Last Modified: Jan 8th, 2024

Please take the time to carefully read this Privacy Notice. By accessing and using Zoig, you acknowledge that you have read and understood all the terms mentioned in this Privacy Notice. We value your privacy and are dedicated to safeguarding your personal data. If you have any inquiries regarding our privacy practices, please refer to the "Contact Information" section below for details on how to get in touch with us.

1. Scope

"Process", "processed", or "processing" in this Privacy Notice refers to any action or series of actions carried out on personal data or sets of personal data (excluding disclosure), whether automated or not. These actions may include collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure, or destruction. Please refer to the "Disclosure of Your Personal Information" section below for more details on the disclosure of personal data or sets of personal data.

This Privacy Notice applies to information we process:

• on Zoig; and
• on your communications with Zoig via email, online support chats, phoneline support or otherwise;

2. The Data We Process About You

Depending on whether you choose to create an account with us, we may process various types of personal data about you. This applies to individuals who visit Zoig without logging in or registering, also known as "Unregistered Users".

• Contact Data: We will only process your email address or any other information that you voluntarily provide to us for a specific purpose.
• Online Forms and Communication Data We process Contact Data and other information that you submit through online forms provided on Zoig. We also process information sent to us via email, online support chats, or any other inquiries. Additionally, we process information provided in the context of support requests, content reporting and moderation, and our internal complaint handling system.
• Website activity data: We collect information about your usage of Zoig, including the pages you visit, your search history on Zoig, and the referring web page that brought you to Zoig. We also collect information about your browser and operating system, the devices you use to access Zoig, and your time zone setting. Additionally, we process online identifiers, such as internet protocol (IP) address information, and we use cookies as explained in the section on Cookies and Automatic Data Processing Technologies...
• Identifiers: In certain instances, users may be requested to provide identifiers, such as government-issued photo identification and other documentation, to confirm that they meet the age requirement to access Zoig and view its content. When this occurs, trusted thirdparty age verification service providers handle the processing of this information. It's important to note that this Privacy Notice does not cover the privacy practices of these third-party age verification service providers. We recommend carefully reviewing the privacy terms and conditions of these third-party service providers.

For individuals who opt to create an account on Zoig ("Registered Users"), we handle the same types of information outlined for Unregistered Users, along with the following detail

• Contact Data: We handle usernames and email addresses.
• User Submitted Personal Information: We handle the information you provide to personalize your account or for a specific purpose. This includes your date of birth, age, gender, preferences, preferences for receiving marketing from us and our third parties, communication preferences, and any other information you voluntarily provide to us for a specific purpose.
• Identifiers and Biometric Information: If you decide to register for Zoig or if it's necessary for age verification purposes, we handle the identifiers you provide to us (including government-issued photo identification and other documentation) to verify your identity, age, and conduct record checks. Additionally, we may process biometric information to authenticate the identifiers you provide while registering for certain services, as explained further in the "Biometric Information" section below. Please note that this information is processed by trusted third-party age verification service providers. It's important to remember that this Privacy Notice doesn't apply to the privacy practices of these third-party age verification service providers. We recommend carefully reading the privacy terms and conditions of these service providers.
• User Contributions including Audio/Video Information: On Zoig, there are designated areas where you can share details about yourself and others, interact with fellow users, upload various content like images and videos, as well as comment on or review the content available on Zoig.

Please exercise caution when sharing user contributions: When you provide user contributions, it's important to be mindful of the information you share. By sharing user contributions, you are making that content and information publicly accessible. Other individuals have the ability to read, collect, use, and disclose your user contributions. We cannot control who accesses your user contributions or how other users may utilize the information you voluntarily post or submit. User contributions are governed by the Zoig terms and conditions found at https://www.zoig.com/terms.

Zoig has strict policies in place to prohibit minors from using the platform. Individuals under the age of 18 or the applicable age of majority in their jurisdiction are not allowed to access Zoig. Throughout the Privacy Notice, we may request certain information from users and our service providers to verify that they meet the age requirements to access Zoig. It is important to note that we do not knowingly process personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, then please contact us at help@zoig.com to have that minor's personal information deleted.

3. The Sources from Which We Process Personal Information

We process Personal Information in the following ways:

• Directly from you: We process the categories of information listed above directly from you.
• Automated technologies or interactions: As explained in the section below on Cookies and Automatic Data Processing Technologies, we set cookies and use other automatic techniques to process website activity data when you visit Zoig.

4. Purposes for Which We Process Your Personal Information

We process personal information for the following purposes:

• Provision of services: When you use our services, we process various types of data to provide you with the best experience possible. This includes identifiers, website activity data, and contact data (specifically for Registered Users). We also process user contributions, such as any interactive features on Zoig, as well as any products or services that you request from us. Our goal is to ensure that you have a seamless and enjoyable experience while using our services..
• For our Registered Users: we handle identifiers and Contact Data to effectively manage their accounts. This includes providing customer support and sending notifications regarding their accounts, as well as updates about Zoig, our products, and services. Additionally, we process identifiers and biometric information to verify the identity and authenticity of the provided identifiers during the registration process on Zoig. Our aim is to ensure a secure and reliable experience for our users.
• Communications and handling of requests: When it comes to communicating with you and addressing your requests, we handle various types of data to ensure a smooth process. This includes processing Online Forms, Communications Data, and other relevant information. Our goal is to promptly respond to and resolve your requests while also ensuring that we comply with our legal obligations.
• Analytics: We utilize identifiers and website activity data for analytics purposes on Zoig. This involves determining the uniqueness of users and identifying if the same user accesses Zoig multiple times. Additionally, we monitor aggregate metrics like the total number of visitors, pages viewed, and demographic patterns. Our aim is to gain insights into user behavior and engagement on the platform..
• Functionality and security: When it comes to ensuring the functionality and security of our services, we may process various categories of data. This includes diagnosing or fixing technology problems, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement. Our goal is to maintain a secure and reliable platform for our users.
• Platform Safety: In order to enhance platform safety on Zoig, we utilize the information gathered to safeguard users and ensure a secure environment, promoting a safe and protected experience for all Zoig users.
• Compliance: We process various categories of data to enforce this Privacy Notice, our terms and conditions, and to fulfill our legal obligations. This includes responding to your data subject requests, verifying the age of users accessing Zoig, addressing content reports, and ensuring compliance with content moderation and complaint handling obligations.
• Hash Values: We have the option to generate hash values from the data categories we handle, like identifying infringing or illegal content, to identify, prevent, and counter illegal activities such as fraud, sexual assault, or exploitation. We retain the right to share any generated hashes with law enforcement agencies.
• Information you provide: We may process Contact Data and usersubmitted personal information in any additional manner that we may specify when you provide the information or for any other purpose, subject to your separate consent provided outside of this Privacy Notice.

5. Our Legal Bases under Canadian and European Union (EU) Privacy Law

To comply with applicable laws, we depend on various lawful grounds to utilize your data for these purposes. This implies that we only process your personal data in situations where:

• You provide your consent for a specific purpose, such as allowing us to show you personalized ads or send you email marketing. You have the right to withdraw your consent at any time, and this will not affect any previous collection, use, processing, or disclosure of your data.
• Biometric information is processed based on your consent, and you have the right to withdraw your consent at any time.
• We process your data to perform our contractual obligations as stated in our terms and conditions on Zoig, such as creating your account.
• We may process your data to comply with legal obligations, which may include collecting, using, or disclosing your information in connection with civil, criminal, corporate, taxation, regulatory matters, or litigation.
• We process your data based on a legitimate interest that is not overridden by your data protection interests. This includes keeping Zoig safe and secure from fraud and illegal activities.
• Your data may be used to protect your or others' vital interests, such as in case of emergencies or to prevent crimes or fraud.
• We may process your data for tasks carried out in the public interest, such as combating unlawful behavior as defined by applicable law.

Depending on the situation, we may depend on various legal bases to process your information for different purposes. However, if you live outside the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), the legal bases we rely on might be different from the ones mentioned above.

6. Disclosure of Your Personal Information

We share personal information with third parties:

• Public Disclosure: By submitting user contributions, such as audio/ video content, you are utilizing Zoig and its services to make that information publicly available.
• Service providers: We disclose the categories of personal information we process to our authorized service providers who perform various services on our behalf. These services include identity and document authenticity verification, biometric processing, age verification, risk and fraud detection and mitigation, customer service, marketing and advertising, content customization, analytics, security, and hosting Zoig or supporting its functionality. Our service providers may have access to personal information necessary for performing their functions, but they are not allowed to process this information for any other purposes. We have entered into data processing agreements with these service providers to ensure that personal information is processed securely and in accordance with our instructions. If required by applicable laws, we have taken measures to ensure that personal information is only processed within the scope of these agreements.
• Legal successors: In the event of a merger, acquisition, sale, or transfer of some or all of our assets, including situations like bankruptcy, liquidation, or similar proceedings, we may disclose all categories of personal information we process to a buyer or other successor. This allows for the continuation of our services and ensures that your personal information is handled appropriately by the new entity.
• To comply with the law or protect our rights or the rights of third parties: In order to comply with the law or protect our rights, as well as the rights of third parties, we may access, preserve, and share all categories of personal information with regulators, law enforcement agencies, out-of-court dispute settlement bodies, or other relevant parties. This disclosure is done when we reasonably believe it is necessary to: (a) satisfy applicable laws, regulations, legal processes, or governmental requests, (b) enforce the terms of use, including investigating potential violations, (c) detect, prevent, or address illegal or suspected illegal activities, security or technical issues, (d) safeguard the rights, property, or safety of our company, users, employees, or others, (e) maintain and protect the security and integrity of Zoig and its infrastructure. In such cases, we may choose to raise or waive any legal objection or right available to us, at our sole discretion.

For more information on recipients of personal information, please see the section “Contact Information” below on how to contact us.

7. Cookies and Automatic Data Collection Technologies

As you browse and engage with Zoig, we employ automatic data collection technologies to gather website activity data. These technologies may encompass cookies, which are tiny text files that are stored in your web browser or downloaded to your device when you access Zoig.

We currently utilize the following cookie types, established by Zoig:

• Strictly necessary cookies: These cookies are essential for the operation of Zoig. They enable users to log in and determine if they have access to specific services or content.
• Functionality cookies: These cookies personalize and enhance your online experience on Zoig. They recognize you when you return and remember your language preference, among other things.
• Analytics cookies: These cookies help us understand and improve Zoig by tracking the number of users and how they navigate the site. We also use third-party session recording technologies to gain insights into user experiences, but the recorded data is pseudonymized.
• You can disable Analytics and Functionality cookies at any time by accessing the 'Manage cookies' option in the footer of Zoig. However, please note that declining these cookies may disable certain functionalities and limit your access to certain parts of Zoig.

Cookies can be categorized as either session cookies or persistent cookies. A session cookie is automatically deleted when you close your browser, while a persistent cookie remains until it expires or you manually delete your cookies. The expiration dates of cookies are determined by the cookies themselves, with some expiring after a few minutes and others lasting for multiple years.

Do Not Track: Our systems do not recognize browser "Do Not Track" signals.

We utilize Google as our service provider to gather and analyze data on how users interact with Zoig. This includes collecting website activity data through first-party cookies set by our domains and third-party cookies set by Google. To ensure privacy, we have enabled IP anonymization for Google Analytics, which means that Google will anonymize the last octet of an IP address and will not store the full IP address. The information collected is solely used for providing Google Analytics services and will not be used for any other purposes. Additionally, we make use of Google Signals, which assist us in running remarketing campaigns, gathering more accurate data, and gaining insights into user engagement across different devices (crossdevice activity) on Zoig. Google Signals are applicable to Google users who have accepted personalized advertising on their Google accounts. The data collected by Google Analytics may be transmitted to and stored on servers in the United States, adhering to standard contractual clauses approved by the EU and the EU Commission's adequacy decision (C (2023) 4745), which confirms an adequate level of data protection under the EU-US Data Privacy Framework and its national extensions. For more information on how Google uses data, you can visit their website. If you wish to opt-out of Google Analytics, you can do so by visiting the Google Analytics opt-out page or by accepting only necessary cookies.

8. Third-party Use of Cookies and Other Tracking Technologies

When you interact with content or applications on Zoig that are provided by third parties, these third parties may use cookies and other tracking technologies to gather information about you. This occurs when you click to view, access, or use any third-party features on Zoig or when you are directed to a third-party website. It's important to note that Zoig does not share any personal information with these third parties, unless expressly stated otherwise. However, if you click on a third-party internet-based advertisement, they may collect information such as your IP address, the advertisements you click on, your time zone setting and location, as well as details about your browser, operating system, and devices used to access Zoig. This information is collected in order to provide targeted content.

You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.

9. Your Choices About How We Collect, Use and Disclose Your Personal Information

Our goal is to offer you options when it comes to the personal information you share with us.

• Opting not to provide certain personal information may limit your access to certain features of Zoig. This information is necessary for activities such as creating an account, using our products or services, communicating with our support teams, or engaging in other activities on Zoig.
• The Cookie Banner allows you to customize your cookie preferences and keeps a record of your consent. For logged-in users, we request consent once a year or when there are significant changes to our cookies, ensuring you are aware of any updates to our cookies and Privacy Notice. Non-logged in users' Cookie Banner selection is only saved for the current session. The Cookie Banner specifically manages functionality, analytics, and advertising cookies used by Zoig. Please note that strictly necessary cookies cannot be disabled, and the tool does not block cookies on third-party websites linked from our site.
• You can opt out of receiving marketing emails from us using the optout link provided in our emails or by changing your preferences in your account settings if you are a Registered User, we may also continue to send you other types of important emails e.g., e-mails about your account.
• If you are a Registered User, you have the option to unsubscribe from receiving marketing emails by adjusting your preferences in your account settings. However, please note that we may still send you other important emails, such as notifications regarding your account.
• Within your account settings, you have the ability to remove your user contributions as well as any audio/video information associated with your account.
• You have the option to delete and deactivate your account with us at any time, unless prohibited by law or a court order. If you choose to do so, your profile will become inaccessible to you. If you decide to create a new account in the future, you will need to sign up again, as none of your previously provided or saved information will be retained.

10. California Rights and Choices

Starting from January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) grants certain rights to California residents (referred to as "Consumers") regarding their personal information as defined by the CCPA. In addition to the rights mentioned in this Privacy Notice, and subject to CCPA exceptions, Consumers have the right to:

• Opt-out of the sale of their personal information if we engage in such sales.
• Receive information about the collection and use of their personal information.
• Request the deletion of specific personal information collected from them.
• Designate an agent to exercise their CCPA rights, provided the agent presents a duly executed notarized power of attorney and possesses sufficient information for us to verify the Consumer's identity and locate their information in our systems.
• Not face discrimination for exercising these rights. We will not deny California residents access to our service, nor will we provide a different level or quality of service based on the exercise of their CCPA rights, unless permitted by the CCPA.

Zoig does not sell, and has not sold in the past twelve (12) months, personal information to third parties in exchange for money or any other valuable consideration. However, we may disclose certain personal information to third parties, service providers, and entities within our corporate group. This is done to facilitate specific services on our behalf and ensure the proper functioning of Zoig, as explained in detail in the section titled "Disclosure of Your Personal Information" above.

We fully respect the rights of California residents to exclude their personal information from such sharing arrangements. We provide them with the option to opt-out of any future sale of their personal information. If you are a Registered User and the California Consumer Privacy Act (CCPA) applies to you, and you wish to exercise your rights, please utilize the buttons located at the bottom of this page or send an email to help@zoig.com with the subject line "CCPA Request".

To verify your identity and locate your information in our systems, you will need to provide the following details: your username and email address that you used during the account creation process. Additionally, we may request other reasonable information to verify your identity. It may be necessary for you to verify that you have access to your account and/or the email account associated with your registration.

If you prefer, you can designate an agent to act on your behalf by executing a notarized power of attorney. The agent should be provided with the aforementioned information to verify your identity and locate your information. Alternatively, you can directly confirm your identity with us using the methods mentioned above. In this case, you will need to sign an authorization for the agent to act on your behalf and provide us with confirmation that you have completed this process.

11. Resident's Rights - Jurisdictions in the United States, Where Applicable

We do not engage in the sale, trade, or exchange of personal information belonging to our Registered Users with any party in exchange for monetary compensation.

12. Biometric Information

To ensure the accuracy of your identity, age, and the validity of the identification documents you provide, we may enlist the assistance of third-party service providers. These providers utilize facial recognition technology, which generates a mathematical representation of your facial features based on a live scan of your face, your selfie, and the government-issued ID you have submitted or previously provided to us. The information derived from this mathematical representation, which may be classified as biometric information in certain states and countries, is shared with us by our service providers as explained in more detail below.

Your biometric information will be used for the following purposes:

• To verify that you are a real, live person and to prevent any attempts to impersonate someone else.
• To compare your selfie with the government-issued ID you have submitted or previously provided, ensuring that no one is pretending to be you.
• To assist in confirming your age.
• We will store your biometric information in accordance with the "Retention of Personal Information" section outlined below.

Please note that the section titled "Biometric Information" applies to users who wish to upload content on Zoig, but it does not apply to identifiers processed by our third-party age verification service providers. These providers solely use the information for granting you access to view the contents on Zoig.

13. Transfers of Your Personal Information to Other Countries

By using Zoig, you agree to the transfer of information, including personal information, to other countries where we, our corporate group members (including affiliates and related entities), or our service providers are located, as long as the laws of your country allow it. When we transfer personal information to countries outside of the European Economic Area (EEA) or other regions with comprehensive data protection laws, we ensure that the transfer complies with the applicable laws. We rely on "adequacy decisions" made by the European Commission, which recognize certain countries as having a level of personal data protection equivalent to the EEA. In other cases, we use standard contractual clauses approved by the European Commission (and the equivalent clauses for the UK, if applicable) or rely on derogations provided by the law to transfer information to third countries.

14. Retention of Personal Information

We will retain your personal information only as long as your account is active or as necessary to fulfill the purposes for which we processed it. This includes satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider various factors such as the type of personal data being processed, the risk of unauthorized disclosure, the purpose of processing your personal data, and whether there are alternative means to achieve the same outcome without processing it. When we no longer need to process your personal information for the purposes stated in this Privacy Notice, we will delete it from our systems.

If permissible, we will also delete your personal information upon your request, as explained in the "Your Rights Related to Your Personal Information" section above.

15. Third-Party Links and Sites

If you click on a link to a third-party website, you will be taken to websites we do not control. This Privacy Notice does not apply to the privacy practices of these websites. Read the Privacy Notice of other websites carefully. We are not responsible for these third-party practices.

16. Changes to Our Privacy Notice

When you click on a link to a third-party website, you will be redirected to websites that are not under our control. Please note that this Privacy Notice does not apply to the privacy practices of these websites. It is important to carefully read the Privacy Notice of other websites before using them. We want to emphasize that we are not responsible for the privacy practices of these third-party websites.

17. Contact Information

If you have any inquiries regarding this Privacy Notice or how we handle information, please don't hesitate to reach out to us. You can contact us at help@zoig.com for any questions or concerns related to this Privacy Notice or our information-handling practices.

If you need to get in touch with our Data Protection Officer, you can reach out to them at the email address dpo@zoig.com.

18. Your Rights Related to Your Personal Information

You have certain rights regarding your personal data, subject to local law and applicable legal requirements and exemptions:

• Right of access: You have the right to receive information about the personal data we hold about you, how it is used, and obtain a copy of your personal data.
• Right to rectification: You have the right to correct any inaccurate personal data concerning you.
• Right to be forgotten: You have the right to delete or erase your personal data.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and transmit it to another data controller.
• Right to object: You have the right to object to the use of your personal data based on our legitimate interests or public interests.
• Right to restriction of processing: In some cases, you have the right to restrict our use of your personal data.
• Right to file a complaint: If you are in the EEA or the UK, you also have the right to file a complaint with your local data protection authority

If we request your consent to process your personal data, you have the right to withdraw your consent at any time, which will affect your ability to use certain functionalities on Zoig or access Zoig in some cases.

To exercise your rights of access or deletion of your data, you can follow the dedicated links in the "Manage Your Personal Data" section below. If you need assistance with exercising your rights, you can also send an email to help@zoig.com, and we will assist you with the process. Please note that we have a one-month timeframe to respond to your request.

Before processing an access or deletion request for your data, we will need to verify your identity and ensure your right to access or delete the information. This is a necessary security measure to prevent unauthorized disclosure or deletion of personal data.

Please note that if you haven't created an account with us, we may not have sufficient information to identify you and may not be able to respond to your request. Additionally, in some cases, we may require you to provide additional information to adequately verify your identity or authorization to make the request.

It's important to note that certain requests to delete specific personal information may require the deletion of your user account since user accounts are closely linked to the processing of certain personal information, such as your email address. If you delete your account, all your personal data, including user profile data, sharing data, and any associated data or content, will no longer be accessible to you. If you decide to create a new account in the future, you will need to sign up again as none of the previously provided or saved information will be retained.

19. Manage Your Personal Data

Registered Users have the option to request a copy of their personal data or ask for the deletion of their personal data by contacting us at help@zoig.com.

20. Company operator

The company operator (also referred to as "we", "us", or "our" in this privacy notice) of the website https://www.zoig.com/ (also known as "Zoig") is the data controller responsible for deciding whether and how to process personal data collected or provided via Zoig: