Zebra Media Privacy Policy

Effective Date: January 1, 2023

SECTIONS IN THIS PRIVACY POLICY

  1. INTRODUCTION AND SCOPE
  2. INFORMATION WE COLLECT, HOW WE COLLECT IT, HOW WE USE IT, AND WHY WE SHARE IT
  3. REGIONAL SPECIFIC DISCLOSURES
  1. EEA and UK
  1. Legal Basis for Collection
  2. Use of Cookies
  3. Data Subject Rights
  1. CALIFORNIA
  1. How and Why We Collect, Use, and Disclose Your Personal Information
  2. Consumer Rights
  1. VIRGINIA
  2. NEVADA
  1. HOW TO EXERCISE YOUR RIGHTS
  2. YOUR PRIVACY CHOICES
  3. DATA HOSTED IN THE UNITED STATES
  4. NON DISCRIMINATION, COMPLAINTS AND DISPUTES
  5. DATA RETENTION AND SECURITY
  6. UPDATES TO THIS PRIVACY POLICY AND CONTACT INFORMATION

1. INTRODUCTION AND SCOPE

ZS Sites and applications. Zebra Surf LLC, (“ZS”) operates a number of search and everyday useful content Sites. We understand that your privacy is important to you, and we are committed to being transparent about the information we collect and process when you use our Sites and applications. This Privacy Policy describes our practices concerning the personal data collected, processed and stored by ZS when you visit and use Sites operated by ZS (“Sites”).

California Based Business. ZS operates the Sites from California in the United States of America and, regardless of your place of residence or access location, your use of the Sites is governed by the laws of the State of California. Users who access or use the Sites from other locations consent to the transfer and processing of their data in the United States of America and any other jurisdiction throughout the world. For more information, see DATA HOSTED IN THE UNITED STATES below. This Privacy Policy is provided in English. Translations to certain other languages may be available and can be requested by contacting us at privacy@zebra.media.

User Consent and Age Requirement. By using the Sites, you consent to our collection and use of your information as described in this Privacy Policy. Our Sites are not intended for children and we do not knowingly collect information from children. IF YOU ARE NOT AT LEAST 16 YEARS OLD, DO NOT USE THE SITES.

Third party links and features. The Sites include many links to third-party websites, services, widgets, ads, and other services. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. If you watch a video sourced from YouTube embedded in our search results page, your use of the YouTube service is subject to the YouTube Terms of Service and the Google Privacy Policy. If you use Social media features implemented on our Sites (like the Facebook “Like” or “Share” button) you are allowing the social media providers to collect information about your use of our Site and tie it to your social media account. This data collection by the social media platform is subject to the privacy policy of the social media provider.

2. INFORMATION WE COLLECT, HOW WE COLLECT IT, HOW WE USE IT, AND WHY WE SHARE IT

 

The chart below describes what personal data we collect about our users, how we collect or access it, how we use it, which third parties have access to it, and the purpose for disclosure. In addition, we may collect, use and disclose your personal data as required or permitted by applicable law, as directed by you, or in accordance with this Privacy Policy.

Categories of Personal Data

How we collect it

How we use it

Who has access

Purpose for disclosure

Your IP address

We automatically collect the IP address you use each time you visit our Sites. We get this information from your browser when it interacts with our servers. We log these IP addresses in our user visit logs.

This is to determine what country or state or province you are in to show you relevant search results, content, and ads. This is also to analyze fraudulent traffic patterns. We also analyze which regions of the world our users come from so we can develop search and content offerings for these regions.

Our vendors receive your IP address and Browser ID to provide to us a variety of services to help our Sites function, such as site hosting, data warehousing, content delivery, Site functionalities (video, push notifications), Site content, security, privacy tools, and analytics (such as Google Analytics - for more information visit: How Google uses information from sites or apps that use our services – Privacy & Terms and to opt out of Google Analytics cookies, visit: Google Analytics Opt-out Browser Add-on Download Page). Our marketing agencies may also have access to your IP address while promoting our Sites on our behalf. Your IP address may also incidentally be accessed by vendors for IT support, data backup and recovery services, and office software.

Our vendors process this data to:

1. Provide their services to us and to determine what amounts are owed to them based on traffic and app install volumes or other metrics

Log page impressions and user actions for their business analytics

Detect and address fraudulent behavior or illegal activity

Monitor the proper functioning of their services, quality assurance, find errors and fix them

Internal research

Improve their products and services

Such vendors may also engage their own vendors to help them process user personal data, so they can provide their services to us. ZS may process IP address data for security purposes. ZS may analyze all traffic patterns for Site security and fraud prevention.

A unique ID assigned to your browser

We attribute a unique ID to your browser for each of our Sites that you visit (Browser ID). We store this information in a cookie set on your browser.

Every time you visit the same Site with the same browser, we recognize you as the same visitor through your Browser ID. If you use a different device or a different browser, or if you visit a different Site with the same browser, you will be identified as a different user with a different Browser ID.

This is so we can count unique users and repeat users for each of our Sites. We can determine which of our Sites receive more repeat visits and which type of content causes users to come back to the Sites.

Data collected via third party cookies

We implement on our Sites certain code provided by partners such as a pixel or beacon that enable them to place or recognize a cookie on your browser or other tracking device (for example, tied to your mobile device ID). Such tracking technology enables them to collect the IP address that you use when you visit our Sites and information about your activities while visiting our Sites.

N/A

Advertisers and digital advertising technology intermediaries who place interest based advertisements on our Sites, advertising networks where we promote our Sites, and service providers who help us optimize our advertising campaigns (such as retargeting companies). For information about opting out of tracking via cookies by these partners, see REGIONAL SPECIFIC DISCLOSURES and YOUR PRIVACY CHOICES.

Ad partners use tracking technology to place ads on our Sites and other websites and applications targeted to you based on your past actions on our Site or on other websites (interest based advertising).

Ad networks where we promote our Sites collect information about you to provide promotion campaign optimization services to us.

Ad partners and ad networks also use cookies to develop their own ad targeting algorithms and help other advertisers optimize their campaigns.

They may also combine information about your activities on our Sites with information about you from other sources not affiliated with us. These partners may also use cookie data to determine payments owed to them, analyze fraudulent traffic patterns, detect and fix errors in their service, and to conduct internal research to improve their service and increase their revenues.

Your activities on our Sites

All of your actions on each of our Sites (your visits, search queries, search results you click on, URL of the webpage you were last visiting before clicking to our Site, pages viewed,, comments posted-where applicable, duration of visit) are logged and tied to your Browser ID. Your browser has a different Browser ID for each of our Sites.

This is to count search queries, clicks, page views, repeat visits, time on Site and in apps, and other metrics so we can determine which search queries are trending, which content, web page layouts or user interfaces are the most popular or generates the most revenue and which app features are the most used

This is also to determine payments owed to content and advertising partners, as well as marketing agencies.

Advertisers and digital advertising technology intermediaries who place interest based advertisements on our Sites, advertising networks where we promote our Sites, service providers who help us optimize our advertising campaigns (such as retargeting companies), and social media platforms.

As explained above in the Data collected via third party cookies row of this chart.

Other technical information

As you interact with the Sites, we collect information about your computer or mobile device such as type of device, mobile device ID number, screen resolution, web browser information and operating system or platform. We also collect your browser preferences and settings (time zone, language, etc.) This information is also tied to your Browser ID.

This is to present search results and content to you in your preferred language and present our Site pages in a format that best fits your device screen and format.

N/A

N/A

Contact information you may submit via email

When you email us, we retain your request and any other information you provide. We do not combine this information with any of your other data collected through our Sites and keep it in a separate database.

This is used only to respond to your email request. We do not use your contact information for any other purpose.

There is no need to provide to us (and we strongly discourage you from) providing any personally identifiable or sensitive information about you or anyone else such as your exact location, physical address, telephone number, health, race, religious beliefs, or sexual orientation.

In addition to the sharing described in the chart above, we share your personal data with other parties for the purposes described below:

  1. Fraud prevention: we may disclose your personal data to third parties when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.
  2. Law enforcement purposes and public safety: if requested or required by government authorities, such as law enforcement authorities, courts, or regulators, or otherwise to comply with the law, we may disclose any information we have about our users. We may disclose personal data collected about you in order to exercise or protect legal rights or defend against legal claims. We also may be required to disclose an individual’s personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
  3. Sale or merger of our business: we may transfer your information to a third party if we or any of our affiliates are involved in a corporate restructuring (e.g., a sale, merger, or other transfer of assets).

3. REGIONAL SPECIFIC DISCLOSURES

A. EEA and UK

I. Legal Basis for Collection

We collect and use your personal data to:

  1. Provide our services: we process your personal data to provide our web search and content services. This is so we can comply with our contractual obligations to you.
  2. Improve our services: we analyze information about how you use our Sites to provide an improved experience for our users, including product testing and site analytics. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our Sites and improve them.
  3. Compensate our partners: we process your personal data for purposes of calculating compensation to be paid to our third party product/service providers and distributors and to analyze usage across products, services and distribution partner/channel. It is in our legitimate interest to appropriately determine amounts to be paid to our partners and inform our product roadmap and distribution strategy.
  4. Communicate with you: we may use your personal data when we communicate with you, for example to respond to your requests via email. It is in our legitimate interests that we are able to provide you with appropriate responses and provide you with notices about our Sites and services.
  5. Promotion of our Sites: we may use your personal data to deliver relevant advertisements to you to promote our Sites, and measure the effectiveness of our marketing campaigns. It is in our legitimate interest to analyze the interests of our users to craft more relevant advertising messages and inform our marketing strategy. We may use automated decision-making to deliver tailored advertisements based on your personal data. In most cases, we and our marketing network partners use cookies, unique ID codes and other types of trackers to carry out this activity as further described in INFORMATION WE COLLECT, HOW WE COLLECT IT, HOW WE USE IT, AND WHY WE SHARE IT.
  6. Exercise our rights: we may use your personal data to exercise our legal rights where it is necessary to do so; for example, to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or our Terms of Service.
  7. Comply with our obligations: we may process your personal data to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law, such as responding to your request for data access or deletion.
  8. Customizeyour experience, including ads: when you use the Sites, we may use information about your use of the Sites (queries you submitted, content you viewed) to customize your experience, such as by providing personalized elements and showing you content based on your recent interests. We may use automated decision-making for these activities. Upon your affirmative consent or request, we may use your browser information to send you notifications about content on our site via your browser. As required by applicable data protection and privacy laws, we will obtain your consent for these activities and enable you to opt out of these activities.

Your personal data is also processed in the United States by some of the third parties with whom we share your data as detailed in INFORMATION WE COLLECT, HOW WE COLLECT IT, HOW WE USE IT, AND WHY WE SHARE IT. We have entered into data processing agreements with service providers who process your data that restrict and regulate their processing of your data on our behalf.

II. Use of Cookies

ZS and its vendors and partners use cookies. Cookies are small text files stored by your browser, to collect, store, and share personal data about your activities across multiple websites. Cookies can remain on your computer or mobile device for different periods of time. Some cookies are 'session cookies', meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are persistent cookies', meaning that they survive after your browser is closed. They can be used by websites and advertising services to recognize you when you open your browser and browse the Internet again. Cookies can be “first party”, meaning they are served directly by us to your browser or mobile device, or “third party”, meaning they are served by either one of our vendors to provide their services to us, or by an advertising partner when we promote our services. Cookies can be divided into categories based on their functionality.

Strictly Necessary. These cookies are necessary for our Sites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but then some parts of the Site will not work.

Functional. These cookies enable the Site to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Site Performance and Analytics. These cookies allow us to count visits and traffic sources so we can measure and understand how our Sites are accessed in order to improve the performance of our Sites. These cookies also help us test different versions of our Sites to see which features or content users prefer. These may be first party cookies or third party cookies from our vendors who help us with analytics services. They help us to know which Site pages, content and features are the most and least popular and see how visitors move around within our Sites. If you do not allow these cookies we will not know if and how you have visited our Sites, and will not be able to use your activity information to monitor our performance or improve our services.

Ad Targeting. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on our Sites other websites and applications. They are based on uniquely identifying your browser and device as you access our Sites. If you do not allow these cookies, you will experience less targeted advertising. If you are in the EEA/UK and would like more detailed information about third party cookies, please click on the Cookie Details Link within our cookie preference center accessible via the Manage Privacy link (only available to EEA/UK users).

III. Data Subject Rights

Subject to certain exceptions, you may have some or all of the following rights in relation to how we use your personal data.

While EEA/UK residents also have a right to access and receive a copy of personal data collected about them, correct inaccuracies in their personal data, and have their data ported to another service, such rights cannot be exercised with us because we do not have a way of authenticating or verifying the identity of our users and so we cannot adequately verify that the requester is the same person as the user whose data copy, correction or portability is being requested. See HOW TO EXERCISE YOUR RIGHTS for more details.

Your right to know. Upon your request, and provided you are able to provide to us your Browser ID, then we may provide you with certain limited information:

Information relating to your Browser ID is retained by us for various time periods, so we may not be able to provide information that was collected but no longer retained by us.

Your Right to delete. Upon your request to delete or if you withdraw the consent that you have previously provided to us to store or use your personal data, and provided you are able to provide to us your Browser ID, then we will delete any personal data we have stored about you. If you are in the UK, Switzerland, or the EEA and you do not consent to your data being processed by us or by our vendors in the United States, please request the deletion of your personal data and please stop accessing our Sites.

Exercising your rights. Follow the steps indicated below in HOW TO EXERCISE YOUR RIGHTS. Please note that we manage requests on a per Browser ID basis, which is the only way we can fulfill a request, and so you will have to provide your browser ID as instructed below. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why subject to any legal restrictions. If you have submitted an email request, your contact information will not be tied to your Browser ID and we will not be able to verify that any Browser ID information corresponds to any additional information you provide to us.

We will do our best to resolve any questions or concerns you may have. If you have any questions about our personal data processing, or want to submit a complaint or an appeal about our decision regarding your request, you can contact us by email at privacy@zebra.media

B. CALIFORNIA

If you are a California resident, you have specific rights under the California Consumer Protection Act (CCPA). Capitalized terms defined in the CCPA that are used in this section shall have the same meaning as in the CCPA. In the event of any conflict between this section and the other sections of this Privacy Policy, this section shall govern for California residents.

I. How and Why We Collect, Use, and Disclose Your Personal Information

The chart below summarizes the Categories of Personal Information we Collect, how we use it, and with whom we Share or Sell certain Personal Information. For further details, please see INFORMATION WE COLLECT, HOW WE COLLECT IT, HOW WE USE IT, AND WHY WE SHARE IT

Category of Personal Information

Purposes for Collection, Use, and Disclosure

Sales and Sharing

Identifiers such as a cookie ID, an IP address or other similar identifiers, and email address if you contact our help desk

  1. Enhance your experience with our services
  2. Recognize you as a repeat visitor
  3. Respond to your requests
  4. Provide customer service
  5. Manage web traffic

This is only so we can count unique users and repeat users for each of our Sites. We can determine which of our Sites receive more repeat visits and which type of content causes users to come back to the Sites.

Third party identifiers are used to customize your experience with our Sites and tailor content and advertisements that are shown to you.

Sold and Shared for marketing and advertising purposes to third party advertisers and analytics providers.

Geolocation data, inferred from your IP address

  1. Enhance your experience with our Sites
  2. For tailoring content and advertisements to your geographic location

Sold and Shared for marketing and advertising purposes to third party advertisers and analytics providers

Internet or other electronic network activity information such as IP address, device identifiers, device advertising identifiers, mobile network, operating system details, language preferences, referring URLs, length of visits, anonymous traffic data, pages viewed, and information regarding interactions with our services or advertisements

  1. Enhance your experience with our services
  2. Guide decisions about ZS’s products, Sites, and communications
  3. Operations

Via third party identifiers, Third Parties can tailor content and advertisements that are shown to you based on your searches and content you viewed on our Sites.

Sold and Shared for marketing and advertising purposes to third party advertisers and analytics providers

II. Consumer Rights

The CCPA gives California consumers certain rights detailed below.

Right to know about Personal Information Collected, Shared, or Sold. You have the right to know about your Personal Information that we are currently maintaining and have Collected and disclosed about you. You also have the right to obtain a transportable copy of such Personal Information. Requests of this nature may be made no more than twice in a 12-month period. Please note that we retain Personal Information for various time periods in accordance with applicable law and our internal recordkeeping policies and procedures. For more information on our retention practices, please see DATA RETENTION AND SECURITY.

Right to know. California consumers have the right to request more information regarding the following:

Right to request deletion of Personal Information. You may request that we delete the Personal Information that we have Collected directly from you and are currently maintaining. Please note, however, that we may have a legal basis for retaining certain Personal Information under the CCPA, despite your request.

Right to correct personal data. While California residents also have a right to correct inaccuracies in their Personal Information, such rights cannot be exercised with us because we do not have a way of authenticating or verifying the identity of our users and so we cannot adequately verify that the requester is the same person as the user whose data correction is being requested. See HOW TO EXERCISE YOUR RIGHTS for more details.

Right to limit use of your sensitive personal data. We do not process sensitive personal information. For this reason, we do not offer a way for you to submit such a request.

Right to non-discrimination for the exercise of your privacy rights. We will not discriminate against you if you choose to exercise any of the privacy rights described above.

To exercise these rights, follow the steps indicated below in HOW TO EXERCISE YOUR RIGHTS. Please note that we manage requests on a per Browser ID basis, which is the only method for us to recognize a user, and so you will have to provide your browser ID as instructed below.

Right to opt-out of the Sale or Sharing of your Personal Information. We only engage in Sales and Sharing via tracking technologies such as cookies through our Sites. You have the right to opt-out of the Sale or Sharing of your Personal Information in the context of cookies or other tracking technologies. To opt out of Sale or Sharing via cookies or other tracking technologies, please click on the “Do Not Sell or Share My Personal Information” link on the bottom of our Sites. You may also opt out of the Sale or Sharing of your Personal Information via cookies or tracking technologies through an opt-out preference signal. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use. We do not knowingly Sell or Share the personal data of individuals under the age of 16.

III. Shine the Light

California law permits customers in California to request certain details about how their personal information is shared with third parties if personal information is shared for those third parties’ own direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at privacy@zebra.media or by sending a letter to: Zebra Surf, LLC, Data Protection Officer, 2930 Domingo Ave Unit #420 Berkeley, CA  94705, Attn: Privacy/Shine the Light.

Any such request must include your name and “California Shine the Light Privacy Rights Request” in the first line of the description and, if sent by mail, must include your street address, city, state, and zip code.

Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through those provided under this section. Because these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

C. VIRGINIA

This section applies to Virginia Consumers as defined by the Virginia Consumer Data Protection Act (“VCDPA”) that use our Sites. Capitalized terms defined in the VCDPA that are used in this section shall have the same meaning as in the VCDPA. In the event of any conflict between this section and the other sections of this Privacy Policy, this section shall govern for Virginia residents.

You can learn more about the Personal Data we Process in INFORMATION WE COLLECT, HOW WE COLLECT IT, HOW WE USE IT, AND WHY WE SHARE IT. We Process your Personal Data for Targeted Advertising. You have the right to opt-out of the Processing of your Personal Data for Targeted Advertising, as described below.

If you are a Virginia Consumer, subject to certain conditions and restrictions set out in the VCDPA and other applicable laws, you have the following rights with regard to your Personal Data:

Right to Access. You have the right to know the Personal Data that we may hold about you and access such Personal Data.

Right to Delete. You have the right to request that we delete certain Personal Data that we have collected from or obtained about you.

Right to Opt-Out of Sales. We do not Sell your Personal Data as defined under the VCDPA, and as such this right is not applicable.

Right to Opt-Out of Profiling. We do not engage in profiling that results in decisions that produce legal or similarly significant effects, and as such this right is not applicable.

Right to Appeal. If you are unsatisfied with our actions related to the exercise of one of your privacy rights above, you may appeal our decision.

Right of Correction. While Virginia residents also have a right to correct inaccuracies in their Personal Data, such rights cannot be exercised with us because we do not have a way of authenticating or verifying the identity of our users and so we cannot adequately verify that the requester is the same person as the user whose data correction is being requested.

To exercise the above listed rights, follow the steps indicated below in HOW TO EXERCISE YOUR RIGHTS. Please note that we manage requests on a per Browser ID basis, which is the only way we have of recognizing a user, and so you will have to provide your browser ID as instructed below. We will confirm receipt of your request and respond to your request as soon as we reasonably can and no later than legally required. You may exercise your privacy rights under the VCDPA no more than twice in a 12-month period. If you choose to exercise any of the privacy rights described above, you will not receive discriminatory treatment from us.

Right to Opt-Out of Targeted Advertising. You may request that we stop sharing your Personal Data for Targeted Advertising by managing your cookie preferences. You can access your cookie preferences by clicking the Do Not Sell or Share My Personal Information link on the footer of our Site.

D. NEVADA

We do not sell our users’ personal information or personal data as selling is defined by Nevada law. Nonetheless, Nevada residents have the right to submit a request that we do not sell your covered personal information, which you can do by contacting us by email at privacy@zebra.media or by US post at Zebra Surf, LLC, Data Protection Officer, 2930 Domingo Ave Unit #420 Berkeley, CA  94705.

4. HOW TO EXERCISE YOUR RIGHTS

Exercising Right of Access, Correction or Portability. We do not collect sufficient personal data to authenticate any particular user. As indicated above in INFORMATION WE COLLECT, HOW WE COLLECT IT, HOW WE USE IT, AND WHY WE SHARE IT, we only recognize a unique browser based on the Browser ID we assign to that browser for a particular Site. A Browser ID could therefore correspond to multiple individuals. Since the personal data we collect related to a Browser ID is not sufficient to verify that the corresponding browser belongs to the person making the request, we are not able to provide certain information in response to a request to know, access or port specific personal information about a user. This is to prevent anyone from using your browser to obtain your search or browsing history. We want to make sure your search and browsing history does not fall into the wrong hands.

5. YOUR PRIVACY CHOICES

You have choices regarding our collection and use of your personal data, as well as the collection and use of some of our third party partners

Removing our cookie. If you remove our Browser ID cookie from your browser cache, we will no longer recognize your browser and activities until a new cookie is placed. Any future Site activities you perform after you delete this cookie will not be tied to your previous activities which were associated with the removed cookie.

Removing Interest based advertising cookies. You can opt-out of third-party interest-based, advertising-related cookies, pixel tags and web beacons, to prevent our advertising partners to deliver targeted interest based ads to you. You can choose to opt-out through these (and other) resources:

You will continue to see advertisements on our Sites, but they will not be tailored to you based on any past behavior on our Sites or other websites. You may, however, still receive customized content and/or ads based on the search queries you submitted or the content of the pages you are visiting.

Removing Interest-based advertising from Mobile Tracking Devices. You may opt out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app.

Other Privacy Tools. In addition, third party tools enable you to search for and opt-out of some of these devices, such as the Ghostery browser plug-in.

Do Not Track. Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. However, we do not recognize or respond to browser-initiated DNT signals.

Deletion of information you submit via our HelpDesk. You may request us to delete all the information you submitted to us via email by contacting us at privacy@Zebra.Media. However, we reserve the right to retain any information you provided via email in order to defend legal claims, retain a record of our compliance with laws, including privacy and data protection laws, and other statutory data retention requirements.

6. DATA HOSTED IN THE UNITED STATES

ZS is headquartered in California, and in order to access our Sites, your browser interacts directly with our Site servers in the United States. By visiting or using our Sites, your data is automatically collected, processed and stored on servers located in the United States. If you are located in the United Kingdom (“UK”), Switzerland, or the European Economic Area (“EEA”), this means your data is stored in a country with laws that may offer less personal data protection than your country. We however comply with requirements set forth in the EU General Data Protection Regulation when we process your data, and you have the right to lodge a complaint with the data supervisory authority of your country if you feel that we have unlawfully processed your data.

7. NON DISCRIMINATION, COMPLAINTS AND DISPUTES

All content and services offered on the Sites are free of charge and ZS will not discriminate against any user who has exercised their rights as set forth in this Privacy Policy. We commit to resolve complaints about your privacy and our collection or use of your personal data. Inquiries, concerns or complaints may be submitted to us at Privacy@Zebra.Media. We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not satisfactorily addressed your complaint or concern, you may have the right to make a complaint to the data protection authority of your state of residence.

8. DATA RETENTION AND SECURITY

We have designed our Browser ID system so that we can manage our Sites while collecting as little information about our users as possible. We generally retain the information tied to your Browser ID for a period of fourteen (14) months, unless necessary for the purpose of satisfying any legal, accounting, or reporting requirements for example to resolve disputes and enforce our agreements. We retain information emailed to us to respond to discovery requests in the event of litigation or have the ability to defend legal claims.

We take the security of your information seriously and use appropriate technical and organizational measures to protect your information against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also limit access to information about you to employees who reasonably need access to it to provide products or services to you, or in order to do their jobs. However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you.

9. UPDATES TO THIS PRIVACY POLICY AND CONTACT INFORMATION

We will continue to evaluate this Privacy Policy against new technologies, applicable laws, business practices, and our user’s needs, and may make changes accordingly. Please check this page periodically for updates. If we make any changes to this notice we will post the updated Privacy Policy on this page and update the effective date. Except in connection with updates that materially change the ways in which we process your information, your continued use of the services after this Privacy Policy has been updated means that you agree to be bound by such updates.

If you have any questions or concerns about this Privacy Policy or the manner in which your information is processed (or if you are an EEA resident, how your data is transferred outside of the EEA), or if you would like to submit a request to us, please contact our Data Protection Officer via Privacy@Zebra.Media or via mail at 2930 Domingo Ave Unit #420 Berkeley, CA  94705,