Introduction

Zenoo is committed to providing its customers with a highly secure and reliable environment for our hosted and cloud-based applications. We have therefore developed a multi-tiered security model that covers all aspects of hosted and cloud-based Zenoo systems. The security model and controls are based on international protocols and standards and industry best practices.

As part of the company’s focus on security issues, Zenoo created Cloud Services team with responsibility for:

• Applying the security model to all system tiers
• Monitoring and analyzing the infrastructure for suspicious activities and potential threats
• Issuing periodic security reports to Zenoo management and customers
• Dynamically updating the security model and addressing new security threats
• In addition, the Zenoo Security team is dedicated to:
• Systematically examining the organization's information security risks, taking into account threats and vulnerabilities
• Designing and implementing a coherent and comprehensive suite of information security controls and/or other forms of risk treatment (such as risk avoidance or risk transfer) to address the risks that are deemed unacceptable
• Adopting an overarching management process to ensure that the information security controls continue to meet the organization's evolving information security needs

Operational and Information Security Protocols

Operating System

Operating systems used in the cloud are hardened according to best practices in the industry. Only services and components that are necessary to support the application stack are activated; the administrator user always has a password set up, and only necessary ports in the firewall are open.

Network Security

Firewalls: Applications in cloud have firewalls installed to shield them from attack and prevent the loss of valuable customer data. The firewalls are configured to serve as perimeter firewalls to block ports and protocols.

Network-Based Intrusion Detection and Prevention

The combination of an intrusion detection system (IDS) and intrusion prevention system (IPS) installed and tracks all illegal activities. The system sends real-time alerts and proactively blocks communication once a suspicious attack is discovered. The system performs various activities on the network: log collection and analysis from the various machines (firewalls, switches, and routers), file integrity checking, and rootkit detection.

Data Elimination

Zenoo has strict procedures and a unique policy for handling obsolete data. These procedures are also applied if a customer decides to stop using our software. Disks and tapes are destroyed once they are no longer needed. Tapes are overwritten with the next use. CDs that are no longer needed are destroyed by a CD/DVD data crusher or shredder. All storage devices that may need to be used again are cleaned by data wipe software.

Backup

On a regular basis, Zenoo performs system backups to back up application files, database files, and storage files. All backup files are subject to the privacy controls in practice at Zenoo. The restore procedures are tested on an ongoing basis to ensure rapid restoration in case of data loss.

Application Security

Development Life Cycle and Maintenance

Zenoo implements a number of practices to keep each stage of the software development life cycle secure. These include:

• Planning – During the planning stage, the Zenoo Head of Technology submits a report specifying the product’s security requirements. The report includes the security requirements covering all of the solution components, such as the application, the database, and the client side. To manage security issues optimally, the Zenoo Head of Technology uses various methods, such as access control, auditing, and monitoring.
• Design and Development – The Zenoo Head of Technology verifies that the design and development of the product are based on our security guidelines. Other security issues are addressed by an additional security-gap requirements document. The security code review is tested on security-sensitive parts of the application.
• Implementation, Testing, and Documentation – Unit, integration, and system testing confirm that security requirements are properly implemented. The requirements are documented and become standard policy.
• Deployment and Maintenance – The Zenoo Head of Technology is responsible for identifying, managing, and minimizing security vulnerabilities.

Access Control

The following items are relevant for access control:

• Access control – Access to the infrastructure is limited, based on role and responsibility and is only available to Operations and Professional Services for maintaining and supporting customers.
• Authentication – Zenoo also enforces a strict role based password policy that applies to both layers - the operational team members and the application's users. Passwords are stored in an encrypted form, using a one-way encryption method based on an industry-standard hash algorithm. Only the application is able to compare the hashed and entered passwords. In some cases Zenoo grants the customer full root access and full control. Customers can implement their own password based on their password policy (depending on products, service level, and their contract agreement).
• Authorization and Privacy – Multi-tenancy and shared resources are basic characteristics of the Hosting and SaaS architecture. Resources, such as storage, and networks are shared between users. Data privacy and protection may be compromised, as the European Network and Security Agency explains, if there is “a failure of mechanisms separating storage, memory, routing, and even reputation between different tenants of the shared infrastructure” (http://www.enisa.europa.eu/media/faq...0Computing.pdf). Therefore, strict data isolation is applied in the application to all layers of the application. Data isolation will be defined based on either shared resources using firewall rules for network isolation or separate databases for database isolation and separate files and permissions for files sharing isolation.
  Since the privacy and confidentiality of its customers' data are the company’s top priority, Zenoo has developed extended authorization controls and additional security processes to protect customer privacy. The authorization mechanism in Zenoo applications supports the segregation of duties. Segregation of duties is applied in order to minimize the risks and the possibility of misusing privileges.

Zenoo has instituted the following policies in order to protect customer data:

• Customer data and personal information is protected.
• Sensitive personal information such as bank information and credit card details are not stored by Zenoo.

Customer data, including private data, is deleted based on the Data Elimination section on page 6, and backed up customer data is deleted periodically.

All access control activities produce logs with enough information to meet auditing requirements and support usage charges. In addition, access control activities generate notifications to designated users to prevent users from setting up rogue accounts or otherwise modifying access entitlements.

Asset Management

The following items are relevant for asset management:

• Incident Management – NIST defines a computer security incident as “a violation or imminent threat of violation of computer security policies, acceptable use policies, or standard security practices.”. To handle security incidents effectively, Zenoo has constructed incident response and notification procedures.
• Zenoo employs a dedicated Incident Handling team that responds to security incidents and mitigates risks. The team uses monitoring and tracking tools and performs real-time analysis. Additionally, the team has clear procedures in place for communicating the incidents to any involved party and for handling escalations. Every incident is forwarded to the Zenoo Head of Technology for assessment and analysis.
• Personnel Security – Zenoo realizes that the malicious activities of an insider could have an impact on the confidentiality, integrity, and availability of all types of data and has therefore formulated policies and procedures concerning the hiring of IT administrators or others with system access. Zenoo has also formulated policies and procedures for the ongoing periodic evaluation of IT administrators or others with system access. User permissions are continuously updated and adjusted so that when a user's job no longer involves infrastructure management, the user's console access rights are immediately revoked.
• Background Checks – Once a candidate has been offered a job with Zenoo and before he or she begins employment, we conduct a background check. For all background checks and reference checks we receive a release from the candidate prior to starting the screening process. We use a third party to conduct our background checks. The standard check includes S.C check, criminal history, employment verification, and reference checks. Any additional checks are conducted based on business needs.

Zenoo Privacy Policy

About This Policy

This Privacy Policy describes the privacy practices of Zenoo with respect to how we collect, use, store, disclose and transfer the information (a) you provide when you interact with us through our websites and when you communicate with us through other means such as email or by telephone, and (b) provided by your institution and you, for its (and your) use of our services and applications.

Data Controller or Data Processor

Zenoo is the data controller for data described by this policy except as specified below, which means that Zenoo determines the purposes and means of the processing of personal data.

Zenoo is the data processor with respect to personal data submitted to and stored on the Zenoo Services for hosting and processing purposes as further described below under Zenoo Services-Customer Data.

Types of Information We Collect About You

Information you or your Institution may provide

Depending upon the Zenoo Sites you are accessing or other method of contact, we may collect information such as

• Contact details such as (for example) your full (i.e., first and last) name, institutional affiliations, phone number, email address, and postal address
• Educational and professional background information
• Usernames and passwords that may be used on some of the Zenoo Sites
• Comments, feedback, posts and other content you submit to the Zenoo Sites
• Information you provide to or post on message boards or chat rooms that are part of the Zenoo Sites
• Interests and communication preferences.

Where we are collecting directly (and not being provided the information by your institution), you will be given advance notice of what information specific to you we are collecting.  Posting information on message boards or in chat rooms is never required.

Information collected automatically

As you navigate the Zenoo Sites, Zenoo may also automatically collect information about you or your computer or device that does not directly identify you. This information may include IP address and device identifiers, information about your Internet connection and information about the equipment or software you use to access the Zenoo Sites. Such information is only collected to the extent that it is necessary for us to provide services that you use, to optimize your user experience, and/or to make improvements to the Zenoo Sites and service offerings. Zenoo does not serve third party advertising.

You have the ability to choose to opt out of inclusion of your personal information at the point of disclosure.  You may choose whether your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. You may also opt out of use of your personal information as outlined below under Access, Correction, and Erasure.
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How We Collect Information About You

We collect information about you in three main ways:

• Information Directly Provided by You or Your Institution: We collect information about you when you register for services, download an app, sign up for email or text alerts, request products or services, respond to surveys, fill out registration forms on an Zenoo Site or otherwise for events, register for or view webinars; create a profile, publicly post or share content, contact us, use social media connections, and/or otherwise interact with Zenoo Sites. We may receive and store information provided by your institution to the extent required to perform a contracted service.
• Information Collected Automatically Using Technological Means: As described above under Information Collected Automatically, we collect certain information automatically using technological means. We also use cookies as further described below under Cookies and Similar Technologies. You may set your browser to block all cookies, including cookies associated with Zenoo Sites, or to indicate when a cookie is being set by us. However, it is important to remember that certain services may not function properly (or at all) if your cookies are disabled.
• Information Collected Through Third Parties:  We may receive information about you from customers and business partners for referral and reference purposes.

Cookies and Similar Technologies

Zenoo uses cookies to manage and improve the functionality of our websites and to enable us to better understand how you use our services. A cookie is a tiny text document, which usually includes anonymous information about the user. You can set your browser to not accept Zenoo’ cookies, but you might not be able to access all aspects of the Zenoo Site you are visiting.
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How We Use and Share Information About You

Zenoo uses the information we collect to perform the services requested, for the purposes of authorizing and processing transactions, authenticating users, customer service, customer support, content processing, content classification, and providing you with information concerning Zenoo services. We will retain this information for as long as the customer account is active or as needed to provide the Zenoo services, comply with our legal obligations, resolve disputes, and as needed to comply with or enforce our licenses and other agreements.

To be clear, we do not access or use Customer Data (as defined below) processed through the Zenoo Services except for the purposes set forth in our agreement with the relevant customer. Please see below under Zenoo Services-Customer Data.

Zenoo remains responsible for the personal data that we share with third parties for processing on our behalf, and we remain liable under this privacy policy if such third parties process such personal data in a manner inconsistent with this privacy policy and we are responsible for the event giving rise to the damage.

Please keep in mind that any information you disclose publicly – either in a public profile or through message boards or other public areas – may be collected and used by others, may be indexable by search engines, and might not be able to be erased from public view to the extent they have been copied to external sites. Please be careful when disclosing personal information in these public areas.

The following is a list of instances where we may share your information with third parties:

• Institutions or Businesses. If you access a service through your affiliation with an institution or through your employer, your information and certain usage data gathered through the Zenoo service may be shared with the institution or business for the purposes of usage analysis, access and license management, collection management, contract and regulatory compliance, and cost allocation.
• Publishers/Content Providers: We may provide anonymized information to publishers so that they understand how their content is being used and consumed.
• Service Providers.  At times Zenoo may hire other companies to process data or do work on our behalf. This is always pursuant to a contract that requires the third-party service provider to protect your information consistent with this privacy policy. These companies are only provided the information they need to perform their functions and the information can only be used to perform the services on our behalf or to comply with legal requirements. We do not disclose personal information to third parties for direct marketing purposes.
• Message Boards and Other Public Areas: Information you post on message boards, chat rooms, or other public areas that are part of the Zenoo Sites is public and will not be kept private. Should you wish to remove your postings from message boards or other public areas, follow the instructions under the Access, Correction, and Erasure section of this policy.  
• Affiliates: To facilitate Zenoo’ global operations, Zenoo may share and transfer information we collect with its affiliates located in countries around the world. For example, Zenoo may need to share such information with other companies within the Zenoo corporate family for customer support, marketing, technical operations and account management purposes.
• Contests and Sweepstakes: We may publicly disclose the name, city and state of contest and sweepstakes winners as permitted by the contest/sweepstakes rules or as required by law.  You may be required to consent to such disclosure if you wish to enter a given contest or sweepstakes.
• Sale or Purchase of Business or Assets: If Zenoo is involved in a merger, acquisition, or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.
• Legal Reasons: We will disclose information to cooperate with law enforcement, government or regulatory bodies, content protection organizations, or judicial processes as required by the applicable laws and regulations. We may also use or disclose information to enforce or protect the rights or safety of Zenoo Services users, us, or others.  We will provide notice to individuals prior to such disclosures, to the extent it is practicable to do so and allowed by law.

Security

Zenoo takes commercially reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, data that you share and that we collect and store. These security measures may include practices such as keeping your data on a secured server behind a firewall, internal reviews of our data collection practices and platforms, industry-standard encryption technologies, and physical security measures to guard against unauthorized access to systems where we store your information.

If you have reason to believe that a third-party has gained unauthorized access to your information, please contact us immediately at privacy@zenoo.com. If Zenoo becomes aware of any data breach, we will notify affected individuals or, with respect to Zenoo Services, affected institutions as soon as reasonably possible.

Your Rights and Choices

Communication Preferences and Opt-outs

If you have subscribed to one or more of our email newsletters or are receiving marketing emails from us and you don’t want them anymore, you can unsubscribe. Follow the instructions contained in the email message to opt-out of receiving future messages of that type.  However, you cannot unsubscribe from some service related messages so long as you maintain an account with Zenoo.

Access, Correction, and Erasure

Postings from message boards or other public areas, may be deleted by using the tools provided when you are logged-in to the particular service; or you may contact Zenoo at privacy@zenoo.com with the details and location of the content (such as a direct link to the information), and Zenoo will make commercially reasonable efforts to remove the content.

You may request to review, correct or delete the personal information that you have previously provided to us through the Zenoo Sites. For requests to access, correct or delete your personal information, please send your request along with any details you may have regarding the method by which the information was submitted to privacy@zenoo.com. Requests to access, change, or delete your information will be addressed within a reasonable timeframe.

To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password, user ID, or other verification before granting access to or removing your information.

Please note that where we are acting as a processor of personal data for our customer, we may first refer your request to the customer that submitted your personal data, and we will assist our customer as needed in responding to your request, as further described below under Zenoo Services-Customer Data.

Please contact privacy@zenoo.com for more information about exercising these rights.
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Data Retention and Deletion

If you request to delete your personal information, we will endeavor to fulfill your request but some personal information may persist in backup copies for a certain period of time and may be retained as necessary for legitimate business purposes or to comply with our legal obligations.

Zenoo may retain your information for a period of time consistent with the original purpose of collection, and for a reasonable time thereafter in accordance with applicable law. We may also retain your information during the period of time needed for Zenoo to conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
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Children

The Zenoo Sites are typically general audience websites, intended for use by users aged 13 and older.

We do not market to nor intentionally collect any personally identifiable information from children under thirteen (13) years of age. If you are under 13, please do not register for any of our services or Sites or provide us with any personally identifying information (such as your name, email address or phone number). Please contact privacy@zenoo.com if you are aware of any personal information supplied to one of Zenoo Sites by a child under the age of thirteen (13).
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Links to Other Services and Websites

The Zenoo Sites may contain links to information created and/or maintained on third-party websites. The third-party website will be displayed in a new browser window and the user will no longer be in the Zenoo environment. When users select a link to an outside website, they are leaving the Zenoo Site and are subject to the privacy and security policies of the owners of the third-party website. We are not responsible for, and we do not endorse or control, the policies or practices of any such website or services.

In some cases, we may embed a content feed, video player or another application from a third party into the Zenoo Site, and those feeds, players, or other applications may appear to be part of the Zenoo Site, even though they are provided or served by a third party. Such feeds, video players, and/or applications do not collect personal information from you.  If information is required for the performance of the service, the service provider is required to protect your information consistent with this privacy policy. For further information, please see the “How We Share Information About You” section of this policy.
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Zenoo Services – Customer Data

Zenoo customers submit data and information to the Zenoo Services for hosting and processing purposes (“Customer Data”). Our customers are data controllers with respect to Customer Data and Zenoo is a data processor. The Zenoo Services include cloud-based library management, discovery, research and reading list solutions, mobile/web platforms for students and other institutional end users and other software as a service or hosted solutions and related services specified in our agreements with such customers. While Zenoo’ customers decide what Customer Data to submit to the Zenoo Services, depending on the particular service, the Customer Data submitted regarding its students, faculty, staff, library patrons, suppliers, users and other individuals may typically include contact details such as name, role, phone number, email address, institutional identification number and postal address, information regarding library and research activity, mobile/web platform information exchange and messaging, and information collected automatically described in this privacy policy.

Zenoo will not use or share any such Customer Data except as provided in its agreements with such customers, or as may be required by law. In accordance with such agreements, Zenoo may access, transfer and process Customer Data only for the purpose of providing the Zenoo Services, preventing or addressing service or technical problems or other purposes as set forth in such agreements or required by law.

Zenoo acknowledges that you have the right to access, correct, amend and delete your personal information. If personal information pertaining to you as an individual has been submitted to us by an Zenoo customer and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our customer directly. Because Zenoo is subject to our agreements with customers (as the data controller) with respect to your personal information stored on the Zenoo Services, if you wish to make your request directly to Zenoo, please provide the name of the Zenoo customer who submitted your data to the Zenoo Services. We will refer your request to that customer, and will support the customer as needed in responding to your request within a reasonable time frame.
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Protection of Customer Data

Zenoo will maintain appropriate administrative, physical, and technical safeguards for protection of the security, confidentiality and integrity of Customer Data. Those safeguards will include measures designed to prevent unauthorized access to or disclosure of Customer Data (other than by Customer or End Users). Except with respect to a free trial, the terms of the data processing addendum at https://www.zenoo.com (“DPA”) are hereby incorporated by reference and shall apply to the extent Customer Data includes Personal Data (as defined in the DPA). For the purposes of the Standard Contractual Clauses (as defined in the DPA), Customer and its Affiliates are each the data exporter, and Customer’s acceptance of this Agreement shall be treated as its execution of the Standard Contractual Clauses and Appendices. Upon request by Customer made within 30 days after the effective date of termination or expiration of this Agreement, Zenoo will make Customer Data available to Customer for export or download. After such 30-day period, Zenoo will have no obligation to maintain or provide any Customer Data and will thereafter delete or destroy all copies of Customer Data in its systems or otherwise in its possession or control, unless legally prohibited.

Updates to Our Privacy Policy

From time to time, we may revise this Privacy Policy. If we make material revisions to the way we collect or use your information, we will provide you with notice of those changes by either: (1) notifying you directly, (2) announcing the change on the Zenoo Sites, and/or (3) posting the revised version of this Privacy Policy online.

You can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this page. By continuing to use Zenoo Sites after such updates, you affirm your agreement with the terms of the Privacy Policy. If we have made changes you don’t agree with, you are free to request that we delete your information as set out in the Your Rights and Choices section above.
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Questions

For any questions on this Privacy Policy or our data practices, you can contact us at privacy@zenoo.com.

Despite the measures outlined in this Privacy Policy, Zenoo cannot guarantee the security of any information that is disclosed online.  To the extent permissible under law, Zenoo shall not be liable for any direct, indirect, special, incidental, consequential or punitive damages relating to this Privacy Policy.

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Record of Changes

Type of Information Document Data
‍Document Title: Cloud Security and Privacy Statement
‍Document Owner: Ceyhun Hallac - Zenoo Head of Technology
‍Approved by: Stuart Watkins - Zenoo Chief Executive Officer (CEO)
‍Issued: Jan 9, 2020

Reviewed & Revised:
Revision Control
‍Version Number 1.0
‍Nature of Change Initial version
‍Date Approved Jan 9, 2020
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Version Number 1.1
‍Nature of Change Updated with “Protection of Customer Data”
‍Date Approved Dec 8, 2020

‍Document Distribution and Review
‍The document owner will distribute this document to all approvers when it is first created and as changes or updates are made. This document will be reviewed and updated annually or upon written request by an approver or stakeholder. Questions or feedback about this document can be directed to the owner or a listed approver.