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Privacy Policy

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Effective as of July 7, 2026.

Last updated July 7, 2026.

California Notice at Collection: If you are a California resident, please see the ‘Notice to California residents’ section below for important information about your personal information and privacy rights.

AppZen, Inc. and its subsidiaries and affiliates (“AppZen,” “we,” “us” or “our”) provides AI-powered solutions for automating companies’ finance workflows. This Privacy Policy describes how AppZen processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including, as applicable, our website and social media pages) as well as our marketing and other activities described in this Privacy Policy (collectively, the “Service”). AppZen may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

This Privacy Policy does not apply to information that we process on behalf of our enterprise customers while providing the AppZen services to them. Our use of information that we process on behalf of our enterprise customers may be governed by our agreements with such customers. If you have questions regarding your personal information that we process on behalf of an enterprise customer, please direct your questions to a representative of that specific organization. If you are a representative of an actual or prospective enterprise customer and have questions about our processing of personal information, please reach out to your AppZen business contact or privacy@appzen.com.

Our websites, products and services are designed for enterprise customers and their representatives. We do not offer products or services intended for use by individuals for their personal, familial or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise customer and not their individual capacities.

European Users: Please see the ‘Notice to European users’ section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe,” and “European” should be understood accordingly).

Index

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, salutation, email address, mailing address, professional title and company name, and phone number.
  • Demographic data, such as your city, state, country of residence, postal code, and age.
  • Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

  • Public sources, such as government agencies, public records, and other publicly available sources.
  • Private sources, such as data providers, social media platforms and data licensors.
  • Marketing partners, such as joint marketing partners and event co-sponsors.
  • Service providers that provide services on our behalf or help us operate the Service or our business.
  • Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, content you viewed or otherwise engaged with, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking & other technologies section below.

Tracking & other technologies

Cookies and other technologies. Some automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy.

Chat and artificial intelligence technologies

Chat and other artificial intelligence (“AI”) technologies, such as those provided by Qualified, that employ cookies and software code to operate the chat features that you can use to communicate with us through the Service. Qualified and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats to facilitate the provision of the Service.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

  • provide the Service and operate our business;
  • enable security features of the Service;
  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
  • provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

  • understand your needs and interests;
  • personalize your experience with the Service and our Service-related communications; and
  • remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For example, we may use Google Analytics for this purpose.

Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes.

  • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.
  • Interest-based advertising. We, our service providers, and third-party advertising partners may use cookies and other technologies to collect information about your interaction (including the data described in the Automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that we or they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in our Cookie Policy.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the Service; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We will not re-identify data that we have de-identified and/or anonymized. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

How we share your personal information

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, providers of AI technologies such as online chat tools, consumer research and website analytics).

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of AppZen, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of AppZen as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and other technologies. For more information about cookies and similar technologies employed by the Service and how to manage your preferences, see our Cookie Policy.

Do Not Track. 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” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should also read the information provided about transfers of personal information to recipients outside Europe contained in the ‘Notice to European users’ below.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business. Depending on the kind of change we make to this Privacy Policy, we might notify you of the change or request your consent to it.

Please click here to view the previous version of our Privacy Policy.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you depending upon applicable law, please contact us.

Notice to California residents

This notice describes our collection, use, and disclosure of personal information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to their personal information. For purposes of this notice, “personal information” and “sensitive personal information” have the meanings given in the CCPA but do not include information exempted from the scope of the CCPA.

Your privacy rights. As a California resident, you have the following rights under the CCPA. However, these rights are not absolute and we may decline your request in certain cases as permitted by law.

  • Right to know. You can request the following information about how we have collected and used your Personal Information:
    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with which we share Personal Information.
    • The categories of Personal Information that we sold or disclosed for a business purpose.
    • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
  • Right to access. You can request a copy of the Personal Information that we have collected about you.
  • Right to correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
  • Right to deletion. You can ask us to delete the Personal Information that we have collected from you.
  • Right to opt-out. If we “sell” or “share” your personal information as defined by the CCPA, you can opt-out of such disclosures.
    • Opt-out of certain processing for targeted advertising purposes. We may process Personal Information for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.
    • Opt-out of other sales of personal data. We do not engage in other sales of your Personal Information.
  • Consumers under 16. We do not have actual knowledge that we collect, sell or share the personal information of consumers under 16 years of age.
  • Sensitive Personal Information. We do not intentionally collect or process sensitive personal information.
  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Exercising your right to know, access, correction, and deletion. You may submit requests to exercise your right to know, access, correction, or deletion at https://www.appzen.com/exercise-your-rights or via email to privacy@appzen.com.

Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information. The CCPA may classify certain of our activities, such as our use of interest-based advertising described above, as “selling” or “sharing” your Personal Information. You can submit requests to opt-out of such “sale” or “sharing” of Personal Information here: https://www.appzen.com/exercise-your-rights or via email to privacy@appzen.com. You may be able to opt out of certain “sales” or “sharing” of Personal Information by broadcasting the global privacy control signal.

Verification of Identity; Authorized agents. We may need to verify your identity to process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your California residency. To verify your identity, we may require you to log into an online account if you have one, provide identifiers we can match against information we may have collected from you previously, confirm your request using the email or telephone account stated in the request, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized the Personal Information we collect, the purposes for which we collect it, and the third parties to or with whom we may disclose, sell or share it by reference below to both the categories defined in the “Personal information we collect” section of this Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). The categories of Personal Information and Sensitive Personal Information described below may be collected via any of the sources described in the “Personal information we collect” section and used for any of the purposes described in the “How we use your personal information” section of this Privacy Policy above. This chart describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

Personal Information (“PI”) we collect CCPA statutory category Categories of third parties to whom we “disclose” PI for a business purpose Categories of third parties to whom we “sell” or “share” PI
Contact data Identifiers
Commercial information
California customer records		 Affiliates
Service providers
Third parties designated by you
Partners
Professional advisors
Authorities and others
Business transferees		 Advertising partners
Demographic data Identifiers
California customer records		 Affiliates
Service providers
Third parties designated by you
Partners
Professional advisors
Authorities and others
Business transferees		 Advertising partners
Communications data Identifiers
Commercial information
California consumer records
Internet or Network Information		 Affiliates
Service providers
Third parties designated by you
Partners
Professional advisors
Authorities and others
Business transferees		 Advertising partners
Marketing data Identifiers
Commercial information
California customer records
Internet or Network Information		 Affiliates
Service providers
Third parties designated by you
Partners
Professional advisors
Authorities and others
Business transferees		 Advertising partners
Device data Identifiers
Internet or Network Information		 Affiliates
Service providers
Third parties designated by you
Partners
Professional advisors
Authorities and others
Business transferees		 Advertising partners
Online activity data Identifiers
Commercial information
Internet or Network Information		 Affiliates
Service providers
Third parties designated by you
Partners
Professional advisors
Authorities and others
Business transferees		 Advertising partners
Communication interaction data Identifiers
Commercial information
California consumer records
Internet or Network Information		 Affiliates
Service providers
Third parties designated by you
Partners
Professional advisors
Authorities and others
Business transferees		 Advertising partners
Data derived from the above Inferences Affiliates
Service providers
Third parties designated by you
Partners
Professional advisors
Authorities and others
Business transferees		 Advertising partners
Other Sensitive Personal Information We do not intentionally collect this information, but it may be revealed in identity data or other information we collect Protected Classification Characteristics None None

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact information in the How to contact us section above.

Notice to European users

General

Where this Notice to European users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”). Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect” that is set out above.

Controller. AppZen is the “controller” in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.

Our GDPR Representatives. Pursuant to Article 27 of the General Data Protection Regulation (GDPR), AppZen, Inc has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

  • Where we need to process your personal information in order to deliver the Service to you, or where you have asked us to take specific action which requires us to process your personal information (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see the ‘How we use your personal information’ section above and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above.

Purpose Categories of personal information involved Legal basis
Service delivery and operations Contact data
Demographic data
Communications data
Data from third-party sources
Device data
Online activity data
Communication interaction data		 Contractual Necessity.
Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service (including, where relevant, responding to any contact via any “contact us” feature or similar), our business and associated IT services, systems and networks.
Service personalization Contact data
Demographic data
Communications data
Device data
Online activity data
Communication interaction data		 Legitimate Interests. We have a legitimate interest in providing you with a good service via the Service, which is personalized to you and that remembers your selections and preferences.
Consent, in respect of any optional processing relevant to personalization (including processing directly associated with any optional cookies used for this purpose).
Service improvement and analytics Contact data
Demographic data
Communications data
Device data
Online activity data
Communication interaction data		 Legitimate Interests. We have a legitimate interest in providing you with a good service and analyzing how you use it so that we can improve it over time, as well as developing and growing our business.
Consent, in respect of any optional cookies used for this purpose.
Direct marketing Contact data
Demographic data
Communications data
Device data
Online activity data
Communication interaction data		 Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose.
Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Interest-based advertising Contact data
Demographic data
Communications data
Device data
Online activity data
Communication interaction data		 Consent.
Compliance and protection Any and all data types relevant in the circumstances Compliance with Law.
Legitimate Interests. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety.
Data sharing in the context of corporate events Any and all data types relevant in the circumstances Legitimate Interests. We have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations).
To create aggregated, de-identified and/or anonymized data Any and all data types relevant in the circumstances Legitimate Interests. We have legitimate interest in taking steps to preserve the privacy of our users.
Further uses Any and all data types relevant in the circumstances The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected.
Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or otherwise for the ‘Compliance and protection’ purposes outlined above.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information that we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other information

No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time.

No sensitive information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic other than as requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide us with any such sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We provide our analysis to our business customers and our business customers make decisions that may affect you.

Your additional rights

General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
  • Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
  • Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
  • Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by contacting us. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

Data Processing outside Europe

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

  • Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
  • Transfers to territories without an adequacy decision.
    • We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S.).
    • However, in these cases:
      • we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
      • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

Data Privacy Framework

The Data Privacy Framework (“DPF”) was developed by the US Department of Commerce and the European Commission to provide the US based organizations with a reliable mechanism for Personal Information transfer from the EU to the US. The European Commission’s adequacy decision for the EU-U.S. DPF entered into force on July 10, 2023, which allows the transfer of EU Personal Information to US to the participating organizations.

AppZen complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), and the UK Extension to the EU-U.S. DPF, and the Swiss-US DPF as set forth by the U.S. Department of Commerce. AppZen has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.

AppZen has certified to the U.S. DOC that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Information received from Switzerland in reliance on the Swiss-U.S. DPF. In case of a conflict between the terms of this Privacy Policy and the principles of the DPF, the principles of the DPF shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit Data privacy framework website (https://www.dataprivacyframework.gov/).

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

AppZen’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, AppZen remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless AppZen proves that it is not responsible for the event giving rise to the damage.

For Queries/ Complaints:

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, AppZen commits to resolve to the DPF Principles-related complaints about our collection and use of your Personal Information. The EU, UK and Swiss individuals with inquiries or complaints regarding our handling of Personal Information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact AppZen at: privacy@appzen.com.

For independent recourse mechanism for non-HR (human resources) data:

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, AppZen commits to refer unresolved complaints concerning our handling of Personal Information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to BBB National Programs, an alternative dispute resolution provider, based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information or to file a complaint. The services of BBB National Programs are provided at no cost to you.

For independent recourse mechanism for HR (human resources) data:

In compliance with the UK Extension to the EU-U.S. DPF, AppZen commits to cooperate and comply respectively with the advice of the panel established by the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the UK Extension to the EU-U.S. DPF in the context of the employment relationship.

Choice/ opt-out mechanism:

You may choose to opt-out of (i) disclosure of your Personal Information with a third party engaged by AppZen and/or (ii) usage of your Personal Information for a purpose that is different from the original purpose for which Personal Information was collected. Please write to us on privacy@appzen.com to exercise your choice/ to opt out.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

Contact the US Enforcement Authority:

AppZen is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC), and you may submit your complaint to the FTC on https://reportfraud.ftc.gov/.