ZincFive’s Privacy Policy Statement

This Privacy Policy (“Privacy Policy” or “Policy”) explains how ZincFive, Inc., a Delaware corporation (“ZincFive” , “Company”, “We” , “Us” or “Our”) may gather, collect, record, hold, distribute, share, disclose or otherwise use any information or data about any user (“User” or “You” or “Your”) of  ZincFive’s website at www.zincfive.com (“ZincFive Website”) or through any other site, program, activity, technology platform, technology application, or service offered by ZincFive or any of the Company’s Affiliates, as such term is defined in this Policy (the ZincFive Website and these other programs, activities, platform, applications and services are collectively referred to as “Company Program(s)”).

BY CONTINUING TO USE THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM OFFERED BY THE COMPANY, YOU HEREBY AGREE TO BE BOUND BY ALL OF THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AS THEY ARE PRESENTED TO YOU AS OF THE DATE OF YOUR FIRST USE OF THE COMPANY WEBSITE OR ANY OTHER COMPANY PROGRAM. 

NO CHANGES (ADDITIONS OR DELETIONS) BY YOU TO THIS POLICY WILL BE ACCEPTED BY ZincFive. IF YOU DO NOT AGREE TO ALL THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, OR YOU DO NOT WISH YOUR PERSONAL INFORMATION TO BE USED PURSUANT TO THIS PRIVACY POLICY, THEN YOU SHOULD NOT USE THE ZincFive WEBSITE OR ANY OTHER ZincFive PROGRAM AND YOU SHOULD NOT PROVIDE ANY OF YOUR PERSONAL INFORMATION TO ZincFive. 

THIS IS A BINDING CONTRACT BETWEEN YOU AND ZincFive AND YOU SHOULD DOWNLOAD AND PRINT THIS PRIVACY POLICY FOR YOUR RECORDS. WE RESERVE THE RIGHT TO AMEND, UPDATE OR OTHERWISE CHANGE THIS PRIVACY POLICY AS MORE FULLY SET FORTH HEREIN.

1. INFORMATION WE COLLECT

During a User’s access or use of the ZincFive Website or any other Company Program, ZincFive may, either directly or by using its service providers, gather, collect, record, hold, distribute, share, disclose or otherwise use personal information or data about You which You provide to Us, as described in Section 1.1 below, or which is automatically collected, as described in Section 1.2 below (hereinafter collectively referred to as the User’s “Personal Information” or “Personal Data” as collectively referred to under the General Data Protection Regulation, “GDPR”).  

1.1 Information You Provide to Us.

We collect Personal Information that You provide directly to Us, including without limitation any Personal Information You provide during Your use of the ZincFive Website or any other Company Program. For example, we may collect Personal Information from You if You:

• Provide Us with any data about You through the ZincFive Website or any other Company Program, or via telephone or electronic means or, any other activities;
• Create an account with Us;
• Seek, purchase or otherwise request any of ZincFive’s products/services (collectively the “products/services”);
• Seek any information about Your purchase, exchange, or return of any of ZincFive’s products/services;
• Request any customer support;
• Request any exchange or return of any of ZincFive’s products/services;
• Request any information from or about ZincFive, such as a newsletter, e-alert, or any other information about Our products/ services, events or business partners;
• Fill out any other information through any Company Program;
• Communicate with any other representative of ZincFive;
• Communicate with Us via third party social media sites;
• Otherwise communicate with Us in any other way. 

In these instances, the following are the types of Personal Information that may be collected from You:

• Your name;
• Mailing address and/or billing address;
• E-mail address;
• Phone (or mobile) number;
• Date of birth or age;
• User name/password for account;
• Credit or debit card number and other information about the same (if You make a payment either directly to Us or by using a third party payment provider that handles payments and will receive Your payment card information);
• Information about Your bank or checking account (if you make a payment through Your bank transfer);
• Information You provide when You seek, purchase, or otherwise request any of ZincFive’s goods/services, including product/service parameters or preferences You provided when making such request;
• If You choose to subscribe, receive, or otherwise participate in any Newsletters/Blogs, We may collect from You, in addition to the above described Personal Information, additional information from and/or about You, such as additional demographic information or other information You may provide as part of Your participation in any such Newsletter/Blogs. 
• Name of the person’s employer, the person’s title/position at employer, and any membership in professional associations;
• If You choose to participate in any Customer Surveys, We may collect from You, in addition to the above described Personal Information, additional information from and/or about You, such Your purchase history, habits, and/or preferences or other information You may provide as part of Your response or feedback to the Customer Surveys, and
• Photos, videos, audio or similar content uploaded by You.

If we work with third-party service providers, we may obtain information about you, including but not limited to demographic information, contact information, publicly available data, and email addresses. We may use this information for legitimate business purposes, including the performance of a contract, customer support, marketing and fraud prevention in connection with the Website. If you receive an email from us which was sourced from a third-party service provider and wish to opt out, please use the unsubscribe functionality found at the bottom of the email to do so.

1.2 Information Automatically Collected.

When a User accesses or otherwise uses the ZincFive Website or any other Company Program, We automatically collect certain Personal Information about You, including:

• Device Information. We (or our service providers) may collect information about the computer, tablet, phone or other device you use to access any of Company Programs, including the Internet Protocol address, hardware models, operating system and version, mobile network information and other unique device identifiers (hereinafter collectively referred to as “Device Identifiers”). 

• Cookies and other Web-based Tracking Technologies: We (or our service providers) may use different technologies such as cookies, web beacons, or other types of small temporary files or web-based tracking technologies to gather certain information. A cookie is a small data file stored by Your web browser on Your computer or mobile device (hard drive) that helps Us to improve the way We deliver our ZincFive Website or other Company Programs to You, helps Us improve Your overall experience using Our ZincFive Website or other Company Programs, and/or helps Us analyze the areas and features of our Company Programs that are most popular or to detect fraud.  Web beacons are electronic images that may be used in Our Company Programs or emails and help deliver cookies, count visits, and understand usage. Like many other websites, cookies and these other web-based tracking technologies may be used by Us (or our service providers) during Your visit to the ZincFive Website or other Company Program in order to improve Your individual experience as a User of the ZincFive Website or other Company Program or to generally improve or enhance the overall functionality of the ZincFive Website or other Company Program. While most websites automatically accept cookies for these purposes, You may be able to instruct Your browser to stop accepting cookies or prompt You before accepting a cookie from the sites You visit, including the ZincFive Website. SEE SECTION 5.1.5 OF THIS PRIVACY POLICY WHICH PROVIDES FURTHER NOTICE ABOUT HOW THESE COOKIES ARE USED AND PROVIDES INSTRUCTIONS IF YOU WANT TO DISABLE ANY OF THESE COOKIES.
• Geo-location Data: Subject to any of Your device permissions, We (or our service providers) may be able to collect information about the precise location of your device or may gather other general location data based on GPS data, mailing address, and/or billing address (hereinafter collectively referred to as “Geo-location Data”).
• Social Media Information. If any of Our Company Programs offer any social media features, such as the Facebook Like buttons or similar social media interactive mini-programs (“Social Media Activities”), these features may collect Your Internet Protocol address, which page You are visiting on Our Company Program, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on Our Company Program. Your interactions with these features maybe governed by the privacy policies of ZincFive providing it (see Section 8 regarding Third Party Sites).

• Additional Sources From Whom Or Where We May Receive Or Collect Information About You.

In addition to the Personal Information provided by You as described in Section 1.1 and in addition to the collection of Personal Information as described in Section 1.2, the following are additional ways We may collect Personal Information about You or additional sources from which We may receive Personal Information about You:

• From Our Service Providers/Contractors. From Our Service Providers/Contractors, as such term is defined in Section 3 herein, including without limitation from Our Data Analytics Providers or from Our Third Party Application Providers, as such terms are defined in Section 3 herein. 

• From Our Advertising Network. From Our Advertising Network, as such term is defined in Section 3 herein. 

• From Distributors, Resellers, or Retailers.  From any other distributors, resellers, or retailers that We work with or with whom We have a relationship. 

• Employees. We may collect Personal Information in the context of Your role as an applicant to, an employee of, director of, or officer of, Our business. The Personal Information We collect in these cases may include name, Social Security number, address, date of birth, gender, race, ethnicity, bank account and routing number, tax filing status, emergency contact information, telephone number, family member names, educational background, criminal background, employment history, medical provider information, dependent name(s), date of birth, gender and address, medical insurance provider, compensation and benefits data, workplace, and title. We only use this information for purposes of evaluating qualifications related to Your job application or Your job duties; evaluating Your performance; or for providing compensation, benefits, and services in the context of the employment relationship. The Personal Information described in this paragraph is the “Employee Data”. 

• Individuals Representing Businesses. We may collect Personal Information in the context of Your role as a representative of a business. The Personal Information We collect in these cases may include Your name, address, email address, telephone, date of birth, gender, Social Security number, and personal financial information. We use this information for communicating with You in Your role as a representative of a business or if You are an owner of a business to evaluate Your creditworthiness. The Personal Information described in this paragraph is the “Biz Rep Data”.
• Other Sources From Which We Collect Personal Information. We may collect Personal Information about You from a number of sources in addition to those means of collection indicated above, including offline or through sources unrelated to Your use of Our ZincFive Website or other Company Programs.  For example, We may collect Personal Information from publicly accessible sources (e.g., property records); directly from a third party, (e.g., credit reporting agencies or customer due diligence providers); or from a third party with Your consent (e.g., Your bank). We may merge or co-mingle that Personal Information with the Personal Information We maintain about You and other data collected on or through Our ZincFive Website. Categories of sources from which We may collect Personal Information include: advertising networks; internet service providers; data analytics providers; government entities; operating systems and platforms; and social networks.

1.4 Exclusions From Personal Information Subject to this Privacy Policy.

“Personal Information” for purposes of this Privacy Policy does not include any of the following types of information:

(i)  Publicly available information from government records.

(ii) De-identified or aggregated consumer information.

2. HOW WE USE YOUR INFORMATION.

2.1 Primary Ways We Use Your Information.  User’s Personal Information may be gathered, collected, recorded, held, or otherwise used by or on behalf of ZincFive (including by Our service providers) to provide, maintain, and improve our Services to You, including for the following purposes:

• Process Your transactions with the Company, including without limitation: (i) fulfilling Your orders (including shipping if applicable), process exchanges and/or returns and send shipping notifications; (ii) scheduling any of Your appointments or meetings with the Company; 
• Send support and administrative messages, and respond to your comments, questions, and customer service requests;
• Communicate with you about products, services, offers, or  any other events offered by Us and others, and/or to offer and provide you with news and information ZincFive thinks will be of interest to You (if you prefer not to receive promotional communications from Us, you may “Opt Out”  at any time by following the “Opt Out” instructions in Section 4 herein;
• Allowing you to sign up and participate in any other ZincFive communication resources, including without limitation any ZincFive newsletters or blogs (if you prefer not to continue to receive these other ZincFive communications, you may “Opt Out”  at any time by following the “Opt Out” instructions in Section 4 herein;
• Monitor and analyze trends, usage, and activities in connection with ZincFive’s goods/services and industry;
• To protect against fraud or unauthorized transactions, including by identifying potential unauthorized users or hackers;
• Personalize Your experience and the advertisements and content You see when You use any Company Program based on Your preferences, interests, and browsing and purchasing behavior;
• For compliance purposes as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for ZincFive’s tax reporting) or as may be requested under any subpoena;
• To facilitate Your use of various social media sharing features or other integrated tools (including, for example only, certain Facebook features, such as a Facebook “Like” button) which You may use as part of social media pages; 
• To facilitate any contests, sweepstakes, loyalty programs, or promotions and process and deliver entries and rewards; or
• To carry out any other purpose described to You at the time the Personal Information is collected.

2.2 Other Ways We May Use Your Information.  In addition to the above, Your Personal Information may be gathered, collected, recorded, held or otherwise used for the following additional purposes: 

• To use with, or otherwise distribute, share or disclose to, any of ZincFive’s professional advisors such as attorneys or accountants (“Outside Professionals”) in order to facilitate the professional advice from those Outside Professionals; or 
• To use with, or otherwise distribute, share or disclose to, any government agencies or third parties in order to comply with, or otherwise pursuant to, any subpoena, court order, or other governmental order, law or regulation (including without limitation tax reporting). 
• Government Entities. To use with, or otherwise distribute, share, or disclose to, any court, tax authorities, law enforcement authorities, other administrative agencies, other governmental agencies, or any other government entities (collectively, “Government Entities”) in order to comply with, or otherwise pursuant to, any subpoena, court order, or other governmental order, law, or regulation, or in order to respond to any request of any Government Entities, including without limitation tax reporting (See Section 3). 

2.3 Other Terms Regarding the Use of Your Information.

2.3.1 ZincFive may also use or share Your Personal Information only for the purposes as described in this Section 2 and in Section 3 herein, unless We reasonably determine We need to use it for another reason and that reason is compatible with the original purpose(s) described herein.  For example, We consider de-identification, aggregation, and other forms of anonymization of Personal Information to be compatible with the purposes listed herein and in Your interest because the anonymization of such information reduces the likelihood of improper disclosure of that information. If We need to use Your Personal Information for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so.

2.3.2 PLEASE NOTE THAT WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR ADDITIONAL CONSENT IN COMPLIANCE WITH THIS PRIVACY POLICY AND WHERE DOING SO IS REQUIRED OR PERMITTED BY LAW INCLUDING WITHOUT LIMITATION ANY SUBPOENA OR OTHER TYPES OF COURT ORDERS.

3. SHARING OF INFORMATION

We may distribute, share or disclose Personal Information about You as follows or as otherwise described herein:

• Affiliates and Subsidiaries. We may disclose Your Personal Information with our affiliates or subsidiaries for any of the purposes described herein.
• Service Providers/Contractors. We may share or disclose Your Personal Information with Our service providers or third-party vendors, or contractors that We engage or retain in connection with the provision of the Company Programs or otherwise to help Us carry out and fulfill a business or commercial purpose for the Company, including without limitation the following types of service providers or contractors (all of the above are hereinafter collectively referred to as ”Service Providers/Contractors”):
  • Email, internet, or other telecommunication Service Providers/Contractors;
  • Cloud, other data storage, website hosting, or other hosting Service Providers/Contractors;
  • Third party payment Service Providers/Contractors, including without limitation third party credit card processors (see Third Party Application Providers below in this Section 3); 
  • Data analytics companies who assist Us with various types of data analytics, web analytics, and app analytics (see Data Analytics Providers and Data Analytics Tools or Services below in this Section 3);
  • Third party delivery or shipping Service Providers/Contractors; 
  • Third party app or software designers; 
  • Database management; and
  • Third party advertising or marketing companies that We engage (see Advertising Networks below in this Section 3).  
  • Other third party contractors or service providers We engage to assist Us in providing Our products/services;

• • Third Party Application Providers. If a third party application is used to support Our Company Programs, We may share or disclose Your Personal Information to such third party application providers, including without limitation third party credit card processors, other third party payment service providers, or intermediary services that assist in processing Your payments service provider (collectively ”Third Party Application Providers“).

• Data Analytics Providers and Data Analytics Tools or Services. We may use analytics tools or services provided by a third party data analytics service provider (”Data Analytics Providers“) or We may use one of their tools, such as, but not limited to Google Analytics, to collect and process certain analytics data (“Data Analytics Tools or Services”). These Data Analytics Tools or Services may also collect data about Your use of other websites, apps, and online resources. SEE SECTION 5 OF THIS PRIVACY POLICY THAT PROVIDES FURTHER NOTICE ABOUT HOW SOME OF THESE DATA ANALYTICS PROVIDERS AND DATA ANALYTICS TOOLS OR SERVICES MAY USE COOKIES AND ALSO PROVIDES INSTRUCTIONS IF YOU WANT TO DISABLE ANY OF THESE COOKIES.

• • Aggregated Form. We may make certain automatically-collected, aggregated, or otherwise de-identified Personal Information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through Company Programs.
  • Advertising Network. We may work with third party sales reporting companies or third party advertising or marketing associations (such as third party sales representative organizations) (collectively, “Advertising Network”) in order to provide You with advertisements, marketing or other information that We think may interest You. These Advertising Network may set or access their own cookies, pixel tags or similar technologies on our Company Programs or they may otherwise collect or have access to data about You which they may collect over time and across different online services. These Advertising Network may also provide Us with their own independent data about potential customers and such data could include data about You previously collected by the Advertising Network. 
  • Social Media Features. Company Programs may, now or in the future, offer social media features, including certain sharing tools or other integrated tools (such as the Facebook “Like” button), which let You share actions that You take on Our social media pages. Your use of such features enables the sharing of Personal Information with the public, depending on the settings You establish with the entity that provides the social sharing feature.
  • Merger, Sale, or Other Asset Transfers. We may share or disclose or otherwise transfer Your Personal Information to ZincFive’s Outside Professionals (as defined in Section 2 herein), other advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which We are acquired by or merged with another. 
  • ZincFive’s Outside Professionals. We may share or disclose Your Personal Information with any of ZincFive’s Outside Professionals (as defined in Section 2 herein) in order to facilitate the professional advice such Outside Professionals provide to ZincFive. 
  • Consent. We may also share or disclose Your Personal Information with your permission.
• As Required By Law, Subpoena or Similar Government Order. We may access, preserve, share, or disclose Your Personal Information if We believe doing so is required or appropriate to: (i) comply with all laws or regulations, including any tax reporting requirements of ZincFive; (ii) comply with any other law enforcement requests or legal process, such as a court order or subpoena; (iii) respond to Your requests; or (iv) protect Your, Our, or others’ rights, property, or safety. FOR THE AVOIDANCE OF DOUBT, WE MAY BE REQUIRED TO DISCLOSE YOUR PERSONAL INFORMATION TO: (I) TAXING AUTHORITIES AS PART OF OUR TAX REPORTING REQUIREMENTS; OR (II) LAW ENFORCEMENT AUTHORITIES OR OTHER GOVERNMENTAL AGENCIES OR VIA SUBPOENA ARISING OUT OF YOUR USE OF ANY UNLAWFUL OR INFRINGING CONTENT WHILE USING ANY ZincFive PROGRAM.

4. CERTAIN ADDITIONAL CHOICES YOU MAY HAVE ABOUT YOUR INFORMATION  

4.1 Opt-Out From Receiving Information From ZincFive.

4.1.1 You Can Opt-Out From Receiving Information From ZincFive.  In the event a User has provided ZincFive with Personal Information such as that discussed above, and thereafter a User does not want to continue to directly receive further notices, or information from ZincFive such as emails about ZincFive’s products or services, the User must send an email message to Privacy@zincfive.com  stating that the User no longer wants to receive these communications directly from ZincFive (“Opt Out”). Once ZincFive has received the User’s request to Opt Out, ZincFive will use commercially reasonable efforts, in a commercially reasonable time period, to try to carry out such User’s request to Opt Out; provided, however, ZincFive will not have any obligation to retrieve, and cannot prevent the further use by others of, such User’s Personal Information which may have been shared up to that time with other parties as permitted by the provisions of this Privacy Policy. 

4.1.2 Effect of Communication Opt-Out.  If a User elects to Opt Out, and provided such User has properly delivered its Opt Out request to ZincFive in accordance with Section 4 herein, such User will no longer receive emails directly from ZincFive after a commercially reasonable time from the date such User sent its Opt Out notice to ZincFive. However, ZincFive does not have any obligations under, or liability arising out of, this Privacy Policy with regard to a User’s decision to share its Personal Information with, Our use of, any other internet websites, forums, or programs that the User may have linked to via the ZincFive Websites which are not under ZincFive’s direct control or ownership. Accordingly, after sending Your Opt Out to ZincFive, You may need to contact these other entities directly regarding their use of Your Personal Information.

4.3. Do Not Track Notice.

Some browsers have a “DO NOT TRACK” feature that lets website users inform websites or other applications that they do not want to have their online activities tracked. These “do not track” features may also give website users other choices regarding the collection of their personal identifiable information. However, these “do not track” features and “do not track’ signals are not yet uniform. ACCORDINGLY, EACH USER OF THE ZincFive WEBSITE OR ANY OTHER COMPANY PROGRAM IS HEREBY NOTIFIED THAT THE ZincFive WEBSITE AND THE OTHER COMPANY PROGRAMS ARE NOT CURRENTLY SET UP TO RESPOND TO ANY OF THE USER’S “DO NOT TRACK” FEATURES OR “DO NOT TRACK” SIGNALS. This “DO NOT TRACK” notice is provided to Users at the recommendation of the U.S. Federal Trade Commission and to residents of the State of California as required pursuant to the California Online Privacy Protection Act (CalOPPA). 

5. GEO-LOCATION DATA

You may be able to prevent Your device from sharing precise location information, including without limitation some or all of the Geo-Location Data described in Section 1 above, at any time through Your device’s operating system settings 

5.1 Cookies Policy; How You Can Disable Cookies.

5.1.1 What Are Cookies?  As is common practice with almost all professional websites, the ZincFive Website or other Company Programs use cookies, which are tiny files that are downloaded to Your computer, to improve Your experience. This section describes what information they gather, how We use it, and why We sometimes need to store these cookies. We will also share how You can prevent these cookies from being stored, however, this may downgrade or “break” certain elements of a website’s functionality.

5.1.2 How We Use Cookies.  

• WE USE COOKIES FOR A VARIETY OF REASONS AS INDICATED IN SECTION 1, SECTION 3, AND THIS SECTION 5 OF THIS PRIVACY POLICY.

• In addition to the description of cookies as set forth in Section 1 and Section 3 of this Privacy Policy, We may use analytics tools, services or similar tools provided by third parties Data Analytics Providers (as defined in Section 3 herein) to help analyze how You and other Users utilize ZincFive products/services. These analytics tools use cookies and other tracking technologies to collect information such as how often Users visit the ZincFive Website or other Company Programs, what pages they visit, and what other websites they have used prior to visiting the ZincFive Website. We use the information We get from these analytics tools to improve Our products/services. Analytics tools collect the IP address or other unique identifier assigned to You and/or Your devices on the date You visited them. Analytics tools provided by third parties plant a persistent cookie on Your web browser to identify You as a unique User the next time You visit the ZincFive Website, and the treatment of that information is governed by the third party’s terms of use and/or privacy policy.

• Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that You leave on all cookies if You are not sure whether You need them or not in case they are used to provide a service that You use. 

• BY USING THE ZincFive WEBSITE, YOU GIVE CONSENT FOR US TO SHARE YOUR PERSONAL INFORMATION WITH THESE PROCESSORS, AND FOR THEM TO TRANSFER THIS INFORMATION ONWARD TO THEIR PARTNERS IN CONNECTION WITH PROVIDING YOU THE PRODUCTS/SERVICES.

5.1.3 Disabling Cookies.  You can prevent the setting of cookies by adjusting the settings on Your web browser (see, for example, Your browser Help for how to do this, including “Incognito” in Chrome, “In Private” for Internet Explorer, “Private Browsing” in Firefox and Safari, etc.). Be aware that disabling or deleting cookies in Your web browser: (i) will usually affect the functionality and/or usability of the ZincFive Website, other Company Programs and/or other websites that You visit; and/or (ii) will usually result in also disabling certain functionality and features of the ZincFive Website or any other Company Programs. 

5.1.4 The Cookies We May Set

In addition to the disclosures We have provided in Section 1 and Section 3 of this Policy regarding cookies or other web-based tracking technologies or analytics tools, the following section details certain ways that We may set or use cookies or other web-based tracking technologies on the ZincFive Website or any other Company Program: 

• Email newsletters related cookies: The ZincFive Website or other Company Programs may offer newsletters or other types of email subscription services and cookies may be used to remember if You are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.

• Orders processing related cookies: The ZincFive Website or other Company Programs may offer e-commerce or payment facilities and some cookies are essential to ensure that Your order is remembered as You move between pages so that We can process it properly.

• Contact or comment related cookies: When You submit any other data through the ZincFive Website or other Company Programs, certain contact or comment-related cookies may be set to remember Your User details for future correspondence or transactions.

5.1.5 Third Party Cookies.  In certain instances, cookies provided by third parties may also be used. In addition to the disclosures We have provided in Section 1 and Section 3 of this Policy regarding use of cookies or other web-based tracking technologies or analytics tools by third parties, the following section details certain third party cookies You might encounter through the ZincFive Website or any other Company Program:

• As noted in Section 3, the ZincFive Website or other Company Program may engage Data Analytics Providers and/or use Data Analytics Tools or Services (including without limitation Google Analytics) that provides Us with widely-used analytics tools or services to help Us better understand how You and other Users are utilizing the ZincFive Website or other Company Program in order to allow Us to improve Your experience. These cookies may track things such as how long You spend on the ZincFive Website or other Company Program and the pages that You visit so We can continue to produce engaging content.  For more information about Google Analytics cookies, see the official Google Analytics page. 
• Data Analytics Providers and/or use Data Analytics Tools or Services may also be used to track and measure usage of this ZincFive Website or other Company Program (including, but not limited to, tracking things such as how long You spend on a website or pages that You visit) so that We can continue to produce engaging content, help Us to understand how We can improve the ZincFive Website or other Company Program site for You and and/or to give Us a better understanding of broader industry trends.
• From time to time, We test new features and make subtle changes to the way that the ZincFive Website or other Company Programs are delivered. When We are testing new features, these cookies may be used to ensure that You receive a consistent experience while on the ZincFive Website or other Company Program while ensuring We understand which optimizations the Users appreciate the most.
• As We promote Our products/services, it’s important for Us to better understand statistics about how many of the visitors of the ZincFive Website or other Company Programs actually make a purchase or which Company products/services the Users viewed the most and, thus, these are additional types of data that these cookies will track. We consider this to be important to You as it means that We can accurately make business predictions that allow Us to monitor Our advertising and product/service costs to ensure the best possible services to all of the Users.
• Certain of Our Advertising Networks (as defined in Section 3 of this Policy) may advertise on Our behalf, and affiliate tracking cookies allow Us to see if Our customers have come to the ZincFive Website or other Company Programs through one of these Advertising Network sites or sources.
• As noted in Section 3 of this Privacy Policy, We also use social media buttons and/or plugins on this ZincFive Website or other Company Programs that allow You to connect with Your social network in various ways. For these to work, many social media sites (such as, but not limited to, Facebook, Instagram, or LinkedIn) may set cookies through the ZincFive Website or other Company Program and such cookies may be used to enhance Your profile on their social media site or to contribute to the data they hold for various purposes outlined in their respective privacy policies. 

6. ENFORCEMENT OF THIS PRIVACY POLICY BY ZincFive.

Each User confirms and agrees that by the User’s act of using any of the Company Programs, including without limitation uploading any of the User’s Personal Information or any other content via any Company Program, the User: (a) unconditionally agrees to all of the terms and conditions of this Privacy Policy; and (b) further agrees that no provision of this Privacy Policy shall limit, condition, alter, or amend, in any way whatsoever, any rights that User may have separately granted to ZincFive pursuant to any other agreement that the User may have separately entered into with ZincFive. 

7. USER RESPONSIBLE FOR UPDATING USER’S OWN PERSONAL INFORMATION.

Users are solely responsible for correcting, updating, or modifying any and all of the User’s Personal Information as it appears in, and as otherwise stored or contained in, any Company Program. Without in any way limiting the foregoing, User acknowledges and agrees that ZincFive does not have an independent obligation to maintain the accuracy or completeness of any of Personal Information provided by the User to ZincFive, including such Personal Information once it is stored, described or otherwise contained in the ZincFive Website or in any other Company Program. 

8. LINKS TO, AND USE OF, THIRD PARTY SITES OR PROGRAMS.

The ZincFive Website or other Company Programs may now or in the future provide links or other access to Internet websites, forums or other programs which are not under ZincFive’s sole control and not solely owned by ZincFive (collectively referred to as “Third Party Sites”). If a User clicks on a link to, or otherwise gains access to, any such Third Party Site, the User will be transported to one of these Third Party Sites. 

THIS PRIVACY POLICY ONLY APPLIES TO THE ZincFive WEBSITE AND THE OTHER COMPANY PROGRAMS DIRECTLY OWNED BY ZincFive.  THEREFORE, THIS PRIVACY POLICY: (A) DOES NOT DESCRIBE THE PRIVACY POLICIES OF ANY OF THESE THIRD PARTY SITES; AND (B) DOES NOT GOVERN THE COLLECTION OR USE OF YOUR PERSONAL INFORMATION BY THE THIRD PARTY SITES. ZincFive IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF ANY OF THESE THIRD PARTY SITES.  IF A USER CLICKS ON A LINK TO, OR IS SENT TO A LINK OF, OR OTHERWISE GAINS ACCESS TO, A THIRD PARTY SITE, THE USER SHOULD REVIEW THE PRIVACY STATEMENTS OR POLICIES OF SUCH THIRD PARTY SITES (IF ANY) TO DETERMINE THAT PARTICULAR THIRD PARTY SITES’ PRACTICES WITH REGARD TO THE COLLECTION AND USE OF PERSONALLY IDENTIFIABLE INFORMATION. 

WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, EACH USER AGREES THAT IF THE USER USES ANY THIRD PARTY SITES IN ANY WAY, THE USER IS ADVISED THAT ANY OF THE USER’S PERSONAL INFORMATION THAT THE USER PROVIDES TO THAT THIRD PARTY SITE MIGHT BE READ, COLLECTED, SHARED, DISTRIBUTED, OR OTHERWISE USED BY OTHER USERS OF THAT THIRD PARTY SITE OR BY ANY OTHER THIRD PARTIES, AND COULD BE USED TO SEND THE USER UNSOLICITED MESSAGES. 

ZincFive IS NOT RESPONSIBLE FOR ANY PERSONAL INFORMATION THAT THE USER ELECTS TO SUBMIT IN, OR OTHERWISE MAKE AVAILABLE TO, THESE THIRD PARTY SITES, WITH THE EXCEPTION THAT USER PERSONAL INFORMATION OF DATA SUBJECTS RESIDENT IN THE EUROPEAN UNION THAT IS RECEIVED BY ZincFive FROM THIRD PARTY SITES SHALL BE SUBJECT TO THE DATA PROTECTION TERMS AND CONDITIONS OF THE GENERAL DATA PROTECTION REGULATION (“GDPR”) SUMMARIZED IN APPENDIX 2 HEREOF.

Any link to any Third Party Site from the ZincFive Website or any other Company Program does not imply any endorsement of the privacy practices of such Third Party Site by ZincFive, and no such Third Party Site is authorized to make any representation or warranty on our behalf.

9. INFORMATION SECURITY

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, We cannot guarantee its absolute security. We make efforts to protect Your Personal Information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If You have questions about the security of Your Personal Information, contact the Company at the email or regular mailing address specified in the Contact Us section below.

10. DATA RETENTION

We will retain Your Personal Information for as long as necessary to fulfill the purposes for which We collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, We consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Your Personal Information, the purposes for which We process Your Personal Information, whether We can achieve those purposes through other means, and the applicable legal requirements. 

11. THIS PRIVACY POLICY MAY CHANGE.

We reserve the right to change, modify or clarify this Privacy Policy at any time (“Changes”), so please review it frequently. All such Changes to this Privacy Policy will take effect immediately upon their posting on the ZincFive Website or any other Company Program. ZincFive reserves the right to make any and all Changes to the Privacy Policy without providing individualized notice to a User.  YOU HEREBY AGREE THAT YOU ARE BOUND BY ALL CHANGES TO, AND ANY UPDATED VERSION OF, THIS PRIVACY POLICY THAT ARE IN EFFECT EACH TIME YOU USE THE ZincFive WEBSITE OR ANY OTHER COMPANY PROGRAM. THUS, THE TERMS OF THIS PRIVACY POLICY MAY BE DIFFERENT THE NEXT TIME YOU USE THE ZincFive WEBSITE OR ANY OTHER COMPANY PROGRAM.  ANY USE OF THE ZincFive WEBSITE OR ANY OTHER COMPANY PROGRAM BY YOU AFTER SUCH CHANGES SHALL BE DEEMED TO CONSTITUTE ACCEPTANCE BY THE USER OF ALL SUCH CHANGES WITH REGARD TO THE ZincFive WEBSITE AND ALL COMPANY PROGRAMS.  EACH USER SHOULD REGULARLY REVIEW AND PRINT THIS PRIVACY POLICY FOR THE USER’S RECORD. If ZincFive is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products or services to You.

• ADDITIONAL NOTICE UNDER THE CALIFORNIA CONSUMER PRIVACY ACT and THE EUROPEAN UNION’S GENERAL DATA PROTECTION REGULATION (“GDPR”) . 

• Notice To California Residents:  Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), residents of the State of California (“California Residents”) have certain rights with respect to their Personal Information, and such rights are hereby disclosed to all California Residents as set forth in Appendix 1 of this Privacy Policy. 

• Data Subject Rights Under the GDPR:  See Appendix 2 of this Privacy Policy.

• COMMUNICATING WITH ZincFive.

If a User believes that ZincFive is not complying with the policies outlined in this Privacy Policy, or if the User has any questions relating to this  Privacy Policy, then the User should write to ZincFive: privacy@zincfive.com.

APPENDIX 1 to ZINCFIVE PRIVACY POLICY

CALIFORNIA PRIVACY RIGHTS NOTICE

Effective Date: Jan 09, 2025

1. YOUR CALIFORNIA PRIVACY RIGHTS UNDER THE CCPA

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if You are a resident of California You have the following rights with respect to Your Personal Information.

1.1 Right to Know About Our Collection, Disclosure, Sharing and Sale of Personal Information about You.

Personal Information as defined in the CCPA is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to You, including the following categories of information: (a) identifiers; (b) categories described in California Civil Code §1798.80(e); (c) characteristics of protected classes; (d) commercial information; (e) biometric information; (f) internet or other electronic network activity; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory or similar information; (i) professional or employment related information; (j) education information; and (k) inferences drawn from such information to create a consumer profile.

You have the right to know the categories of Personal Information We have collected about You; the categories of sources from which We collect Personal Information; Our business or commercial purpose for collecting, disclosing, sharing, or selling Personal Information; the categories of third parties to whom We disclose, share, or sell Personal Information, if any; and the specific pieces of Personal Information We have collected about You. Personal Information includes “sensitive” Personal Information as described below.

1.2  Right to Know About Our Collection, Disclosure, Sharing and Sale of “Sensitive” Personal Information about You.

“Sensitive” Personal Information as defined in the CCPA is Personal Information that reveals: (a) Your Social Security, driver’s license, state identification card, or passport number; (b) Your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) Your precise geolocation; (d) Your racial or ethnic origin, religious, or philosophical beliefs, or union membership; (e) the contents of Your mail, email, and text messages unless We are the intended recipient of the communication; and (f) Your genetic data. “Sensitive” Personal Information also includes biometric information that is processed for the purpose of identifying You, information that is collected and analyzed concerning Your health; or Your sex life or sexual orientation.

You have the right to know the categories of “sensitive” Personal Information We have collected about You, the categories of sources from which We collect Personal Information, Our business or commercial purpose for collecting, selling, or sharing “sensitive” Personal Information, the categories of third parties with whom We sell or share “sensitive” Personal Information, if any, and the specific pieces of “sensitive” Personal Information We have collected about You.

1.3  Right to Delete Your Personal Information

Subject to the exceptions set out below, and upon Your submission of a verifiable request, You have the right to deletion of Your Personal Information from Our records, and to have Us direct Our Service Providers/Contractors and third parties to delete Your Personal Information from their records. 

We are not required to, and reserve Our right to not delete Your Personal Information if it is necessary to: (i) complete the transaction for which the Personal Information was collected, provide a good or service requested by You, or reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform a contract between You and Us; (ii) help to ensure security and integrity to the extent the use of Your Personal Information is reasonably necessary and proportionate for those purposes; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided We have obtained Your informed consent; (vii) enable solely internal uses that are reasonably aligned with Your expectations based on Your relationship with Us and compatible with the context in which You provided the information; and (viii) comply with a legal obligation.

1.4  Right to Correct Inaccurate Personal Information.

Subject to the exceptions set out below, and upon Your submission of a verifiable request, You have the right to correct any inaccurate Personal Information in Our records, and to have Us direct Our Service Providers/Contractors and third parties to correct any inaccurate Personal Information from their records. 

If We cannot verify Your identity pursuant to the CCPA and its regulations, We may deny a request to correct. In such event, We shall inform You that Your identity cannot be verified.

In determining the accuracy of the Personal Information that is the subject of Your request to correct, We shall consider the totality of the circumstances relating to the contested Personal Information. We may deny Your request to correct if We determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances.

1.5 Right to Be Free from Discrimination

You have the right to not be discriminated against by Us because You exercised any of Your rights under the CCPA. This means We cannot, on the basis of the exercise of Your rights thereunder, among other things, deny goods or services to You, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to You; or suggest that You will receive a different price or rate for goods or services or a different level or quality of goods or services or retaliate against You as an employee, applicant for employment, or independent contractor. 

1.6  Right to Opt-Out of the Sharing of Personal Information

We may disclose Your Personal Information to third parties for cross-context behavioral advertising purposes (“Share” or “Sharing”). This means the targeting of advertising to You based on Your Personal Information that We obtain from Your activity across businesses, distinctly-branded websites, applications, or services, other than Our business, distinctly-branded website, application, or service. We may Share Personal Information with Advertising Networks so they may help Us to deliver advertisements to You based on Your activity on the ZincFive Website or apps and/or Your activity on other websites or apps.

You have the right to opt-out of the Sharing of Your Personal Information and You may exercise Your right by clicking the following link. If You exercise Your right to opt-out of the Sharing of Your personal information, We will refrain from Sharing Your Personal Information, unless You subsequently provide express authorization for the sharing of Your Personal Information.

1.7 Right to Opt-Out of the Sale of Personal Information

We may disclose Your Personal Information to third parties in exchange for monetary or other consideration. Such disclosures are considered to be “Sales” under the CCPA. We may Sell Personal Information to advertising networks so they may help Us to deliver advertisements to You based on Your activity on the ZincFive Website or any other Company Programs and/or to recommend Our products/services to You based on Your activity on other websites or apps. You have the right to opt-out of the Sale of Your Personal Information and You may exercise Your right by clicking on the following link: [Insert Do Not Sell or Share My Personal Information Link]. If You exercise Your right to opt-out of the Sale of Your Personal Information, We will refrain from Selling Your Personal Information, unless You subsequently provide express authorization for the Sale of Your Personal Information.

1.8 Right to Limit the Use of “Sensitive” Personal Information 

We use Your “sensitive” Personal Information only to the extent that it is necessary to provide Our products/services as reasonably expected by You. If We were to use Your “sensitive” Personal Information other than is necessary to provide Our products/services, You would have the right to limit Our use of Your “sensitive” Personal Information to that which is necessary to provide Our products/services to You.]

1.9 Right of Children to Opt-In to the Sale of Personal Information

We do not knowingly collect or sell the Personal Information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their Personal Information, We have established the following processes:

Minors between 13 and 16 years of age: 

In the case of consumers between 13 and 16 years of age, We require the consumer to affirmatively authorize the sale of the consumer’s Personal Information. In order to opt-in minors in this age range, as part of the account registration process for Our products which may be targeted toward minors, We require the consumer or consumer’s parent or guardian to verify the consumer’s identity by providing at least two data points with data points maintained by the business, which We have determined to be reliable for the purpose of verifying the consumer. 

Minors under 13 years of age:

In the case of consumers who are less than 13 years of age, We require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for Our products/services s which may be targeted toward minors, We require that the consumer’s parent or guardian verify the consumer’s identity, which We have determined to be reliable for the purpose of verifying the consumer. 

We reserve the right to require additional information or not complete Your request if We cannot verify Your identity. If You are a parent or guardian seeking to opt-out on behalf of their child, please contact Us at 1-888-735-6891 or email Us at privacy@zincfive.com with the subject “Minor Opt-Out.”

2. HOW TO EXERCISE YOUR CCPA RIGHTS

Unless otherwise specified, to exercise any of Your rights described in this Appendix A, please submit Your request to Us at 1-888-735-6891 or at privacy@zincfive.com with the subject “CCPA Consumer Request.”

In order to verify Your request, We will need You to provide Us with enough information to identify You (e.g., Your full name, address, and customer or matter reference number), proof of Your identity and address (e.g., a copy of Your driver’s license or passport and a recent utility or credit card bill), and a description of what right You wish to exercise along with any information to which Your requests relates. If feasible, We will match the identifying information provided by You with the personal information that We already maintain about You.

You may designate an authorized agent to make a request under the CCPA on Your behalf. In order to fulfill Your request to know or delete submitted by an authorized agent, You must provide the authorized agent written permission to do so, and We may require that You verify Your own identity with Us directly. 

We reserve Our right not to grant a consumer request if We cannot verify that the person making the request is the person about whom We have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of Personal Information twice within a 12-month period. Any Personal Information We collect from You to verify Your identity in connection with Your request will be used solely for the purposes of verification.

3. OUR PERSONAL INFORMATION COLLECTION, USE, AND DISCLOSURE PRACTICES

A description of the Personal Information that We collect online and off-line is provided in Section 1 of the main Policy. 

The purposes for which We collect and use Personal Information are described in Sections 1, 2, 3 and 5 of the main Policy.

Sources from which We receive Personal Information are described in Section 1 of the main Policy. 

Our Personal Information disclosure practices are described in Section 1, 2, 3, and 5 of the main Policy.

Our Personal Information retention practices are described in Section 10 of the main Policy.

3.1 Categories of Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

3.2 Categories of “Sensitive” Personal Information Collected; Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

4. OTHER CALIFORNIA PRIVACY RIGHTS

4.1  Shine the Light Request.

Individual consumers who reside in California and have provided Us with their Personal Information may request information about Our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must include Your name, street address, city, state, and zip code, and be submitted to Us at one of the following addresses: privacy@zincfive.com with the subject “California Shine The Light Request” or ZincFive, Inc., 20170 SW 112th Ave., Tualatin, Oregon, 97062, USA, Attn: General Counsel. Within thirty (30) days of receiving such a request, We will provide a list of the categories of Personal Information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve Our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

4.2  Minor’s Right to Remove Posted Content.

If You are a California resident under the age of 18, and a registered User of any website where this Policy is posted, California Business and Professions Code Section 22581 permits You to request and obtain removal of content or information that You have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacy@zincfive.com with the subject “Privacy Rights for Minors.” Please be aware that such a request does not ensure complete or comprehensive removal of the content or information You have posted and that there may be circumstances in which the law does not require or allow removal even if requested. 

APPENDIX 2 to ZINCFIVE PRIVACY POLICY

NOTICE UNDER THE EUROPEAN UNION’S GENERAL DATA PROTECTION REGULATION (“GDPR”).

The GDPR provides European Union (EU) Data Subjects (as such term is defined in the GDPR) with specific rights with regard to their Personal Data (as such term is contemplated by the GDPR). In addition to any disclosures provided to any User who is an EU Data Subject under the GDPR pursuant to any separate Informed Consent, the following provides an explanation of the following rights of, and the following notification provided to, any User who is an EU Data Subject pursuant to the GDPR:

EU DATA SUBJECT’S RIGHTS UNDER GDPR.

Data Subjects (as such term is defined in the GDPR) are hereby notified that they have the following additional rights pursuant to the GDPR:

• Pursuant to GDPR Article 15 (Right of Access by the Data Subject), to obtain from Us confirmation as to whether Personal Data (as such term is defined in the GDPR) has been Processed (as such term is defined in the GDPR) and, if that is the case, access to that Personal Data and additional information about how it has been Processed, including without limitation: (i) the purpose of the Processing; (ii) the category of Personal Data concerned; (iii) the categories of recipients to whom the Data Subject’s Personal Data has been disclosed; (iv) the planned retention period; (v) the existence of Your right of rectification, deletion, limitation of processing, or opposition; (vi) the existence of a right to complain; (vii) the source of the collection of Personal Data if not collected from Us; (viii) and the existence of automated decision-making including profiling and, where appropriate, meaningful information about their details;
• Pursuant to GDPR Article 16 (Right to Rectification), to request the correction (modification) of incorrect Personal Data or any completed Personal Data stored by Us;
• Pursuant to GDPR Article 17 (Right to Erasure; “Right to be Forgotten”), to request the deletion of the Data Subject’s Personal Data stored by Us, except for the allowed continued uses permitted by the GDPR, including without limitation as far as the Processing is needed to exercise the right to freedom of expression and information, for the fulfillment of a legal obligations, for reasons of the public interest, or for the assertion, exercise, or defense of legal claims, if required;
• Pursuant to GDPR Article 18 (Right to Restriction of Processing), to demand the restriction of the Processing of the Data Subject’s Personal Data where one of the following applies: (i) as far as the accuracy of the Personal Data is disputed by the Data Subject; (ii) the Processing of the Personal Data is unlawful, but the Data Subject rejects its deletion; (iii) We no longer need the Personal Data, but the Data Subject requires it to exercise or defend legal claims; or (iv) the Data Subject has objected to the Processing of the Personal Data in accordance with GDPR Article 21;
• Pursuant to GDPR Article 20 (Right to Data Portability), the right of the Data Subject to receive his/her Personal Data as provided to Us, in a structured, common, and machine-readable format or to request the transfer to another person responsible;
• Pursuant to GDPR Article 7(3) (Conditions of Consent), the Data Subject’s right to withdraw, at any time, the Data Subject’s once granted consent. As a result, We are no longer allowed to continue the Processing of Personal Data based on that consent for the future, but such withdrawal does not affect the lawfulness of the Processing of Personal Data based on such consent before such withdrawal; 
• Pursuant to GDPR Article 34 (Communication of a Personal Data Breach to Data Subject), if a personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall communicate the personal data breach to the data subject without undue delay.
• Pursuant to GDPR Article 77 (right to Lodge a Complaint with a Supervisory Authority), the right of the Data Subject to complain to a Supervisory Authority, as such term is defined in the GDPR. As a general rule, the Data Subject can contact the Supervisory Authority of the Data Subject’s usual place of residence or work or place of the alleged infringement.

LEGAL BASIS FOR COMPANY’S PROCESSING OF PERSONAL DATA UNDER GDPR.

The Company may process Your Personal Data (as such term is defined under the GDPR) under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the Processing of Your Personal Data, and, in particular, whether the provision of Personal Data (as defined under the GDPR) is a statutory or contractual requirement, or a requirement necessary to enter into a contract.