ZPLAY PRIVACY POLICY

1. INTRODUCTION

ZPLAY (Hong Kong) Technology Co., Ltd. ("ZPLAY") is committed to respecting the privacy rights of users of the www.zplayads.com Site and all related Apps and services (collectively with the Site, the “Services”) provided by ZPLAY. ZPLAY has published this Privacy Policy to show its commitment to fair information practices and to the protection of privacy.
This Privacy Policy is only applicable to the Services, and not to any websites or services of third parties ("Third Party Websites"), which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.
By using the Services, you represent and warrant that you have also read and understood, and agree to be bound by, both this Privacy Policy and ZPLAY's separate Terms of Service Agreement (the "Terms of Service"), which incorporates this Privacy Policy by reference. The Terms of Service are available at https://www.zplayads.com/en/service.html. Capitalized terms not defined in this Privacy Policy shall have the same meaning as assigned to them in the Terms of Service.
No Permission Without Agreement. By using the Services, you represent and warrant that you have read and understood, and agree to the terms of, this Privacy Policy. If you do not understand or do not agree to be bound by this Privacy Policy, you must immediately cease using or accessing the Services.

2. CONTROLLERS OF PERSONAL INFORMATION

Any personal information provided to or gathered by ZPLAY via the Services is controlled by ZPLAY (Hong Kong) Technology Co., Ltd., Flat/Rm 1501(682) 15/F, Spa Centre, 53-55 Lockhart Road, Wanchai, Hong Kong.

3. INFORMATION WE COLLECT FROM YOU

Traffic Data. Like most website and mobile application operators, ZPLAY automatically gathers information that web browsers (like Microsoft Edge or Google Chrome) automatically make available, including: (i) IP addresses; (ii) Internet domain names; (iii) types of devices accessing the Services; and (iv) types of Web browsers accessing the Services (collectively "Traffic Data"). Traffic Data is anonymous information that is not meant to personally identify you.
Mobile Data. Similarly, where you download or access the Services through a mobile device, we may receive and gather information about your location and your mobile device, including a unique identifier for your device (collectively, “Mobile Data”).
Personally Identifiable Information. To use certain features of the Services, you may be asked to provide ZPLAY certain personally identifiable information ("Personal Information"). Personal Information includes the following categories, without limitation: (1) "Contact Data" (such as your name, phone number, fax number, mailing address and email address); (2) "Financial Data" (such as your payment information); and (3) "Demographic Data" (such as your ZIP code or gender). In each case, you will be asked to provide Personal Information; the Services will not gather it secretly. ZPLAY may supplement the Personal Information you provide with additional Personal Information gathered from public sources or from third parties (e.g., consumer reporting agencies) who may lawfully provide that information to ZPLAY. You are under no obligation to provide Personal Information, with the caveat that your refusal to do so may prevent you from using certain features of the Services.
Specific Information Collected. ZPLAY collects the following specific items of Personal Information:
           •    your first and last name
           •    your address
           •    your email address
           •    your telephone number
Information You Make Public. The Service may contain features that allow you to upload, post, transmit, display, perform, or distribute content, or other information, including your Personal Information. Any information that you choose to disclose through such features becomes public information over which ZPLAY is unable to exercise control. You should exercise caution when deciding to disclose your Personal Information through such features, and you agree to assume all responsibility for doing so.

4. COOKIES

Cookie Policy. "Cookies" are text files that are placed on your computer by websites that you visit or certain emails that you open. Cookies store a string of information on a user's computer or mobile device, which the user's web browser provides to the Services automatically each time it interacts with the Services. The purpose of Cookies is to identify the user as a unique user of the Services.
ZPLAY uses Cookies on the Services, for example analytics cookies, to gather visitor and access information relevant to customizing the Services to your interests.If you do not wish to have Cookies placed on your computer or mobile device, you should set your web browser to refuse Cookies before accessing the Services. However, certain features of the Services may not function properly without the aid of Cookies. If you refuse Cookies, you assume all responsibility for any resulting loss of functionality.
Advertising on Third Party Websites. ZPLAY may advertise on other Third Party Websites to you after you access the Services. ZPLAY and it third-party marketing partners, including without limitation Google, Inc. ("Google"), may use Cookies (such as the Google Analytics cookie or the DoubleClick cookie), and web beacons (such as the Facebook conversion tracking pixel, see https://en-gb.facebook.com/business/learn/facebook-ads-pixel), including across multiple devices, to inform, optimize, and serve advertisements to you based on your use of the Services. This practice is commonly known as retargeting or remarketing (see https://en.wikipedia.org/wiki/Behavioral_retargeting).
Opting Out of Cookies. You may opt out of third parties' Cookies by visiting the Network Advertising Initiative opt-out page at http://optout.networkadvertising.org/?c=1#!. You can also learn more about how to delete or control Cookies at http://www.aboutcookies.org/.

5. HOW WE USE YOUR INFORMATION

Traffic Data, Mobile Data and Personal Information Gathered Using Cookies. ZPLAY analyzes Traffic Data, Mobile Data and information gathered using Cookies to help ZPLAY better understand who is using the Services and how they are using it. By identifying patterns and trends in usage, ZPLAY is able to better design the Services to improve your experience, and to serve you more relevant and interesting content. From time to time, ZPLAY may release Traffic Data and information gathered using Cookies in the aggregate, such as by publishing a report on trends in the usage of the Services. ZPLAY does not attempt to link information gathered using Cookies to Personal Information.
Personal Information. ZPLAY may use your Contact Data to send you information about ZPLAY and ZPLAY's products and services, and to contact you when necessary in connection with the Services. ZPLAY uses your Financial Data to verify your qualifications for certain features of the Services and, when necessary, to bill you. ZPLAY uses your Demographic Data to customize and tailor your experience on the Services. ZPLAY uses your Third Party Social Media Account Data in accordance with this Privacy Policy and the privacy policies of third party social media companies, such as Facebook and Twitter. As with Traffic Data and information gathered using Cookies, from time to time ZPLAY may release Demographic Data in the aggregate, such as by publishing a report on trends in the usage of the Services.
Disclosure in Connection with Service. ZPLAY discloses Personal Information to those who help it provide services, including without limitation those who perform technical, administrative, and data processing tasks such as hosting, billing, fulfillment, data storage, and security.
By Law or to Protect Rights. ZPLAY discloses Personal Information when required to do so by law, in response to a subpoena or court order, or when ZPLAY believes in its sole discretion that disclosure is reasonably necessary to protect the property or rights of ZPLAY, third parties, or the public.
Business Transfers; Bankruptcy. ZPLAY reserves the right to transfer all Personal Information in its possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of ZPLAY's assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and an opportunity to affirmatively opt out of it. Personal Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by ZPLAY's successor organization.

6. HOW WE PROTECT YOUR INFORMATION

ZPLAY has taken technological and administrative measures to protect your Personal Information against loss, manipulation, or unauthorized access. ZPLAY continually updates its security measures to keep them consistent with advances in technology and able to address any newly developed threats. Unfortunately, no security measures are 100% foolproof, and as such no network or system (including ZPLAY) can be guaranteed to be 100% secure against destruction, loss, alteration, unauthorized disclosure of, or access to information we collect and store. If you believe your information may not be secure for any reason, please contact us immediately through our Contact Us form or at privacy@zplay.com.

7. YOUR RIGHTS WITH REGARD TO YOUR INFORMATION

You have the right to request information about the Personal Information, Traffic Data, and Mobile Data ZPLAY has gathered from you at any time (and free of charge for one request per year). If your Personal Information is incorrect or incomplete, you may request to have it corrected or removed; provided, however, that ZPLAY cannot remove your Personal Information if it is required by law to retain it, or if ZPLAY has other legitimate reasons for its retention. You may withdraw your consent for ZPLAY to use your Personal Information or Data at any time by providing your request to us through our Contact Us form or at privacy@zplay.com. In addition, you can always choose not to provide Personal Information, although it might be needed to participate in the Services.

8. THE PERIOD OF DATA STORING

We store data until it is no longer necessary to provide our services and ZPALY Products, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. Content you delete (including Content containing personal information) may be retained in archived or backup copies in order to enable you to use certain features like revision history and past bill. For instructions on how to permanently delete Content from your ZPALY account, please contact us through our Contact Us form or at privacy@zplay.com.

9. CHILDREN’S PRIVACY

ZPLAY does not solicit or knowingly collect Personal Information from children under the age of 13. If ZPLAY obtains actual knowledge that it has collected Personal Information from a child under the age of 13, ZPLAY will immediately delete such information from its database. Because ZPLAY does not collect Personal Information from children under the age of 13, ZPLAY has no such information to use or disclose to third parties. ZPLAY has designed this Privacy Policy to comply with the Children's Online Privacy Protection Act ("COPPA"). Please contact us through our Contact Us form or at privacy@zplay.com if you believe we have any personal information from or about a child under the age of 13.

10. UPDATES AND CHANGES TO PRIVACY POLICY

Each time you access the Services, the then-current version of this Privacy Policy will apply. Each time you use the Services, we recommend that you check the date of this Privacy Policy and review any changes since the last time you used the Services.

Although most changes are likely to be minor, ZPLAY reserves the right, at any time and without notice, to add to, update, change, or modify this Privacy Policy, simply by posting a new version on this page. Any such addition, update, or change will be effective after the effective date that states in the beginning of this page. Unless ZPLAY obtains your express consent, any revised Privacy Policy will apply only to information collected after the effective date of the revised Privacy Policy, and not to information collected under any earlier Privacy Policy. If you have any questions about this Privacy Policy, please contact us through our Contact Us form or at privacy@zplay.com.

11. CONSENT TO RECEIVE ELECTRONIC COMMUNICATIONS FROM COMPANY

Without limitation, by registering for the Services and/or by providing your name, email, postal or residential address, and/or phone number through the Services, you expressly consent to receive promotional electronic and other communications from ZPLAY, over the short term and periodically, including email communications, regarding the Services, new product offers, promotions, and other matters. You may opt out of receiving promotional electronic communications at any time by (a) following the unsubscribe instructions contained in each communication; or (b) by providing your request to us through our Contact Us form or at privacy@zplay.com.

12. INTERNATIONAL TRANSFERS (INCLUDING TRANSFERS OUTSIDE OF EU)

We process and store information on servers in Singapore, and we may store information on servers in other countries in the future. By using the Services, you consent to the transfer of information (including Traffic Data, Mobile Data, Personally Identifiable Information, and Specific Information) to locations that may be outside of your country of residence. You acknowledge and agree that, as a condition of providing any Content, you can legally transfer it to Singapore or another country.
With respect to transfers of information out of the European Union (EU), we may process some personally identifiable information pursuant to data processing agreements that include the EU Standard Contractual Clauses. To learn more about our data processing agreements, please contact us through our Contact Us form or at privacy@zplay.com.

13. LOST OR STOLEN INFORMATION

You must promptly notify us if your credit, bank, other financial institution information, username, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, bank account information, other financial institution information, username, or password from your account and update our records accordingly. If you encounter this issue, please contact us through our Contact Us form or at privacy@zplay.com.

14. THIRD PARTY WEBSITES

ZPLAY neither owns nor controls Third Party Websites. Accordingly, Third Party Websites are under no obligation to comply with this Privacy Policy except with respect to Personal Information provided directly to them by ZPLAY. Before visiting or providing Personal Information to Third Party Websites, you should inform yourself of the privacy policies and practices (if any) of those Third Party Websites, and should take those steps necessary to, in your discretion, protect your privacy.

15. PROMOTIONAL ACTIVITIES

From time to time, ZPLAY may conduct contests, giveaways, and other promotions (collectively, "Promotional Activities"). Any information submitted in connection with Promotional Activities will be treated in accordance with this Privacy Policy. From time to time, ZPLAY may also ask you to participate in surveys designed to help ZPLAY improve the Services. Any Personal Information provided to ZPLAY in connection with any survey will be used only in relation to that survey and will be disclosed to third parties not bound by this Privacy Policy only in aggregated form.

16. DO NOT TRACK DISCLOSURE

ZPLAY does not respond to "Do Not Track" signals sent by browsers.

17. SPECIAL STATEMENT

We maintain servers around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. If you discover that this privacy policy violates any applicable law or regulation, you should immediately discontinue the use of the Services and/or disclose any personal information to ZPLAY