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| PRIVACY POLICY OF The ZZP Group of Companies
ZZP Group Agreement to Access the Site Scope ZZP professionals control the information about you described in this Privacy Policy. This Privacy Policy describes how we handle your personal information acquired by ZZP as a result of your use of or access to the Site. This Privacy Policy is effective upon acceptance for new users and is otherwise effective September 26, 2006. This Privacy Policy applies to ZZP's collection, use, storage and disclosure of information by ZZP: (a) on its web site and all websites used or maintained by its divisions, subsidiaries and related companies (collectively, the "Site"); (b) on various third party websites; and (c) in connection with ZZP’s other information collection methods, including the purchase of customer lists from third parties, or the use of customer lists from third parties. ZZP is not responsible for the information collection or privacy practices of third party websites or applications Changes to Privacy Policy 1. Collection of Information. 1.2. Survey Information: ZZP collects information from you when you voluntarily complete a ZZP survey, order form, or a registration page either by using the Internet, offline by providing this information through the mail, in person or using a telephone. This information may be collected by surveys, order forms, or registration pages operated by third parties. This method of collection is collectively known as a "Survey." In such Surveys, ZZP or a third party may ask you to provide personally-identifiable information including your name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and ZZP interests, and such other information as may be requested from time to time. ZZP may also collect such information concerning you from another source and use that information in combination with Personal Information collected about you from this Site. Completing the Surveys is voluntary, and you are under no obligation to provide Survey Information to ZZP or a third party, but you may receive incentives from ZZP or a third party in exchange for providing such information. 1.3. Third Party List Information: ZZP may collect information from you when you provide information to a third party and ZZP subsequently purchases, licenses, or otherwise acquires the information from the third party. Such purchased information may include, but is not limited to, your name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, industry of employment, personal and ZZP interests, and such other information as the individual may have provided to the third party. When acquiring this information, ZZP seeks assurances from the third party that it has a right to transfer the information to ZZP and that the third party has a right to provide offers from advertisers to you included on the third party list. 1.4. Other Methods of Collecting Personal Information: Other occasions when ZZP obtains information from you include: (1) your claiming a prize or seeking to redeem an incentive offered by ZZP or by a third party; (2) your requests for assistance through ZZP's customer service department; and (3) when you voluntarily subscribe to a ZZP service or newsletter. 1.5. Cookies, Web Beacons, and Other Information Collected Using Technology: ZZP currently uses cookie and web beacon technology to associate certain Internet-related information about you with information about you in its database. Additionally, ZZP may use other new and evolving sources of information in the future. (a) Cookies: "Cookies" are a feature on your browser software. If enabled, we may write cookies that may store small amounts of data on your computer about your visit to any of the pages of this Site. Cookies assist us in tracking which of our features appeal the most to you and what content you may have viewed on past visits. When you visit this Site again, cookies can enable us to customize our content according to your preferences. We may use cookies to: (a) keep track of the number of return visits to this Site; (b) accumulate and report aggregate, statistical information on Site usage; (c) deliver specific content to you based on your interests or past viewing history; or (d) save your password for ease of access to our Site. You can disable cookies, although the Site may not function properly for you. Your browser preferences can be modified to accept or reject all cookies, or request a notification when a cookie is set. You may read more about cookies at http://cookiecentral.com. In order to use all of the features and functionality of the Site, you need to accept cookies. (b) Web Beacons: A web beacon is a programming code that can be used to display an image on a web page, but can also be used to transfer your unique user identification to a database and associate you with previously acquired information about an individual in a database. This allows ZZP to track certain websites you visit. Web beacons are used to track ZZP behavioral habits for marketing purposes to determine products or services with which you may be interested. In addition to using web beacons on web pages, ZZP also uses web beacons in email messages sent to individuals listed in ZZP's database. (c) IP Addresses: ZZP automatically tracks certain information based upon your behavior on the Site. We may use this information to do internal research on our users' demographics, interests, and behavior to better understand, protect and serve you and our community. This information may include the URL that you just came from (whether this URL is on the site or not), which URL you next go to (whether this URL is on the site or not), your computer browser information, and your Internet Protocol address. Your Internet Protocol ("IP") address is a unique Internet "address" which is assigned to you by your Internet Service Provider ("ISP"). For local area network ("LAN"), DSL, or cable modem users, an IP address may be permanently assigned to a particular computer. IP addresses are automatically logged by Web servers, collecting information about a user's traffic patterns. While the IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual using the Web. Your IP address can, however, reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages. (d) Computer Profiles: ZZP may also collect and accumulate other anonymous data which will help us understand and analyze the Internet experience of our visitors. For instance, ZZP may accumulate visitor data relating to referring domain names, the type of browsers used, operating system software, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords and JavaScript enablement. When you provide us with Personal Information, we are able to use such visitor data to identify you. 1.6. No Information Collected from Children: ZZP will never knowingly collect any personal information about children under the age of 13. If ZZP obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from its database. Because it does not collect such information, ZZP has no such information to use or to disclose to third parties. 1.7. Credit Card Information: ZZP may, in certain instances, collect credit card numbers and related information when an individual places an order from ZZP. When the credit card information is submitted to ZZP, such information is encrypted and is protected with SSL encryption software. ZZP will use the credit card information for purposes of processing and completing the purchase transaction, and the credit card information will be disclosed to third parties only as necessary to complete the purchase transaction. 2. Use of Individual Information. 2.1. Discretion to Use Information: The Personal Information collected on this Site and by third parties will be used to operate the Site and to provide the services or products or carry out the transactions you have requested or authorized. ZZP may change or broaden its use of your Personal Information at any time. ZZP may use your Personal Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, ZZP banner advertising, and package stuffers, and other possible uses. ZZP MAY SELL OR TRANSFER PERSONAL INFORMATION TO THIRD PARTIES FOR ANY LEGALLY PERMISSIBLE PURPOSE IN ITS SOLE DISCRETION. 2.2. Email: ZZP uses your Personal Information to provide promotional offers by email to you. ZZP may maintain separate email lists for different purposes. If you wish to end your email subscription from a particular list, you only need to press the unsubscribe button on the mail message. To unsubscribe from all ZZP's email lists, you must submit your email address to optout@ZaZaPay.com or to the postal address set forth in section 7 of this Privacy Policy. [Note: We suggest highlighting this language in a color font.] Such an unsubscribe request will permanently delete your email from all lists used by ZZP. Email messages sent by ZZP will contain an advertiser's name in the "From:" line but hitting the "Reply" button will cause a reply email to be sent to ZZP. The "Subject:" line of a ZZP email messages will usually contain a line provided from the advertiser to ZZP. 2.3. Profiling and Target Advertising: ZZP uses your Personal Information to make and improve profiles of you and to track your ZZP browsing habits and determine which areas of ZZP's websites are most frequently visited. This information helps ZZP to better understand your interests so that it can target advertising and promotions to you. ZZP may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers. 2.4. Storage of Personal Information and Security: ZZP stores your information in a database on ZZP's servers located in the United States. Our servers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under ZZP's control. However, as you probably know, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your Personal Information that they collect from the Site. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your Personal Information or private communications will always remain private. 3. Use of Personal Information. 3.2. Customer Service: ZZP will use your Personal Information to respond to you, to process, validate and verify requests and/or purchase orders, to fulfill any of your requests and to tailor your experience on the Site. 3.3. Marketing: ZZP will use your Personal Information for any marketing and survey purpose on behalf of ZZP and its affiliates and subsidiaries to send information to you about additional goods or services that may be of interest to you. In addition, ZZP will disclose your Personal Information to third party agents and independent contractors to help us conduct our marketing and survey efforts and to share with other companies in connection with marketing efforts including but not limited to direct marketing. You may have no relationship with these other companies and third parties. 3.4. Complying with Legal Process: ZZP will use or disclose your Personal Information in response to subpoenas, court orders, warrants, or legal process, or to otherwise establish or exercise our legal rights or defend against legal claims or in the event you violate or breach an agreement with ZZP. ZZP will use and disclose your Personal Information if we believe you will harm the property or rights of ZZP, its owners, or those of ZZP 's other customers. Finally, we will use or disclose your Personal Information if we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of ZZP’s Acceptable Use Policy, or as otherwise required by law when responding to subpoenas, court orders and other legal processes. 3.7. Other Access to Personal Information: You have access to your Personal Information collected by the Site and ZZP. You may correct, amend, or delete such Personal Information by contacting legal@ZaZaPay.com. ZZP may also give advertising clients and email services providers access to your email address to verify the origin of the Personal Information collected. 4. Privacy Practices of Third Parties. 4.2. Links: The Site and email messages transmitted from the Site sometimes contain hypertext links to the websites of third parties. ZZP is not responsible for the privacy practices or the content of such other websites. Linked websites may contain links to websites maintained by third parties. Such links are provided for your convenience and reference only. ZZP does not operate or control in any respect any information, software, products or services available on such third party websites. The inclusion of a link to a website does not imply any endorsement of the services or the site, its contents, or its sponsoring organization. 5. Unsubscribe Procedures. Third Party Newsletter – if applicable by submitting your information you agree to receive a third party newsletter from a selected ZZP Affiliate. There is no cost to receive this newsletter. Should you have any questions or concerns or if you would like to discontinue receipt of the newsletter simply email us at newsletter@ZaZaPay.com. 6. Special Notice to California Residents and California User Consumer Rights. As a California resident, you have certain rights under state law that relate to the sharing of your Personal Information with third parties for their own direct marketing purposes. ZZP has chosen to comply with California law SB-27 in the following way: First, individual consumers who reside in California and who have provided their Personal Information to ZZP may request (no more than once per calendar year) information about our disclosures of certain categories of your Personal Information to any third parties. To make such a request, please send an e-mail to legal@ZaZaPay.com and provide us with your name, address, and e-mail address. Within thirty days of receiving such a request, ZZP will provide a list of categories of Personal Information disclosed to third parties during the immediately preceding calendar year, along with the names and addresses of such third parties. All inquiries relating to California SB-27 should be directed to us at legal@ZaZaPay.com.
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