Legal
Zorg Media LLC Privacy Policy
1. Introduction
This Privacy Policy is incorporated by reference into the Zorg Media LLC Terms of Service (the “Terms”). The terms “Zorg Media LLC,” “we,” and “us” include Zorg Media LLC and our affiliates and subsidiaries. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we use and share that information, and how you can exercise the privacy rights available to you.
2. Scope of policy
This Privacy Policy applies to Personal Information that is Processed by us in the course of our business, including on our Sites, mobile applications, forums, blogs, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of Zorg Media LLC, the “Services”).
This Privacy Policy does not apply to any Personal Information collected by Zorg Media LLC other than Personal Information collected through the Services.
3. Transparency/Notice—Types of Personal Information We Collect and How We Use It
Zorg Media LLC uses the Personal Information you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Information you provide to answer your question or resolve your problem. Also, if you provide Personal Information in order to obtain access to the Services, we will use your Personal Information to provide you with access to such Services and to monitor your use of such Services.
Zorg Media LLC may also use your Personal Information and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services.
Zorg Media LLC may use this information to contact you in the future to tell you about aspects of the Services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt out” of receiving future marketing communications.
In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
If Zorg Media LLC intends on using any Personal Information in any manner that is out of the scope of this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Information is collected.
Types of Personal Information We Collect
Zorg Media LLC collects Personal Information regarding its clients, customers, users, visitors, and guests (collectively “Individuals”).
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 LLC, 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. We can collect information necessary to verify an account such as proof of identity or age.
User-Generated Content. This includes comments, photographs, audio recordings, videos, text, hashtags, and virtual item videos that you choose to create with or upload to the Site (“User Content”) and the associated metadata, such as when, where, and by whom the content was created. Even if you are not a user, information about you may appear in User Content created or published by users on the Site. When uploading the User Content, we may access information, including text, images, and videos, found in your device, with your permission.
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 LLC’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 LLC 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 on Zorg Media LLC’s Site, including 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 legitimate purposes, including:
To Provide Products, Services, or Information Requested. Zorg Media LLC 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 LLC’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 LLC may use Personal Information about you for its administrative purposes, including to:
Measure interest in Zorg Media LLC’s Services.
Develop the Services.
Ensure internal quality control.
Verify Individual identity.
Allow you to register for events.
Communicate about Individual accounts and activities on Zorg Media LLC’s Services and systems, and, in Zorg Media LLC’s discretion, changes to any Zorg Media LLC 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 LLC Products and Services. Zorg Media LLC 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 LLC 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.
Additional Information. When you interact with Zorg Media LLC 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 LLC may store such information itself or such information may be included in databases owned and maintained by Zorg Media LLC 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 LLC 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 LLC 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 LLC’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.
Services via Mobile Devices. From time to time, Zorg Media LLC may provide Services that are specifically designed to be compatible and used on mobile devices. Zorg Media LLC will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Zorg Media Inc’s Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts. In addition, Zorg Media LLC may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Zorg Media LLC to enable Individuals to access accounts and to enable Zorg Media LLC to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Zorg Media LLC may use personal or non-identifiable information transmitted to Zorg Media LLC to enhance these tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Zorg Media LLC provides.
De-Identified and Aggregated Information Use. In an ongoing effort to better understand and serve the users of the Services, Zorg Media LLC 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 and aggregate basis, and Zorg Media LLC may share this data with its affiliates, agents and business partners. Zorg Media LLC may also disclose aggregated 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 LLC’s Services may offer various tools and functionalities. For example, Zorg Media LLC 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 LLC or any other Third Parties for any other purpose.
Other Uses. Zorg Media LLC 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.
Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
We, as well as Third-Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our Site, Services, applications, messaging, and tools, and to recognize you across devices.
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Social Media Widgets. Our Website includes social media features. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third-Party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
Analytics. We may allow Third-Party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Service. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Site, Services, applications, and tools. This includes technologies that allow you access to our Site, Services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions.
Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Site, applications, Services, and tools, including as part of our analytic practices to help us understand how our visitors use our Site, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Site content, applications, Services, or tools.
Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Site, Services, applications, or tools. This may include identifying you when you sign into our Site or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Site.
Advertising or Targeting Related. We may use first-party or Third-Party cookies and web beacons to deliver content, including ads relevant to your interests, on our Site or on Third-Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our Site, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
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 LLC 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.
Zorg Media LLC’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.
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. Legal Basis
Our legal basis for the use of Personal Information:
Performance of the Terms: when we provide you with the Services or communicate with you about them;
Legal obligation: to comply with our legal obligations under applicable laws and regulations; for example, to verify an account and collect proof of identity or age.
Our legitimate interest in operating the Services and communicating with you as necessary to provide these Services; in addition, when processing Personal Information strictly necessary and proportionate to ensure network and information security; and
Your consent when we ask for your consent to process your Personal Information for a specific purpose that we communicate to you in this Privacy Policy. When you consent to process your Personal Information for a specified purpose, you may withdraw your consent at any time, and we will stop processing your data for that purpose.
5. Onward Transfer to Third Parties
Information We Share
We do not disclose your Personal Information, except as provided below.
Upon your request, we can provide the list of the categories of Personal Information we have disclosed about consumers for a business purpose in the past 12 months, if any. We have not sold consumers’ Personal Information in the preceding 12 months.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; iii) customer service activities; and (iv) in connection with the provision of the Site. Zorg Media LLC endeavors to execute appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services or to comply with applicable legal requirements.
Business Partners. Zorg Media LLC may share Personal Information with our business partners, and affiliates for our and our affiliates’ legal purposes or to provide you with a product or Services that you have requested. Zorg Media LLC 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 LLC. Zorg Media LLC 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 LLC 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 LLC 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 LLC 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.
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 contacting [email protected].
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 LLC policies or contracts; (v) to collect amounts owed to Zorg Media LLC; (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.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Zorg Media LLC will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.
International Data Transfers
You agree that all Personal Information collected via or by Zorg Media LLC may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Economic Area, 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 LLC, you explicitly consent to the prosessing, storage and other usage of your Personal Information in these locations.
6. Your Choices
General
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 LLC’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 in this Privacy Policy.
Email and Telephone Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding Zorg Media LLC and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).
Mobile devices
Zorg Media LLC 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 LLC 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.
“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.
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.
7. Your Privacy Rights
Subject to applicable law and this Privacy Policy, you may have the following rights:
Right to access: you have the right to obtain confirmation that your data are processed and to obtain a copy of it as well as certain information related to its processing;
Right to rectify: you can request the rectification of your data which are inaccurate and also add to it. You can also change your Personal Information in your account at any time;
Right to delete: you can, in some cases, have your data deleted;
Right to object: you can object, for reasons relating to your particular situation, to the processing of your data. You may ask us to restrict the processing of your Personal Information;
Right to limit the processing: in certain circumstances, you have the right to limit the processing of your data;
Right to portability: in some cases, you can ask to receive the data that you have provided to us in a structured, commonly used, and machine-readable format or, when this is possible, that we communicate your data on your behalf directly to another data controller;
Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent;
Right to define the instructions relating to the use of your Personal Information post-mortem: you have the right to define instructions relating to the retention, deletion, and communication of your data after your death;
Right to non-discrimination: you have the right not to receive discriminatory treatment as a result of your exercise of rights conferred by laws applicable in your jurisdiction; and
Right to lodge a complaint to the relevant data protection authority: procedure depends on your jurisdiction and is subject to local regulations. For more information, please contact your local data protection authority.
You may have other rights according to applicable legislation in your jurisdiction. Where permitted by applicable law, you may send an e-mail to [email protected] or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, request erasure, or request restriction of or object to processing of Personal Information held about you by Zorg Media LLC. Please include your full name, email address associated with your account, and a detailed description of your data request. Such requests will be processed in line with local laws.
Although Zorg Media LLC makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Zorg Media LLC 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 LLC 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 LLC 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 LLC for the exercise of your rights conferred by the California Consumer Privacy Act.
8. Consent for User Content Involving Third Parties
If you submit, post, or display any content on or through the Services that includes Personal Information of other individuals, you must ensure that you have obtained all necessary consents and permissions from such individuals to collect, use, and share their Personal Information in accordance with this Privacy Policy. Zorg Media LLC shall not be held responsible for any unauthorized collection, use, or disclosure of Personal Information by you in your User Content.
9. Data Retention
Zorg Media LLC retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate purposes, enforce our agreements, and comply with applicable laws.
10. Security of Your Information
Zorg Media LLC 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 LLC 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.
11. Global Data Transfer
By using the Site, Zorg Media LLC may transfer data to the United States, or to locations that may have different data protection laws to your jurisdictions or no data protection laws. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the Saint Vincent and the Grenadines and the adjudication of any disputes arising in connection with Zorg Media LLC or the Site will be in accordance with the Terms.
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.
When we transfer your information outside of the EEA, the UK, or Switzerland, we ensure it benefits from an adequate level of data protection by relying on adequacy decisions and/or standard contractual clauses.
Please contact us by the means mentioned in this Policy if you want to know more about appropriate or suitable data transfer safeguards, the means, and where they are available.
12. 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.
13. Redress/Compliance and Accountability
To keep your Personal Information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via the Services. If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact Zorg Media LLC by email at: [email protected]. We will address your concerns and attempt to resolve any privacy issues in a timely manner.
14. Third-Party Services and Content
Our Services may integrate content or provide links to services and content offered by third parties, such as external systems or platforms. This Privacy Policy does not cover the privacy, security, or other practices of these third parties. Zorg Media LLC is not responsible for the privacy policies or practices of these third-party entities. We strongly advise you to carefully review their privacy policies and terms of service.
15. Important Information
Changes To Our Privacy Policy and Practices
The Services and our business may change from time to time. As a result, at times it may be necessary for Zorg Media LLC to make changes to this Privacy Policy. Zorg Media LLC reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Information. This Privacy Policy was last updated on the date indicated below. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Zorg Media LLC may notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Zorg Media LLC will endeavor to comply with the law or contract.
16. Blockchain-Specific Information and Privacy Risks
Zorg Media LLC may utilize distributed ledger technologies (DLT), such as blockchain, in providing services. For example, in connection with your participation in the $WAP Token Program or any blockchain-related services provided by Zorg Media LLC, we may collect and process certain blockchain-specific information about you. This includes, but is not limited to:
The ID of your cryptocurrency wallet(s) (wallet address).
Information regarding your eligibility for and participation in activities and bonuses offered within the Services.
Details concerning your ownership and transactions of crypto coins and tokens.
Please be aware that blockchain technologies afford a transparent transaction history, meaning that transactions are traceable. Consequently, the wallet address you provide is a public key and, when disclosed, may allow third parties to infer certain information. This public key can potentially be used to associate your wallet transactions with your identity and other Personal Information. Given the inherent public nature of blockchains, we cannot guarantee privacy of your blockchain transactions.
Blockchain, a form of DLT, structures data in blocks linked through cryptographic hash-chaining, ensuring data integrity and creating a tamper-evident record. This structure supports transparency and accountability but is generally immutable, meaning once data is added, it cannot be easily altered or erased. DLT's immutable nature poses challenges in adhering to certain data protection principles, such as data minimization and purpose limitation. Personal Information stored on blockchains, including public keys and transactional data, may fall under the scope of data protection laws. Encrypted or hashed data might be considered Personal Information.
17. Definitions
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 LLC or to which Zorg Media LLC 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 LLC 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. Special categories of personal data may have another meaning under the applicable legislation.
“Site” or “Sites” refers to the web pages, websites, applications, and other platforms operated by Zorg Media LLC, as well as any future online or offline platforms that Zorg Media LLC may operate with the intention of providing Services.
“Third-Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Zorg Media LLC or Zorg Media LLC’s Agents.
Last updated: 10 Apr 2024