the instructions in your browser settings. Many browsers accept Cookies by default until you change your settings. Please note that if you set your browser to disable Cookies, the Site may not work properly. Similarly, your browser settings may allow you to clear your browser web storage. While you will still be able to use the Services if you disable Cookies in your browser, certain parts of the Services may not function as effectively.

If you wish to update or delete your testimonial, you can contact us via

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit

Where we are required by law to collect your Personal Information, or where we need your Personal Information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.

Data Retention

We will retain the personal data we process for as long as needed to provide our Services to you and to maintain compliance with our agreements with Employers and Merchants. We will retain and use this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Links to Other Websites

The Services may contain links to other websites, mobile applications, and other online services that are not owned, controlled, or operated by Company. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We have no control over, do not review, and are not responsible for the privacy policies of or content displayed by such other websites, mobile applications, or online services, or of your Employer, Merchants, or any other third party. Please be aware that the terms of the Privacy Policy do not apply to any outside websites, mobile applications, or online services or to the treatment of your Personal Information by your Employer, Merchants, or any other third party. Other websites, mobile applications, and online services follow different rules regarding the collection, use, and sharing of your Personal Information. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use as well as the privacy policies of your Employer and any Merchants with whom you interact via the Services.

Personal Information of Children

The Services are not directed to, and we do not knowingly collect or maintain Personal Information from anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us.


The security of your Personal Information is important to us. We employ commercially reasonable and appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect. However, security risk is inherent in all internet and information technologies and no company, including Company, can fully eliminate security risks associated with Personal Information.

International Data Transfers

We are headquartered in the United States and your Personal Information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Notice to EU Citizens

Although we do not market the Services to Employers based in the European Union (“EU”), certain Employers may have potential users of the Services who reside in EU and, as a result, we may process personal data of EU residents. In these cases, we will, upon request of the Employer, enter into a data processing addendum with such Employer.

Changes in this Privacy Policy

This Privacy Policy is subject to occasional revision. We will post any revised version of the Privacy Policy on this page. If we make any material changes to it, we will post the modified Privacy Policy on our website. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Services. You agree that such amended Privacy Policy will be effective thirty (30) days after being posted, and your continued use of the Services after that time shall constitute your acceptance of the amended Privacy Policy.

Contact Us

If you have any questions or suggestions regarding our Privacy Policy, please contact us by sending us an e-mail to