Partner Terms

The following is a list of our complete terms and conditions that apply to all members of the Zoey Partner Program (the “Agreement”), as between Zoey Inc. (“Zoey”) and you (“Zoey Partner” and, together with Zoey, the “Parties”). Please read this Agreement in its entirety as it is a legally binding agreement on both Parties.

By marking the “I have read and agree to the terms and conditions” checkbox, Zoey Partner hereby agrees to be bound by the terms and conditions set out in this Agreement.

1. Definitions

1.1. Acquisition

Shall mean a monetary transaction made by a Lead who opens a paid Zoey account.

1.2. Affiliate

Shall mean, with respect to Zoey, any other entity who, directly or indirectly, controls, is controlled by, or is under common control with Zoey.

1.3. Branded Material(s)

Shall mean any marketing and/or promotional materials relating to Zoey and/or Zoey brands that (a) are promoted by Zoey and Zoey Related Entities as Zoey deems necessary or appropriate and/or (b) are developed or created by a Partner with the written consent of Zoey in accordance with Section 2.3 below.

1.4. Cause

Shall mean (a) the commission by or allegation against a Party of criminal activity which constitutes a felony under applicable law or the entry of a plea of guilty or no contest with respect thereto by such Party; (b) the commission by or allegation against a Party of fraudulent activity or gross negligence under applicable law; (c) the material breach by a Party of any of its material obligations under this Agreement; (d) the commission by a Party of any act that directly conflicts with the interests of the other Party or causes or is reasonably likely to cause material harm to the other Party or its reputation; (e) the filing by a Party of a voluntary petition or action for relief under any bankruptcy, reorganization, insolvency or moratorium law or any other law for the relief of, or relating to, debtors, now or hereafter in effect; (f) the seeking by a Party of the appointment of a custodian, receiver, trustee (or other similar official) of such Party or all or any substantial portion of such Party’s assets, or the making by such Party of any assignment for the benefit of creditors or taking of any action in furtherance of any of the foregoing; or (g) an involuntary petition filed, or any proceeding or case commenced, against a Party (unless such proceeding or case is dismissed or discharged within 30 days of the filing or commencement thereof) under any bankruptcy, reorganization, arrangement, insolvency, adjustment of debt, liquidation or moratorium statute now or hereafter in effect.

1.5. Confidential Information

Shall include, but shall not be limited to, any and all information associated with the other Party’s business and not publicly known, including, the contents of this Agreement, specific trading information, technical processes and formulas, source codes, customer lists, prospective customer lists, names, addresses and other information regarding customers and prospective customers, product designs, sales, costs, and other unpublished financial information, business plans and marketing data, and any other confidential and proprietary information, whether or not marked as confidential or proprietary. Without limiting the generality of the foregoing, Confidential Information of Zoey shall include, without limitation: (a) onboarding documents that Zoey uses to train Partner employees on Platform; (b) Branded Materials (e.g., use cases, case studies and one sheeters) that show Partner employees how to sell Zoey to Leads; (c) previews of upcoming Zoey features; (d) the Zoey roadmap and strategic plan; and (e) Zoey’s performance record.

1.6. Lead

Shall mean any unique user who (a) is introduced by a Partner to Zoey, (b) arrives on the Platform through a Referral Link supplied by Zoey to that Partner and (c) enters into a monthly or yearly agreement with Zoey. Notwithstanding the foregoing, a Lead cannot be a store (i) owned by a Partner and for which that Partner seeks commissions or compensation pursuant to this Agreement, (ii) previously referred to Zoey by any party other than the Partner, (iii) that has previously contacted Zoey directly (including, without limitation, by visiting the Platform), and/or (iv) that does not register for a paid Zoey account within six (6) months of the date it first arrives on the Platform.

1.7. Malware and Spyware

Relates to the use of pop-up banners that hide banners that are displayed on a website, the placement of icons beside keywords found in text that if clicked will take the visitor to another website, and other similar practices.

1.8. Names and Trademarks

Refers to any names and/or trademarks or any other protected marks associated with the Platform or Service and Zoey Inc.

1.9. Opt-in List

Shall mean the list of emails where the individuals on the list have expressly elected to receive e-mails from Zoey Partners.

1.10. Partner

Shall mean an entity that has agreed to the terms of the Partner Program herein to work with Zoey to promote the Service by referring clients to Zoey.

1.11. The Platform or Service

Refers to the Zoey software platform available via the Zoey website (currently www.zoey.com) and any associated websites including info.zoey.com and any other replacement or substitute websites.

1.12. Prospective Partners

Refers to any other marketing organizations and/or website owners and/or operators that may be potential partners of Zoey.

1.13. Related Entity(ies)

Shall mean any entity that, directly or indirectly, controls, is controlled by, or is under common control with, Zoey; where “control” means the possession, directly or indirectly, of the power to direct or cause the direction of the management policies of another, whether through the ownership of voting securities, by contract, as trustee or executor, or otherwise.

1.14. Revenue

Shall mean, with respect to any Lead, all fees actually received by Zoey from such Lead under the applicable monthly or yearly agreement, net of any taxes, credit card fees, charge backs, discounts, refunds, exchanges, promotions, coupons, waivers, failed charges and other customary offsets. Revenue shall only include fees relating to the provision of the Platform to the Lead and shall exclude all fees relating to any ancillary service provided by Zoey to the Lead even if such services are documented within the monthly or yearly agreement entered into between Zoey and the Lead. Revenue shall also exclude any revenue share received by Zoey from an application partner with respect to any application subscribed to by the Lead through the Platform.

1.15. Websites

Refers to any Zoey account associated with websites that are managed by a Zoey Partner that currently have or will have a marketing arrangement with Zoey.

2. Responsibilities of the Partner

2.1. Activities

Zoey Partner will use its best efforts to (a) promote and market Zoey and (b) identify for Zoey prospective Leads. Should Zoey assign Zoey Partner a territory, in no event shall Zoey Partner engage in any marketing or promotional activity related to Zoey in any area, location, territory or jurisdiction outside of such territory as defined by Zoey from time to time. Zoey Partner shall bear all costs and expenses for such activities unless Zoey, in its sole discretion, approves in writing in advance the incurrence of such costs and expenses.

2.2. Branded Materials

All Branded Materials will be solely provided by Zoey alone except where agreed to by Zoey in writing in advance. Zoey will provide Zoey Partner with copies of or access to Branded Materials. The Branded Materials shall be accessible from the Zoey Partner Program website (once such website is developed) and/or via email from Zoey directly to Zoey Partner. The Branded Materials are provided “as is” and without warranty (express or implied) of any kind.

2.3. Use of Branded Materials

Zoey Partner may display Branded Materials on the Websites solely for the purpose of marketing and promoting Zoey brands promoted by Zoey and by Zoey Related Entities during the term of this Agreement, or until such earlier time as Zoey may, upon reasonable prior notice, instruct Zoey Partner to cease displaying the Branded Materials. Zoey Partner may not alter, amend, adapt, edit or translate the Branded Materials without Zoey’s prior written consent. Nothing contained in any Branded Materials shall in any way be deemed a representation or warranty of Zoey or of any Zoey Related Entity. The Branded Materials shall at all times be the sole and exclusive property of Zoey and no rights of ownership shall at any time vest with Zoey Partner even in such instances where the partner has been authorized by Zoey to make changes or modifications to the Branded Materials or create or develop new ones.

2.4. E-Mail Internet Marketing

In no event shall a Zoey Partner engage in any e-mail marketing or promotion with respect to Zoey and/or any Zoey Related Entity except as expressly set forth in this Agreement. In the event that Zoey Partner has an Opt-in List, Zoey Partner may make a written request to Zoey to send e-mails regarding the offering of Zoey and Zoey Related Entities to the individuals on the Opt-in List. In the event Zoey approves such request in its sole discretion, Zoey Partner shall comply with all applicable laws, rules, regulations and directives, including, without limitation, those relating to e-mail marketing and “spamming”. Without limiting the generality of the foregoing, Zoey Partner shall (a) not send any e-mail regarding Zoey and/or Zoey Related Entities to any individual or entity that has not requested such information and (b) always include “unsubscribe” information at the top and bottom of any e-mail regarding Zoey, Zoey Related Entities and/or the Platform.

2.5. Unauthorized and Prohibited Marketing Activities

In addition to the restrictions of Section 2.4 above, a Zoey Partner shall not (a) engage in any fax, broadcast or telemarketing and any other offline marketing methods with respect to Zoey, Zoey Related Entities and/or the Platform; (b) use Malware and/or Spyware techniques or use any other aggressive advertising or marketing methods in any of its dealings relating to Zoey, Zoey Related Entities and/or the Platform; (c) make any false, misleading or disparaging representations or statements with respect to Zoey, Zoey Related Entities or the Platform; (d) misrepresent Zoey Partner’s affiliation with Zoey; or (e) engage in any other practices which may affect adversely the credibility or reputation of Zoey, Zoey Related Entities or the Platform, including, without limitation, using any Website in any manner, or having any content on any Website, that (i) promotes sexually explicit materials, violence, discrimination based on race, sex, religion, nationality, disability, sexual orientation or age and/or any illegal activities or (ii) violates any intellectual property or other proprietary rights of any third party.

2.6. Prohibited Marketing Activities by a Partner

A Zoey Partner shall not purchase search engine or other pay-per-click keywords (such as Google AdWords) or domain names that use Zoey or Zoey’s trademarks and/or variations and misspellings thereof.

2.7. Compliance with Laws

In addition to, and without limiting the provisions of this Agreement, Zoey Partner shall perform its obligations hereunder in accordance with the highest applicable industry standards and in compliance with all applicable laws, rules and regulations.

2.8. Partner Duty to Inform

Zoey Partner shall promptly inform Zoey of any information known to Zoey Partner related to any Leads or prospective partners that could reasonably lead to a claim, demand or liability of or against Zoey and/or the Zoey Related Entities by any third party.

3. Zoey Partner Commercial Terms

3.1. Referral Plan

a) Referrals to Zoey

Subject to the provisions below, Zoey Partner is entitled to twenty percent (10%) of the total Revenue received by Zoey from a Lead (“Revenue Share”), with Zoey being entitled to the remaining eighty percent (90%).

Zoey Partner shall receive a Partner Revenue Share for the initial period covered by the first monthly or annual agreement, as applicable, that the Lead enters into with Zoey, plus all consecutive (but not non-consecutive) renewal periods of such agreement, up to one year. At Zoey’s discretion, Zoey may extend payments beyond the one year limit, and will notify a partner in writing when this has been extended.

All payments are subject to risk analysis considerations and Anti-Money Laundering procedures. Zoey reserves the right to demand and receive information about any Lead and to assess the competency of such Lead for payments.

3.2. Payment

a) Payment by Zoey

If Zoey Partner is entitled to receive a Partner Revenue Share under Section 3.1(a), then, (i) if under a yearly agreement – with respect to any Partner Revenue Share earned in a given quarterly period, Zoey shall remit, in arrears, such Partner Revenue Share to Zoey Partner in four equal quarterly installments with the first of the four payments due within forty-five days of the first day of the subsequent quarterly period, and (ii) if under a monthly agreement – with respect to any Partner Revenue Share earned in a given month, Zoey shall remit such Partner Revenue Share to Zoey Partner within forty-five days of the first day of the subsequent quarter thereafter; provided, however, that Zoey Partner shall be required to provide Zoey with such information andor documentation reasonably requested by Zoey to enable it to process such payment of Partner Revenue Share, including any requisite tax forms and other personal information, by no later than fifteen days following Zoey’s written request. If Zoey Partner fails to provide Zoey with such information andor documentation in a timely manner, as set forth above, Zoey shall not be required to remit the Partner Revenue Share. Any Zoey Partner that has not provided such information and documentation within thirty days of Zoey’s request, will be deemed to have waived its right to receive the Partner Revenue Share. If the account balance of a Zoey Partner is less than USD$20 at the end of the quarterly period, such funds will remain in the account until the end of the next subsequent quarterly period in which the account has USD$25 or more.

4. Termination

4.1. Termination

Zoey may terminate this Agreement at any time without Cause, effective immediately upon notice to Zoey Partner. Zoey may terminate this Agreement at any time with Cause effectively immediately without notice to, or recourse for, Zoey Partner.

Zoey’s obligation to pay Zoey Partner its Partner Revenue Share under Section 3 shall terminate effective immediately if Zoey terminates this Agreement with Cause.

Zoey Partner can terminate this Agreement at any time, with or without Cause, effective immediately upon notice to Zoey.

Zoey’s obligation to pay the Zoey Partner the Revenue as the case may be, under Section 3 shall survive the termination of this Agreement if such Party terminates this Agreement without cause; otherwise, such obligation shall terminate effective on the date of termination.

4.2. Consequences of Termination

Upon expiration or termination of this Agreement: (a) each Party shall return to the other Party all property of the other Party in its possession or control (including all Branded Materials and all Confidential Information); (b) Zoey Partner shall immediately cease displaying any Branded Materials on any Website or otherwise; and (c) all rights granted to Zoey Partner hereunder will immediately cease.

5. Proprietary rights

5.1. Proprietary Rights of Zoey

As between Zoey Partner and Zoey, the Branded Materials, all demographic and other information relating to Leads, prospective partners and Partners, the Platform and all software, documentation, hardware, equipment, devices, templates, tools, documents, processes, methodologies, know-how, websites, and any additional intellectual or other property used by or on behalf of Zoey or otherwise related to Zoey, together with all copyrights, trademarks, patents, trade secrets and any other proprietary rights inherent therein and appurtenant thereto (collectively, “Zoey Property”) shall be and remain the sole and exclusive property of Zoey. To the extent, if any, that ownership of any Zoey Property does not automatically vest in Zoey by virtue of this Agreement or otherwise, Zoey Partner hereby transfers and assigns to Zoey, upon the creation thereof, all rights, title and interest Zoey Partner may have in and to such Zoey Property, including the right to sue and recover for past, present and future violations thereof.

5.2. Zoey Trademarks

During the term of this Agreement, Zoey hereby grants to Zoey Partner a limited, revocable, non-exclusive and non-transferable license to display the Zoey trademarks, solely as necessary to perform Zoey Partner’s obligations under this Agreement. Zoey Partner acknowledges and agrees that: (a) it will use the Zoey trademark only as permitted hereunder; (b) it will use the Zoey trademark in a lawful manner and in strict compliance with all format(s), guidelines, standards and other requirements prescribed by Zoey; (c) the Zoey trademark is and shall remain the sole property of Zoey; (d) nothing in this Agreement shall confer in Zoey Partner any right of ownership in the Zoey trademark and all use thereof by Zoey Partner shall inure to the benefit of Zoey; and (e) Zoey Partner shall not, now or in the future, contest the validity of any Zoey trademark or use any term or mark confusingly similar to any Zoey trademark.

6. Confidentiality

Each Party agrees to use the other Party’s Confidential Information solely as necessary for performing its obligations hereunder. Each Party agrees that it shall take all reasonable steps, at least substantially equivalent to the steps it takes to protect its own proprietary information, to prevent the duplication, disclosure or use of any such Confidential Information, other than (a) by or to its employees, agents and subcontractors who must have access to such Confidential Information to perform such Party’s obligations hereunder, who each shall treat such Confidential Information as provided herein; or (b) as required by any law, regulation, or order of any court of proper jurisdiction over the Parties and the subject matter contained in this Agreement. Confidential Information shall not include any information which is: (i) in the public domain, or is already known by or in the possession of the non-disclosing Party, at the time of disclosure of such information; (ii) is independently developed by the non-disclosing Party without breaching any provisions of this Agreement and compelling documentary evidence of such development exists; or (iii) is thereafter rightly obtained by the non-disclosing Party from a source other than the disclosing Party and such source is not breaching any provision of any agreement it may have with Zoey or any third party.

7. Disclaimer of warranty

Zoey makes no warranties whatsoever hereunder, and Zoey hereby expressly disclaims all warranties, express or implied, including, without limitation, warranties of merchantability and fitness for a particular purpose. Without limiting the foregoing, Zoey further disclaims all representations and warranties, express or implied, that the Platform does not infringe or otherwise violate any intellectual property or other proprietary right of any third party in any jurisdiction, including, but not limited to, any territory that Zoey might assign to Zoey Partner. Zoey Partner understands and agrees that the Platform may not satisfy all of the Leads’ requirements and may not be uninterrupted or error-free.

8. Limitation of liability and indemnification

8.1. Limitation of Liability

Zoey shall have no liability with respect to the Platform or its obligations under this Agreement or otherwise for any indirect, consequential, exemplary, special, incidental or punitive damages even if Zoey has been advised of the possibility of such damages. In any event, Zoey’s liability to Zoey Partner under this Agreement for any reason will be limited to the amounts paid to Partner by Zoey during the six (6) month period immediately preceding the event giving rise to the claim for damages. This limitation applies to all causes of action in the aggregate, including, without limitation, breach of contract, breach of warranty, negligence, strict liability, misrepresentations, and other torts.

8.2. Indemnification

1. Zoey Partner Indemnification.

Zoey Partner agrees to indemnify, defend and hold harmless Zoey and any Zoey Related Entities and the directors, officers, employees, subcontractors and agents thereof (collectively, the “Indemnified Party”), with respect to any claim, demand, cause of action, debt or liability, including reasonable attorneys’ fees, to the extent that such action is based upon or arises out of: (a) Zoey Partner ‘s breach of any provision, representation, warranty, obligation or covenant under this Agreement; (b) Zoey Partner’s gross negligence or willful misconduct; or (c) any warranty, condition, representation, indemnity or guarantee relating to Zoey and Zoey Related Entities granted by Zoey Partner to any Lead, Prospective Partner or other third party.

2. Notice of Indemnification.

In claiming any indemnification hereunder, the Indemnified Party shall promptly provide Zoey Partner with written notice of any claim which the Indemnified Party believes falls within the scope of Section 8.2.1; providedhowever, that any failure of the Indemnified Partner to provide prompt written notice pursuant to this Section 8.2.2 shall excuse Zoey Partner only to the extent that it is prejudiced thereby. The Indemnified Party may, at its own expense, assist in the defense if it so chooses, provided that Zoey Partner shall control such defense and all negotiations relative to the settlement of any such claim and further provided that any settlement intended to bind the Indemnified Party shall not be final without the Indemnified Party’s written consent, which consent shall not be unreasonably withheld.

9. Non-exclusive remedies

In the event (a) Zoey Partner markets or promotes Zoey and/or any Zoey Related Entity that promotes the Platform to any person or entity outside of any territory (if any) assigned by Zoey to Zoey Partner or (b) of any breach or threatened breach of any provision of Sections 2, 5 and/or 6 above, in addition to all other rights and remedies available to Zoey under this Agreement and under applicable law, Zoey shall have the right to (i) immediately enjoin all such activity, without the necessity of showing damages or posting bond or other security, (ii) immediately terminate this Agreement and Zoey Partner ’s engagement hereunder, (iii) receive a prompt refund of all amounts paid to Zoey Partner hereunder and (iv) be indemnified for any losses, damages or liability incurred by Zoey in connection with such violation, in accordance with the provisions of Section 8 above.

10. General provisions

10.1. Force Majeure

If the performance of any part of this Agreement by either Party is prevented, hindered, delayed or otherwise made impracticable by reason of any flood, riot, fire, judicial or governmental action (including, but not limited to, any law, regulation or embargo prohibiting the performance contemplated hereunder and/or the failure or refusal of a government agency to issue a license required for any performance pursuant to this Agreement), labor disputes, act of God, war, insurrection, terrorist activity, power failure or any cause beyond the reasonable control of that Party, the Party shall be excused from such performance to the extent that it is prevented, hindered or delayed by such cause. Notwithstanding anything herein to the contrary, the Party prevented from performing hereunder by a force majeure event shall nevertheless use its best efforts to recommence its performance hereunder as soon as reasonably practicable and to mitigate any damages resulting from its non-performance hereunder.

10.2. Relationship Between the Parties

Although the Agreement refers to one of the Parties as a “Partner,” the Parties are not members of an association, partnership or joint venture in the legal sense. The Parties are independent contractors, and neither has a fiduciary duty to the other. Neither Party is an agent of the other Party. Neither Party may represent to any person that it has the power to bind the other Party on any contract or agreement or take any action reasonably likely to lead the public to believe it is the agent or representative of the other Party. This Agreement is non-exclusive. Either Party may provide services of the type described herein to any person, including a competitor of the other Party. Neither Party agrees to provide the other with any type of exclusivity in any market segment or geographic region.

10.3. Notice

Any notice, approval, request, authorization, direction or other communication under this Agreement shall be given in writing and shall be deemed to have been delivered and given for all purposes: (a) on the delivery date if delivered personally or by e-mail to the Party to which the same is directed; (b) two (2) business days after deposit with an internationally recognized commercial overnight courier service, with written verification of receipt; or (c) five (5) business days after deposit in certified or registered mail, return receipt requested, postage and charges prepaid, to the respective addresses of the Parties as set forth on the Registration Page.

10.4. No Waiver

The failure of either Party to insist upon or enforce strict performance by the other Party of any provision of this Agreement or to exercise any right under this Agreement shall not be construed as a waiver or relinquishment to any extent of such Party’s right to assert or rely upon any such provision or right in that or any other instance; rather, the same shall be and remain in full force and effect. Each waiver shall be set forth in a written instrument signed by the waiving Party.

10.5. Entire Agreement

This Agreement, including the Registration Page completed by Zoey Partner, sets forth the entire agreement of the Parties and supersedes any and all prior and contemporaneous agreements, written or oral, of the Parties with respect to the subject matter hereof as set forth herein. Neither Party shall be bound by, and each Party specifically objects to, any term, condition or other provision that is different from or in addition to the provisions of this Agreement (whether or not it would materially alter this Agreement) and which is proffered by the other Party in any correspondence or other document, unless the Party to be bound thereby specifically agrees to such provision in writing.

10.6. Assignment

All the terms and provisions of this Agreement shall be binding upon and inure to the benefit of the Parties to this Agreement and to their respective heirs, successors, assigns and legal representatives. Zoey may assign this Agreement and its rights and obligations hereunder to (i) any of its Affiliates, or (ii) an acquirer of all of its assets, or (iii) any successor of Zoey by merger or consolidation, without the consent of Zoey Partner. Zoey Partner shall have no right to assign or otherwise transfer this Agreement, or any of its rights or obligations hereunder, to any third party without Zoey’s prior written consent, to be given or withheld in Zoey’s sole discretion. Any purported assignment or transfer by Zoey Partner without such prior written consent from Zoey shall be null and void, ab initio.

10.7. Applicable Laws

This Agreement shall be governed and construed in accordance with the laws of the State of New York applicable to agreements made and to be performed entirely within such State, without regard to the conflicts of law rules thereof.

10.8. Jurisdiction and Venue/Equitable Remedies

The Parties hereby expressly agree that if, under any circumstances, any dispute or controversy arising out of or relating to or in any way connected with this Agreement shall be the subject of any court action at law or in equity, such action shall be filed exclusively in (a) the United States District Court for the Southern District of New York or, if such court is not available because of jurisdictional reasons, (b) the Supreme Court of New York, New York County. Each party agrees not to commence any action, suit or other proceeding arising from, relating to, or in connection with this Agreement except in such a court and each party irrevocably and unconditionally consents and submits to the personal and exclusive jurisdiction of such courts for the purposes of litigating any such action, and hereby grants jurisdiction to such courts and to any appellate courts having jurisdiction over appeals from such courts or review of such proceedings. Because the breach of the provisions of this Section 10.8 would cause irreparable harm and significant injury to the Parties, which would be difficult to ascertain and which may not be compensable by damages alone, each Party agrees that the other Party will have the right to enforce the provisions of this Section 10.8 by injunction, specific performance or other equitable relief in addition to any and all other remedies available to such Party without showing or proving any actual damage to such Party.

10.9. Survival

Sections 1, 4.2 and 6 through 10 shall survive the expiration or termination of this Agreement.

10.10. Severability

If any provision of this Agreement is held invalid, illegal or unenforceable, a court may reform such provision to the extent necessary and in such a manner as to effect the original intention of the parties; all remaining provisions shall continue in full force and effect.

10.11. Amendment and Modification

Zoey reserves the right to cancel, amend or modify the Zoey Partner Program Agreement in its entirety, including Zoey Partner Commercial Terms, upon 30 days’ notice to a Zoey Partner.

10.12. Federal Trade Commission Considerations

The Federal Trade Commission in the United States (“FTC”) has guidelines for governing endorsements and testimonials. These rules are aimed at increasing transparency between endorsers and consumers. As members of the Partner Program with Zoey, Zoey Partner receives compensation for the affiliate referrals it makes to Zoey. This may establish a “material connection” according to FTC rules, which creates an obligation on the part of Zoey Partner to provide disclosure to its consumers.

Full compliance with these guidelines requires that information be provided by Zoey Partner to its consumers clearly and conspicuously, outlining that Zoey Partner is being compensated for referring clients to Zoey. For further information, Zoey Partner may refer to the statement released by the FTC regarding these guidelines.

Last Updated August 20, 2020

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