2. Scope of policy
The ways that we use and share this Personal Information are described in Sections 3 and 4 respectively.
3. Transparency/Notice—Types of Personal Information We Collect and How We Use It
3.1 Types of Personal Information We Collect
Zorg Media Inc collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
(i) Information You Provide Directly to Us.
When you use the Services or engage in certain activities, such as registering for an account with Zorg Media Inc, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
Account Creation. To create an account, we collect your username, password, and email address.
Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Zorg Media Inc’s newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us. Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or Services and in any manner consistent with the policies provided herein. Posting on the Site. Zorg Media Inc may offer publicly accessible fun pages, blogs, private messages, or community forums. You should be aware that, when you submit your content or disclose information about yourself in on Zorg Media Inc’s fun pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested. Zorg Media Inc may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
Generally manage Individual information and accounts. Respond to questions, comments, and other requests. Provide access to certain areas, functionalities, and features of Zorg Media Inc’s Services. Contact you to answer requests for customer support or technical support. Verify or maintain the quality or safety of a service or device. Allow you to register for events. Administrative Purposes. Zorg Media Inc may use Personal Information about you for its administrative purposes, including to: Measure interest in Zorg Media Inc’s Services. Develop new products and Services. Ensure internal quality control. Verify Individual identity. Allow you to register for events. Communicate about Individual accounts and activities on Zorg Media Inc’s Services and systems, and, in Zorg Media Inc’s discretion, changes to any Zorg Media Inc policy; Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as account management, customer service, or system maintenance. Process payment for products or Services purchased. Process applications and transactions. Prevent potentially prohibited or illegal activities. Enforce our Terms.
Marketing Zorg Media Inc Products and Services. Zorg Media Inc may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Zorg Media Inc may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include: To tailor content, advertisements, and offers. To notify you about offers, products, and Services that may be of interest to you. Auditing relating to interactions, transactions and other compliance activities. For other purposes disclosed at the time that Individuals provide Personal Information; or Otherwise with your consent. You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
When you interact with Zorg Media Inc through the Services, we receive and store certain additional information that we do not use to identify you (e.g., IP address or mobile ID). Zorg Media Inc may store such information itself or such information may be included in databases owned and maintained by Zorg Media Inc affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. Research and Development. Zorg Media Inc may use Personal Information to create de-identified information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Zorg Media Inc may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Zorg Media Inc’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
De-Identified and Aggregated Information Use. In an ongoing effort to better understand and serve the users of the Services, Zorg Media Inc often conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on a de-identified or aggregate basis, and Zorg Media Inc may share this data with its affiliates, agents and business partners. Zorg Media Inc may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Sharing Content with Friends or Colleagues. Zorg Media Inc’s Services may offer various tools and functionalities. For example, Zorg Media Inc allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Zorg Media Inc or any other Third Parties for any other purpose.
Other Uses. Zorg Media Inc may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
3.4 Third-Party Websites And Social Media Platforms
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Zorg Media Inc does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.
We may use third party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
4. Onward Transfer to Third Parties
4.1 Information We Share
We do not disclose your personal information, except as provided below.
Business Partners. Zorg Media Inc may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or Services that you have requested. Zorg Media Inc may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Zorg Media Inc. Zorg Media Inc endeavors to require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Zorg Media Inc provided them. Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
Advertising Partners. Through our Services, Zorg Media Inc may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Zorg Media Inc related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 5 below.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures).We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Zorg Media Inc policies or contracts; (v) to collect amounts owed to Zorg Media Inc; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
4.2 International Data Transfers
You agree that all Personal Information collected via or by Zorg Media Inc may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Zorg Media Inc, you explicitly consent to the storage of your Personal Information in these locations.
5. Your Choices
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Zorg Media Inc’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting [email protected]. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Site and/or information and for other legal purposes as described above.
5.2 Email and Telephone Communications
5.3 Mobile devices
Zorg Media Inc may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Zorg Media Inc may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.
5.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.5 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at https://www.networkadvertising.org/managing/opt_out.asp, or https://www.youronlinechoices.eu/ and https://www.aboutads.info/choices/.
To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
6. Your Privacy Rights
Although Zorg Media Inc makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Zorg Media Inc is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Zorg Media Inc determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Zorg Media Inc will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. As required by law, if you are a California resident, you have the right not to receive discriminatory treatment by Zorg Media Inc for the exercise of your rights conferred by the California Consumer Privacy Act.
7. Data Retention
8. Security of Your Information
Zorg Media Inc takes reasonable steps to protect the Personal Information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Information to Zorg Media Inc via the Internet. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you.
9. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy. If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
10. Children’s Privacy
Our Services are not directed to children under 18 (or other age as required by local law). In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect Personal Information from children under 18. If you learn that your child has provided us with Personal Information without your consent, you may alert us at [email protected]. If we learn that we have collected Personal Information of a child, we will take steps to delete such information from our files as soon as possible unless we have a legal obligation to retain it, and terminate the child’s account.
11. Redress/Compliance and Accountability
12. Other Rights and Important Information
The following capitalized terms shall have the meanings herein as set forth below.
“Agent” means any Third-Party that Processes Personal Information pursuant to the instructions of, and solely for, Zorg Media Inc or to which Zorg Media Inc discloses Personal Information for use on its behalf.
“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Zorg Media Inc or its subsidiaries worldwide.
“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Information” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third-Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Zorg Media Inc or Zorg Media Inc’s Agents.
Last updated: 04 Jan 2022