ZAM Network LLC (Marketing, Creative Services and User Research) Privacy Policy

If you register an account to use the Service then we will need some information from you to set this up, including name, email address and password. If you choose, you can provide certain other information to personalize your experience of the Service, enable Service features or participate in the Service. If you need to get in touch with us, we will retain some information so that we can get back in touch with you and address any concerns.

We use your information to provide the many functions and services that comprise the Service. We also use your information for account verification, security purposes and to support and improve the Service. We do not share your information with any third parties, except where we need to in order to provide the Service (e.g., use local cloud providers or to back up your data; use our affiliates around the world to help us to deliver the Service) or monitor the success of our marketing and advertising programs, or where we are instructed to by a court, authority or compelled by law.

We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data and support services). When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the Service and we may be required by a court or legal obligation to disclose certain information in some circumstances.

Our servers are located in the United States and Singapore. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world.

We generally retain your information for the period during which you maintain an account for the Service, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws.

Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.

Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

Data Controller: ZAM Network LLC | Email: privacy@zam.com

EU Representative: Achieved Compliance Advocacy, Ltd. | Email: zam@gdprrepresentative.eu

UK Representative: Achieved Compliance Advocacy Ltd. | Email: zam@gdprrepresentative.eu

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

 

Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything!

Privacy Policy

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with, and the website for the marketing, creative services and user research business activities by ZAM Network LLC (the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it. 

 

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging our rules regarding your personal information as described in this Privacy Policy. 

 

This Service has been developed by ZAM Network LLC (“we”, “us”, “our”). 

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is ZAM Network LLC. The registered address of ZAM Network LLC is 12777 West Jefferson Blvd – Building E, Los Angeles, CA 90066, USA. 

 

Our representative in the EU for the purpose of EU data protection laws is Achieved Compliance Advocacy, Ltd. The registered address of Achieved Compliance Advocacy, Ltd. is Singel 250, 1016 AB Amsterdam, the Netherlands. Our representative in the EU can be contacted at zam@gdprrepresentative.eu.   

Our data protection officer can be contacted at privacy@zam.com. 

Our representatives for data protection purposes in certain jurisdictions are as follows:

Jurisdiction

Representative

Address

Contact Details

EU

Achieved Compliance Advocacy, Ltd.

Singel 250, 1016 AB Amsterdam, the Netherlands

UK

Achieved Compliance Advocacy Ltd.

Princess House, Princess Way, Swansea, UK SA1 3LW

EU Jurisdiction

Representative: Achieved Compliance Advocacy, Ltd.

Singel 250, 1016 AB Amsterdam, the Netherlands

zam@gdprrepresentative.eu

UK Jurisdiction

Representative: Achieved Compliance Advocacy, Ltd.

Princess House, Princess Way, Swansea, UK SA1 3LW

zam@gdprrepresentative.eu

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at privacy@zam.com.

 

The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How We Use Your Personal Information” below.

 

The following is a high-level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party). 

 

  • Registration and Account information: You give us information about you when you set up an account to register for the Service: name, email address and password. You may provide additional optional information (such as address, phone number, language and gender).

 

  • Game-Related Information: Relevant information that you provide to us when you give reviews or feedback on games through the Service.

 

  • Survey information: If you choose to participate in a survey as part of the Service, you may be asked to provide certain personal information, such as your age, gender, email, address, geographic (country) location, game information (game habits and preferences) and any other content you choose to provide as part of the survey response.

 

  • Contests, Sweepstakes and Give-aways Information:  If you choose to participate in a contest, sweepstake or giveaway as part of the Service, you may be asked to provide certain personal information, such as your name, photograph, likeness, voice, opinions, information, biographical information, hometown and jurisdiction of residence for advertising, publicity and promotional purposes.

 

  • Social Media Information: We collect this when you log into the Service via social media sites, such as Facebook and Twitter. When you choose to connect your social media account to your profile on the Service, we collect Personal Information from that social media website. For example, when you connect your Facebook account, we collect certain Personal Information you have made publicly available in Facebook, such as your name, user ID, profile picture, and certain any other information you have made public. When you allow it, we also obtain other non-public information from these social media websites. We do this because it is in our legitimate interests to enable you to connect via your social media account and provide a well-functioning site that you can integrate into your online experience.

 

  • Partner Site Information: When you log in or authenticate your account on the Service using your credentials from other partner gaming websites and applications (such as Battle.net and Twitch), we collect personal information about you, including a unique user ID, information about your avatars or game characters, and other gaming information. We do not receive your name, email address, or your account log-in credentials from our partners.

 

  • Feedback: If you participate in an interview or focus group discussion, then we will process the feedback provided by you. 
 

2. Information about you generated as part of the Service

 

We automatically collect certain data from you when you use the Service, namely:

 

  • Technical information: your IP address, and device information, including device ID, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, IDFA, AAID, click-through data, preferences and usage statistics.
 

Children

Children must not use the Service for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

 

By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age.

 

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at privacy@zam.com and we will delete such information.

 

How We Use Your Personal Information 

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the United Kingdom, the European Economic Area, Switzerland, Thailand, Brazil or Turkey (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Personal Information

Use

Legal Basis

Information you provide to us (either directly or through a third party) 

( only relevant if you are located in a Relevant Jurisdiction)

Registration and Account information: name, email address and password. 

(Optional) address, phone number, language and gender

We use this information to create your account for the Service in accordance with your request. Please note if you participate in a sweepstake or competition your name may be disclosed as a winner within the 3 month period following the date of the end of the relevant event. 

Necessary to perform our contract with you to provide the Service.

Game-Related Information: reviews or feedback on games

We use this information to help support and improve the associated product or service.

If you choose to participate, we process such information in accordance with our contract to facilitate the relevant survey, interview or session.

Survey information: age, gender, email, address, geographic (country) location, game information (game habits and preferences) and any other content provided as part of the survey response.

We use this information to help support and improve the associated product or service.

If you choose to participate, we process such information in accordance with our contract to facilitate the relevant survey, interview or session.

Contests, Sweepstakes and Give-aways Information:  

If you choose to participate in a contest, sweepstake or giveaway as part of the Service, you may be asked to provide certain personal information, such as your name, photograph, likeness, voice, opinions, information, biographical information, hometown and jurisdiction of residence.

To facilitate the relevant activity and associated rewards and for advertising, publicity and promotional purposes.

Please note if you participate in a sweepstake or competition this information your name may be processed in connection with our marketing activities.

Necessary to perform our contract with you to provide the Service.

Social Media Information (if you choose to log in via your social media account with these networks):

Facebook: Name, Facebook ID, Profile Picture, Email Address (optional)

We use this information to create your account for the Service in accordance with your request.

Necessary to perform our contract with you to provide the Service.

Partner Site Information: unique user ID, information about your avatars or game characters, and other gaming information

We use this information to help support and improve the associated product or service.

If you choose to participate, we process such information in accordance with our contract to facilitate the relevant survey, interview or session.

Feedback: If you participate in an interview or focus group discussion, then we will process the feedback provided by you.

 

We use this information to help support and improve the associated product or service.

If you choose to participate, we process such information in accordance with our contract to facilitate the relevant survey, interview or session.

Information generated as part of the Service

IP address

We use this information to allow you to connect to our server.

Necessary to perform our contract with you to provide the Service.

Device ID, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, IDFA, AAID, click-through data, preferences and usage statistics

We use this information:

  • to improve our services, including the functionality of the Service;
  • for security and verification purposes; and
  • to identify and address bugs and assess Service function for optimization.

It is in our legitimate interest to ensure the security of our Service, manage registrations and improve our Service.

Usage Logs 

We use this information to:

  • maintain a record of log-in and actions of your account;
  • improve our Service, including the functionality of the Service; and
  • for security and verification purposes.

Necessary to perform our contract with you to provide the Service and retain your record of progress.

Personal Information

Information you provide to us (either directly or through a third party) 

Use:

We use this information to create your account for the Service in accordance with your request. Please note if you participate in a sweepstake or competition your name may be disclosed as a winner within the 3 month period following the date of the end of the relevant event. 

 

Legal Basis (only relevant if you are located in a Relevant Jurisdiction):

Necessary to perform our contract with you to provide the Service.

Use:

We use this information to help support and improve the associated product or service.

 

Legal Basis (only relevant if you are located in a Relevant Jurisdiction):

If you choose to participate, we process such information in accordance with our contract to facilitate the relevant survey, interview or session.

Use:

We use this information to help support and improve the associated product or service.

 

Legal Basis (only relevant if you are located in a Relevant Jurisdiction):

If you choose to participate, we process such information in accordance with our contract to facilitate the relevant survey, interview or session.

Use:

To facilitate the relevant activity and associated rewards and for advertising, publicity and promotional purposes.

Please note if you participate in a sweepstake or competition this information your name may be processed in connection with our marketing activities.

 

Legal Basis (only relevant if you are located in a Relevant Jurisdiction):

Necessary to perform our contract with you to provide the Service.

Use:

We use this information to create your account for the Service in accordance with your request.

 

Legal Basis (only relevant if you are located in a Relevant Jurisdiction):

Necessary to perform our contract with you to provide the Service.

Use:

We use this information to help support and improve the associated product or service.

 

Legal Basis (only relevant if you are located in a Relevant Jurisdiction):

If you choose to participate, we process such information in accordance with our contract to facilitate the relevant survey, interview or session.

Use:

We use this information to help support and improve the associated product or service.

 

Legal Basis (only relevant if you are located in a Relevant Jurisdiction):

If you choose to participate, we process such information in accordance with our contract to facilitate the relevant survey, interview or session.

IP Address

Information generated as part of the Service.

Use:

We use this information:

  • to improve our services, including the functionality of the Service;
  • for security and verification purposes; and
  • to identify and address bugs and assess Service function for optimization.

 

Legal Basis (only relevant if you are located in a Relevant Jurisdiction):

It is in our legitimate interest to ensure the security of our Service, manage registrations and improve our Service.

Use:

We use this information to:

  • maintain a record of log-in and actions of your account;
  • improve our Service, including the functionality of the Service; and
  • for security and verification purposes.

 

Legal Basis (only relevant if you are located in a Relevant Jurisdiction):

Necessary to perform our contract with you to provide the Service and retain your record of progress.

How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with the Service, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers for the Service are located in the United States and Singapore.

 

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world. Our clients are located around the world, and therefore the information will be provided to such clients in the locations they operate or request.

 

Only where necessary will we share your personal information with third parties. Situations where this occur are: 

 

  • Third parties that provide services in support of the Service, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Service, for the purpose of processing support ticket ID and support communication, and for the purpose of providing marketing and advertisements and monitor the success of our marketing and advertising programs. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

 

  • Companies within our corporate group who process your personal information in order to operate the Service. All related group companies may only use your personal information in accordance with this Privacy Policy.

 

  • Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

 

    • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

 

    • detect, prevent or otherwise address security, fraud or technical issues; or

 

    • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

 

  • A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

 

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk. 

 

Data Retention

  • We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below. 

Personal Information

Retention Policy

Registration and Account Information

7 years after your last active session

Game-Related Information

3 years after last update

Survey Information / Feedback

7 years after your last submission

Contests, Sweepstakes and Give-aways

7 years after your last submission

Social Media Information

7 years after last active session

Partner Site Information

7 years after last active session

Payments Information

1 year after last usage

Usage Logs

30 days

Customer Support & Communications Information

7 years after your last submission

Technical Information

30 days

Personal Information

 

Registration and Account Information. Retention Policy: 7 years after your last active session.

 

Game-Related Information. Retention Policy: 3 years after last update.

 

Survey Information / Feedback. Retention Policy: 7 years after your last submission.

 

Contests, Sweepstakes and Give-aways. Retention Policy: 7 years after your last submission.

 

Social Media Information. Retention Policy: 7 years after last active session.

 

Partner Site Information. Retention Policy: 7 years after last active session.

 

Payments Information. Retention Policy: 1 year after last usage.

 

Usage Logs. Retention Policy: 30 Days.

 

Customer Support & Communications Information. Retention Policy:7 years after your last submission.

 

Technical Information. Retention Policy: 30 Days.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information. 

 

Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.

 

This section entitled “Your Rights” applies to users that are located in the Relevant Jurisdictions. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised. 

 

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada, Argentina, India and Russia.

 

The sub-section entitled “Advertising” also apply to users that are located in Japan, Korea, Thailand, United States, Canada, Argentina, Brazil, India, Indonesia,  Mexico, Philippines, Russia, Turkey, Saudi Arabia and Vietnam.

 

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at privacy@zam.com. 

 

Where we act as a data processor, you should contact the data controller to exercise any of your rights.

You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us at privacy@zam.com. 

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

 

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property). 

You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at privacy@zam.com

If there is any other personal information you believe we process that you would like us to erase, please contact us at privacy@zam.com. 

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too. 

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too. 

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at privacy@zam.com.

 

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at privacy@zam.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. 

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

 

Advertising

You may choose to stop receiving personalized advertising or marketing promotions from us by contacting us at privacy@zam.com.

 

Contact & Complaints 

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to privacy@zam.com.

 

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at privacy@zam.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

 

Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. 

 

Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section.

 

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Your rights 

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). 

 

Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing us your personal information and by using the Service, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina. 

This section applies to users located in Brazil:

 

Language

This Privacy Policy is provided in Portuguese for users located in Brazil. In case of dispute, the Portuguese version of this Privacy Policy shall prevail. 

 

Consent Revocation 

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact privacy@zam.com. This may affect our provision of the Service to you.

 

Parental and Guardian Consent

If you are under the age of 18, you should not use the Service for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.

 

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

 

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

  • Identifiers, such as your name, IP address, email address, mailing address, cookie identifiers, device identifiers, payment processor user identifiers, ZAM and social media account usernames, and phone number. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
  • Internet or other electronic network activity information, such as your language preference, information about your avatars or game characters, user preferences, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, IDFA, AAID, click-through data, browse and search history, and log-in and clickstream data.  We also collect preferences and usage statistics to analyze how our Service is used, to optimize your ability to view and use the Service, and to provide targeted advertising. This information is collected directly from you and your device.

 

  • Commercial information about any transactions within the Service which you will provide to our payment processors — including credit card numbers, bank account numbers, and financial account information (including user tokens used to facilitate transactions and information collected to verify transactions). We will receive summary information about transactions from our payment processors without specific reference to individual credit card numbers of bank account numbers.. This information is collected directly from you. 
  • Audio and visual information such as your profile pictures, photos, screenshots, and videos shared or posted through the Service. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.
  • Professional or employment-related information such as your employment profile. This information is collected directly from you.
  • Other information described in subdivision (e) of Section 1798.80, including information about your gender. This information is collected directly from you in the context of being our consumer.

 

We collect your personal information for the following purposes:

  • To provide you with the Service.
  • To process surveys and administer sweepstakes.
  • To improve our services, including the functionality of the Service.
  • For security and verification purposes, including to prevent and detect fraudulent activity.
  • To address and remediate technical issues and bugs.

 

For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.

 

We disclose personal information to the following types of entities:

  • Other companies within our corporate group who process your personal information in order to operate the Service.
  • Other companies that provide services on our behalf in support of the Service and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
  • Regulators,  judicial authorities and law enforcement agencies
  • Entities that acquire all or substantially all of our business.

 

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

Rights under the CCPA:

If you are a California resident, you have the right to:

  • Request we disclose to you free of charge the following information covering the 12 months preceding your request:
    • the categories of personal information about you that we collected;
    • the categories of sources from which the personal information was collected;
    • the purpose for collecting personal information about you;
    • the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
    • the specific pieces of personal information we collected about you;
  • Request we delete personal information we collected from you, unless CCPA recognizes an exception; and
  • Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.   

 

We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

 

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us at privacy@zam.com.

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at privacy@zam.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers. 

 

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Language

This Privacy Policy is provided in Spanish for users located in Colombia. In case of dispute, the Spanish version of this Privacy Policy shall prevail. 

 

How We Use Your Personal Information

From the entry into force of this Privacy Policy, at the time of the collection of your personal data, we will request your prior authorization, by informing you about the specific purposes of the processing of your personal data for which such consent is obtained under the Privacy Policy.

 

Your authorization may be expressed (i) by writing, (ii) orally or (iii) through unequivocal conducts that allow us to reasonably conclude that your authorization was granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

 

Your Rights

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information.

 

You can contact us if you want to exercise any of these rights through our contact information in the section ‘Contact & Complaints’ of this

 

Privacy Policy. 

Proceedings For The Exercise Of Your Rights

Queries (rights to access): You can file queries regarding the processing of your personal data by us. 

Claims (right to correction and erasure): You have the right to file claims in relation to the processing of your personal data by clearly describing the facts that give rise to your claim. 

Age Restrictions

Parental consent is required for children under the age of 18 years to use the Service.

 

Sensitive Personal Information

Sensitive Personal Information under local law includes passwords, financial information (such as bank account, credit card, debit card or other payment instrument details), biometric data, physical or mental health, sex life or sexual orientation, and/or medical records or history, but does not include information available in the public domain, or provided under Indian laws, including the Right to Information Act, 2005.

 

Sharing Of Your Sensitive Personal Information

 Where we permit any third parties to collect and use Sensitive Personal Information, we shall use reasonable measures to ensure that the third parties do not further disclose the Sensitive Personal Information to the extent required by applicable laws.

 

Withdrawal Of Consent 

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at privacy@zam.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service. 

Consent

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

 

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

 

Data Subject Rights

You have the right to access your personal information stored in our Service from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

 

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

 

Data Retention

We will retain your personal information in line with legal requirements. 

 

Notification to Amendment of this Privacy Policy

If you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, you may stop using or accessing our Service by unsubscribing or ceasing your use of the Service at any time, if you cease to agree with the amended  Privacy Policy.

 

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Minimum Age

If you are under the age of 20, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Service.

 

Consent to transfer to third parties

You consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore and the United States.

 

Your Rights 

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at privacy@zam.com.

You consent to the collection, use, disclosure, export and storage of your personal information as described in this Privacy Policy.

Language

This Privacy Policy is provided in Spanish for users located in Mexico. In case of dispute, the Spanish version of this Privacy Policy shall prevail. 

 

Age Restrictions

You won’t be able to use the Service unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). 

 

Types of Personal Information We Use

For clarification purposes, in section 1 “The types of personal information we use” and section 2 “How we use your personal information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.

 

Purposes of Processing

Some of the purposes of processing stated above are for voluntary purposes, including to show you personalised recommendations and advertising. We may also use your personal data for the voluntary purpose of sending information to your email or SMS that we may consider relevant to you. You may object the processing of your personal data for voluntary purposes as stated in the section “Your Rights” below. 

 

Please, be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and to carry out the transfer of personal data detailed in section 3 “How we store and share your personal information”. 

 

Data Transfer Consent

In general, we do not require your consent to carry out the transfers detailed in section 3 “How we store and share your personal information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.

 

By using the Service and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “Your Rights” below.

 

Your Rights

The sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, and “Advertising” included in Section “Your Rights” above also apply to users that are located in Mexico.  

 

You also have the right to revoke the consent that you have provided us to process your personal data. 

To exercise any of your rights, contact our Data Protection Officer at privacy@zam.com.

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer at privacy@zam.com. 

Minimum Age

You must be at least 18 years of age to be able to use the Service.

 

Your Rights

You are entitled to the following rights:

  • Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
  • Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling. 
  • Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
  • Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
  • Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.


Consent

By consenting to this Privacy Policy, you consent to us:

  • collecting and processing your personal information as described in the section How We Use Your Personal Information” above;
  • sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
  • transferring or storing your personal information in destinations outside the Philippines as described in the section How We Store and Share Your Personal Information” above.

The Service is not directed at Russian users or Russian market and, in particular, is not available in the Russian language. However, if you happen to be using the Service in Russia, by using the Service you consent to:

  • for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this Privacy Policy; if legitimate interests, optimization of the Service or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);
  • the cross-border transfer of your information to any country where we have databases or affiliates, in particular Singapore and the United States;
  • for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy; and
  • for the purposes of Federal Law “On Marketing/Advertising”, that we may share advertising/marketing communications with you, unless you have opted-out from such communications.

 

The sub-sections “Access”, “Correction”, “Erasure”, “Restriction of Processing to Storage Only”, “Objection” and “Advertising” of the section “Your Rights” above apply to users in the Russian Federation.

 

We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Service after the notification.

 

As regards the representative for Russia, you can contact us at privacy@zam.com. Please include the word “Russia” in the subject line of your email.

 

Separate consent for using certain data

By using the Service you also consent to the sharing of your personal information with certain third parties for the purposes set out under section 5 “How We Store and Share Your Personal Information”.

 

You determine, in your discretion, the terms of processing of your personal information (and, if applicable, you consent to the provision of access to your personal data to the general public), including by choosing to use certain features of the Service and by choosing the appropriate privacy settings in respect of your personal information in the Service.

 

We process your personal information subject to the terms of this Privacy Policy.

This consent is granted for as long as you use the Services. The consent may be withdrawn by you (and you may set any restrictions on processing of your relevant personal information) at any time by contacting us (privacy@zam.com): please include the word “Russia” in the subject line of your email.

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa. 

You acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the Service.

 

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at privacy@zam.com.

 

We will give you notice by email of any material changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

By accepting this Privacy Policy, you expressly agree and authorize us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.

 

We maintain international standards and security practices for data protection. When your personal information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.    

 

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information. 

 

Your personal information, if required to be disclosed to the law enforcement agencies, public authorities or other judicial bodies and organizations, it will disclosed upon receipt of written request from such organizations.

 

Your Rights

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.

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