Effective Date: April 12, 2021

Zash Global Media and Entertainment Corporation (“Company,” “we,” “our,” or “us”) is committed to respecting and protecting the privacy of our users. This Privacy Policy (“Policy”), describes how we collect, use, and disclose information that we obtain about visitors to our website, https://zash.global/  (the “Site”), our mobile application (“Application”) and the services available through our Site and Application (collectively, the “Services”), and does not apply to any other platforms or services that we own or operate.

Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes.

The Information We Collect About You

We collect information about you directly from you and from third parties, and automatically through your use of our Services.

Information We Collect Directly from You. The information we collect from you depends on how you use our Services.  Information we collect may include:

• To respond to inquiries or communications you send to us, we collect contact information, such as your name, e-mail address, mailing address, and phone number.
• We collect the information you provide us when you fill out a survey, questionnaire, or other type of form you complete through the Services.
• If you contact us, we collect records and copies of your correspondence, including e-mail addresses and other contact information.
• While you are navigating the Site or using the Services, we may also collect your search queries or information about your viewing history.
• We collect any information you choose to e-mail or communicate to us while using the Services.

Information We Collect from Other Entities. When you access the Services, we may collect information about you from third-party sources, such as: service providers, business partners, public and third-party databases, platform providers, non-affiliated partners, other users of our Services, public sources, third-party advertising partners, or from other third parties. Information we collect may be combined with other information we have collected about you in order to complete requests you have made or facilitate transactions you have initiated via the Services, or for other purposes, for which we provide you with notice or to which you consent.  Information we may collect about you from third-party sources may include your name, e-mail address, mailing address, phone number, and other contact information. 

Information We Collect Automatically. We automatically collect information about your use of our Services through cookies, web beacons, and other technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

When you use our Site, we may collect your browser type and operating system, web pages you view on the Site, links you click on the Site, and your IP address. We may also collect information about the length of time you spent visiting our Site and/or using our Services, and the referring URL, or the web pages that led you to our Site. 

How We Use Your Information

Personal Information Under the California Consumer Privacy Act (“CCPA”). We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Our Uses of Your Personal Information. We use your information, including your personal information, for the following purposes:

• To provide and maintain our Services
• To notify you about changes to our Services
• To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes
• To tailor the content and information that we may send or display to you, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences while using the Services
• To send you e-mail marketing materials about our products and services
• To send you news and newsletters
• To better understand how users access and use our Services, both on an aggregated and individualized basis
• To handle inquiries and complaints you or other users of our Services submit to us.
• To improve our Service
• To administer surveys and questionnaires, such as for market research or user satisfaction purposes
• To comply with legal obligations, as part of our general business operations, and for other business administration purposes, such as maintaining customer records, monitoring your compliance with any of your agreements with us, collecting debts owed to us, and safeguarding our business interests
• Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, and in situations involving potential threats to the safety of any person or violations of our Terms of Use or this Privacy Policy
• For research and analytics purposes
• To fulfill any other purpose for which you provide the information
• To fulfill purposes that you otherwise request or consent to

How We Share Your Information

We may share your information, including personal information, as follows:

Vendors, Service Providers, and Other Processors. We may disclose the information we collect from you to vendors, service providers, or other processors, such as customer management providers and IT services providers, to help us provide our Services to you, to assist us in analyzing how our Services are used, and to provide other services.

Subsidiaries and Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries as needed to provide the Services to you. 

Advertisers, Influencers, or Other Third Parties.  We may disclose the information we collect from you to our advertising partners, influencers, content providers, and other third-party platforms.

In addition, we may also share your personal information under the following circumstances:

Business Transfers.If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.

In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.

Aggregate and De-Identified Information. We share aggregate or de-identified information about users with third parties for marketing, advertising, research, or other purposes.

Others for Business Purposes. We may also share your personal information by disclosing it to a third party for a business purpose, including the business purpose of directly or indirectly enabling or effecting commercial transactions.  We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purposes except performing the contract.  For more information about how we have disclosed personal information for business purposes, please see the Categories of Personal Information Under the CCPA section below.

Sales of Personal Information to Third Parties. We may also share your personal information by selling it to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. We may also make certain categories of personal information available in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Sites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. For more information about sales of personal information, please see the Categories of Personal Information Under the CCPA section below.

Categories of Personal Information Under the CCPA 

In this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior twelve (12) months.

Sources of Personal Information. As further described in the Information We Collect About You and How We Collect It section above, we may collect personal information from the following sources:

• directly from the individual  
• advertising networks
• data analytics providers
• social networks
• internet service providers
• operating systems and platforms
• government entities
• business customers/clients

Categories of Personal Information Collected and Disclosed. In the table below, we identify the categories of personal information (as defined by the CCPA) we have collected and disclosed for a business purpose, and/or “sold” as defined by the CCPA, as well as the categories of third parties to whom we may disclose and/or sell such personal information. For more information about the business and commercial purposes for which we may disclose and sell, as defined by the CCPA personal information, please see the How We Share Your Personal Information section above. Under the CCPA, a “sale” includes disclosing or making available to a third-party personal information, in exchange for monetary compensation or other benefits or value. While we do not disclose personal information in exchange for monetary compensation, we may make certain categories of personal information available in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Sites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. 

Categories of Personal Information	Description	Do We Disclose for a Business Purpose?	Do We Sell?	Categories of Third Parties to Whom Information is Sold or Disclosed
Identifiers	Includes direct identifiers, such as name, alias, user ID, username, account number or unique personal identifier; e-mail address, phone number, address and other contact information; IP address and other online identifiers.	Yes	Yes	service providers   advisors and agents government entities and law enforcement affiliates and subsidiaries  advertising networks data analytics providers social networks internet service providers operating systems and platforms business customers/clients
Usage Data	Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, and our marketing emails and online ads.	Yes	Yes	service providers   advisors and agents government entities and law enforcement affiliates and subsidiaries  advertising networks data analytics providers social networks internet service providers operating systems and platforms business customers/clients [other]

Our Use of Cookies and Other Tracking Mechanisms 

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Services. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf). 

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process or to allow us to track your activities while using our Services. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in and as you move through our Services.

• Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve the performance of our Sites, Services, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout. 

Cross-Device Use. We and our third party service providers, including Google, may use the information that we collect about you (whether directly from our Site, through your device(s), or from a third party) to help us and our third party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers also may use the cross-device use and other information we learn about you to serve targeted advertising on your devices and to send you e-mails. To opt-out of cross-device advertising, you may follow the instructions set forth in the Third-Party Ad Networks section below. Please note: if you opt-out of these targeted advertising cookies, your opt-out may be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you may need to opt-out from each browser or device that you use.

Do-Not-Track Signals. Please note that our Site does not recognize or respond to any signal which your browser might transmit through the so-called “Do Not Track” feature your browser might have. If you wish to disable cookies on our Site, you should not rely on any “Do Not Track” feature your browser might have. For more information about do-not-track signals, please click here.

Ad Networks. We use network advertisers to serve advertisements on non-affiliated websites or other media (e.g., social networking platforms). This enables us and these network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, pixels, LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity’s specific privacy policy, not this one. We may provide these advertisers with information, including personal information, about you. 

Users may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising. Please be advised that opting out of ad networks will opt you out from certain companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Additional information is available on the DAA’s website at www.aboutads.info.

Your Consumer Rights Under the CCPA

Right to Request Disclosure. You have the right to request, free of charge, that we disclose information about our collection and use of your personal information over the past twelve (12) months, including:

1. The categories of personal information we collect about you; 
2. What personal information we collect, use, or disclose about you; 
3. The categories of sources of the personal information we collect about you;
4. Our business or commercial purpose for collecting the personal information;
5. For each category of personal information, the categories of third parties with whom it was disclosed; and
6. The specific pieces of personal information we collect about you.

For more information on how to request information about our collection, use, and disclosure of your personal information, please see the Submitting CCPA Requests section below.

Right to Request Deletion. You have the right to request the deletion of your personal information that we collected. For more information on how to request deletion, please see the Submitting CCPA Requests below. Once we receive your request and verify your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or de-identify personal information not subject to an applicable exception from our records and will direct our service providers to take similar action.

You do not need to create an account with us to exercise your deletion rights. We will only use personal information provided in a deletion request to review and comply with the request.

Right to Request Opt-Out of the Sale of Your Personal Information. If you are age 16 or older, you have the right to direct us to not sell your personal information at any time. We do not sell the personal information of consumers we actually know are less than 16 years old.

To exercise the right to opt-out, you or your authorized representative may submit an opt-out request by following the procedures specified in the Submitting CCPA Requests section below.  Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorized personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting us via the information in the Contact Us section below.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Right of Non-Discrimination. You have the right to be free from discriminatory adverse treatment for exercising these rights. We will not discriminate against you for exercising any of your CCPA rights. 

Submitting CCPA Requests

Requests to Know or Delete.  To exercise your rights to know or delete described above, you may submit a request by contacting us through the Contact Us section below.

Requests to Opt-Out of Sales of Your Personal Information. To exercise your right to opt-out of sales of your personal information, you may submit a request form via our website at: Do Not Sell My Personal Information.  You may also submit a request by emailing [email protected].

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Verification of Requests.  Only you, or an individual legally authorized to act on your behalf, may make a request to know, delete, or opt-out related to your personal information.  To designate an authorized agent, please contact us by using the contact information above.

You may only submit a request to know twice within a 12-month period.  Your request to know or delete must: 

1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or that the requestor is your authorized representative.
2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may request information from you in order to verify your identity. Additionally, we may require that authorized agents provide proof of their authorization. We cannot respond to your request or provide you with personal information if we are unable to verify your identity, your authority to make a request on behalf of another person, or if we cannot confirm that the personal information relates to you.  In general, we will verify your request and your identity by matching the information you provided with the information we have in our records.

You do not need to create an account with us to submit a request to know, or to submit a request to delete your personal information or opt-out of sales of your personal information.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Third-Party Links

Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Security of Your Personal Information 

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust, unique password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Access Your Personal Information

You may modify personal information that you have submitted by contacting us using the information in the Contact Us section below.

Your Choices Regarding Our Use of Your Personal Information

We may send periodic promotional e-mails to you. You may opt-out of promotional e-mails by following the opt-out instructions contained in the e-mail. If you opt-out of receiving promotional e-mails, we may still send you e-mails about your account or any services you have requested or received from us.

Notice Concerning Children

We do not knowingly collect, use, or disclose information from children under 16, except as required by law or regulation. If we learn that we have collected the personal information of a child under 16, we will take steps to delete the information as soon as possible. Please immediately contact us if you become aware that a child has provided us with personal information.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. 

Contact Us

If you have questions about the privacy aspects of our Site, Application, or Services or would like to make a complaint, please contact us at: 

Zash Global Media and Entertainment Corporation
1000 5^th Street
Suite 200 H-2
Miami Beach, FL 33139
E-mail: [email protected]