Effective Date: February 21, 2023

Zinger Media Limited (“Zinger,” “we,” “us” or “our”) respects the privacy

of visitors to our websites, apps and online services and values the

confidence of our customers, partners, and employees. This Privacy Policy

sets forth Zinger’s practices regarding the collection, use and disclosure of

information that you may provide through the websites that we operate,

their subdomains, and all portals (“Websites”), our mobile applications

(“Apps”), all other products, services, events or interactive features

(“Services”) that link to this Privacy Policy, as well as Personal

Information provided to Zinger by any means. Additional privacy

disclosures may be made at the time of collection of the information. WE

DO NOT SELL YOUR PERSONAL INFORMATION. Please read the

entire Privacy Policy before using our Websites, Apps or Services. By

using the Websites, Apps or Services, you agree to abide by the terms of

this Privacy Policy. This Privacy Policy is also part of our Terms of Use,

which govern your use of the Websites and Apps.

Collection of Information

We may ask you for some or all of the following types of information when

you access various content or features of the Websites, Apps or Services,

submit content, or directly contact us:

 Contact information, such as name, email address, postal address,

and telephone number;

 Online identifiers, such as Internet Protocol (IP) address, cookies,

username, and password;

 Information from social media accounts;

 Annotations you make in the App or on the Websites (for your

privacy, we discourage you from including sensitive health or other

personal information in your annotations; any annotations made by

you are at your own discretion and your own risk);

 Financial information, such as credit card, debit card or bank

account number, if necessary for payment (we do not store this

information);

 Search queries;

 Other Personal Information that may be contained in employment

applications, including submissions of your professional or

educational background, your contact information and other

information contained in resumes, cover letters, recommendations,

and references;

 Personal Information contained within correspondence and other

information that you send to us.

We also may collect certain information automatically when you visit the

Websites and Apps, including:

 Your IP address, which is the number automatically assigned to your

computer whenever you access the Internet and that can sometimes

be used to derive your general geographic area;

 Other unique identifiers, including mobile device identification

numbers (e.g., IDFA, Android/Google Advertising ID, IMEI);

 Your browser type and operating system;

 Your device characteristics;

 Sites you visited before and after visiting the Websites and Apps;

 Pages you view and links you click on within the Websites and Apps,

including remembering you and your preferences;

 Your device location and/or other geolocation information,

including the zip code, state, or country from which you accessed

the Websites and Apps;

 Information collected through cookies, web beacons and other

technologies;

 Information about your interactions with email messages, such as

the links clicked on and whether the messages were received,

opened, or forwarded;

 Standard Server Log Information.

We may use cookies, pixel tags and similar technologies to automatically

collect this information. Cookies are small bits of information that are

stored by your computer’s web browser. Pixel tags are very small images

or small pieces of data embedded in images, also known as “web beacons”

or “clear GIFs,” that can recognize cookies, the time and date a page is

viewed, a description of the page where the pixel tag is placed, and similar

information from your computer or device. By using the Websites or Apps,

you consent to our use of cookies and similar technologies. You can decide

if and how your computer will accept a cookie by configuring your

preferences or options in your browser. However, if you choose to reject

cookies, you may not be able to use certain online products, services or

features on the Websites or Apps.

Use of Information

We may use information that we collect through the Websites, Apps or in

person for a variety of purposes, including to:

 Operate and improve our Websites, Apps and Services;

 Understand you and your preferences to enhance your experience

and enjoyment using our Websites, Apps and Services;

 Process employment applications;

 Respond to your comments and questions and provide customer

service;

 Maintain your account;

 Verify your identity and for fraud prevention;

 Provide and deliver products, information, and services you request

and identify your preferences;

 Process your payments or purchases;

 Meet our audit, compliance, and regulatory obligations;

 Send you information, including confirmations, invoices, technical

notices, updates, security alerts and support and administrative

messages;

 Communicate with you about upcoming events and news about

products, information and services offered by Zinger or our selected

partners;

 Link or combine with other Personal Information we get from third

parties, to help understand your needs and provide you with better

service;

 Assist when it is necessary for emergency medical purposes or to

protect your or another person’s vital interests;

 Comply with a law, court order, or other judicial or administrative

process;

 Protect, investigate, and deter against fraudulent, unauthorized, or

illegal activity; and

 As otherwise described to you at the point of collection or with your

consent.

Sharing of Information

We are committed to maintaining your trust, and we want you to

understand when and with whom we may share the information we

collect. We do not sell your Personal Information. We may need to

provide your Personal Information to others in the following instances:

 Corporate Parents and Affiliates. As applicable, we may share your

information with affiliated entities for a variety of purposes,

including business, operational and marketing purposes.

 Service Providers. We may share your information with service

providers that perform certain functions or services on our behalf

(such as to host the Websites and Apps, manage databases, process

payments or other data, perform analyses or send communications

for us).

 Other Parties When Required by Law or as Necessary to Protect the

Websites and Apps. We may disclose your information to third

parties in order to: protect the legal rights, safety and security of

Zinger, affiliates and the users of our Websites and apps; enforce our

comply with or respond to law enforcement or legal process or a

request for cooperation by a government entity, whether or not

legally required.

 In Connection with a Transfer of Assets. If we sell all or part of our

business, or make a sale or transfer of assets, or are otherwise

involved in a merger or business transfer, or in the event of

bankruptcy, we may transfer your information to one or more third

parties as part of that transaction.

 Other Parties with Your Express or Implied Consent. We may share

information about you with third parties when you consent to such

sharing.

 Aggregate Information. We may disclose to third parties

information that does not describe or identify individual users, such

as aggregate usage data or demographic reports for the Websites and

Apps. (This is not considered Personal Information.

 In addition, we may allow third parties to place and read their own

cookies, web beacons and similar technologies to collect

information through the Websites and Apps. For example, our

third-party service providers may use these technologies to collect

information that helps us with traffic measurement, research, and

analysis. Please note that you may need to take additional steps

beyond changing your browser settings to refuse or disable some of

these technologies. If you choose to refuse, disable, or delete these

technologies, some of the functionality of the Websites and Apps

may no longer be available to you. You understand that when you

use the Websites and Apps, these analysis providers may collect

information related to your use of the Websites and Apps.

Security

We maintain a variety of security procedures to help protect against loss,

misuse, unauthorized access, disclosure, alteration, or destruction of the

information you provide through the Websites and Apps. However, no data

transmission over the Internet or stored on a server can be guaranteed to be

100% secure. As a result, while we strive to protect your information and

privacy, we cannot guarantee or warrant the security of any information

you disclose or transmit to us online and cannot be responsible for the theft,

destruction or inadvertent disclosure of your information. Please see our

Response to “Do Not Track” Signals

Do Not Track (“DNT”) is a web browser setting that requests a web

application disable its tracking of an individual user. When you choose to

turn on the DNT setting in your browser, your browser sends a special

signal to Websites, analysis companies, ad networks, plug in providers,

and other web services you encounter while browsing to stop tracking your

activity. However, because there currently is no industry standard

concerning what, if anything, Websites should do when they receive such

signals, we currently do not take action in response to these signals.

Children’s Privacy

Zinger respects the privacy of children, and no part of our Site is targeted to

attract anyone under the age of 13. Zinger does not knowingly collect, use,

or disclose Personal Information from children under the age of 13 without

prior parental consent. Users from ages 13 to 15 must represent and

warrant that they are visiting the Site under the supervision of a parent or

guardian, and we may ask your parent or guardian to provide prior written

consent for you to use the Site. By providing your consent, you agree that

we may collect, use, and disclose your child’s Personal Information

consistent with this Privacy Policy. If you believe we have information

regarding a child under the age of 16 that you have not authorized, you may

Your Choices Regarding Your Personal Data

If you receive emails or other communications from us, you may indicate a

preference to stop receiving further communications from us and you will

have the opportunity to “opt-out” by following the unsubscribe

instructions provided in the email you receive or by contacting us directly

at our contact information below. If you opt out, we may still send you

non-promotional emails, such as emails about our ongoing business

relations. You may also request changes or updates to your Personal

Information by sending a request at our contact information below.

International Transfers of Information

If you are visiting the Site from a location outside of the United States,

your connection will be through and to servers located in the United States.

All information you receive from the Site will be created on servers located

in the United States, and all information you provide will be maintained on

web servers and systems located within the United States. Your

information, including your Personal Information, may be transferred to –

and maintained on --- computers located in the United States. The data

protection laws in the United States may differ from those of the country in

which you are located, and your information may be subject to access

requests from governments, courts, or law enforcement in the United

States according to laws of the United States. Your consent to this Privacy

Policy, followed by your submission of your information represents your

agreement to the collection, storage, processing and transfer of your

information in and to the United States, or other countries and territories,

pursuant to the laws of the United States.

Zinger will take all the steps reasonably necessary to ensure that your

Personal Information is treated securely and in accordance with this

to an organization or a country unless there are adequate controls in place

including the security of your data and other Personal Information.

Your Additional Data Protection Rights Under the

General Data Protection Regulation (GDPR)

If you are a resident of or located within the European Economic Area

(EEA), you have certain additional data protection rights. These rights

include:

 The right to access, update or delete the information we have about

you. Whenever made possible, you can access, update or request

deletion of your Personal Information by contacting us at the contact

information below.

 The right of rectification. You have the right to have your

information rectified if that information is inaccurate or incomplete.

 The right to object. You have the right to object to our processing of

your Personal Information.

 The right of restriction. You have the right to request that we restrict

the processing of your Personal Information.

 The right to data portability. You have the right to be provided with a

copy of the information we have on you in a structured,

machine-readable, and commonly used format.

 The right to withdraw consent. You also have the right to withdraw

your consent at any time where Zinger relied on your consent to

process your Personal Information.

Legal Bases for Processing Personal Information

Under the GDPR

Zinger is a controller of Personal Information. Zinger’s legal bases for

collecting or processing your Personal Information are as follows:

 We need to provide a service to you;

 You have given us your consent to do so;

 The processing is in our legitimate interests and it is not overridden

by your rights; or

 To comply with the law.

Retention of Information

Zinger will retain your Personal Information only for as long as is

necessary for the purposes set out in this Privacy Policy. We will retain and

use your Personal Information to the extent necessary to comply with our

legal obligations (for example, if we are required to retain your

Information to comply with applicable laws), resolve disputes and enforce

our legal agreements and policies.

Zinger will also retain Personal Information and usage data for internal

analysis purposes. Usage Data is data collected automatically either

generated by the use of the Site or from the Site infrastructure itself (for

example, the duration of a page visit). Usage Data is generally retained for

a shorter period of time, except when this data is used to strengthen the

security or to improve the functionality of our Site or we are legally

obligated to retain this data for longer periods.

Disclosure of Personal Information

Zinger may disclose your Personal Information in the good faith belief that

such action is necessary to:

 To comply with a legal obligation or in response to valid requests by

public authorities or as otherwise set forth in this Privacy Policy;

 To protect and defend the rights or property of Zinger;

 To prevent or investigate possible wrongdoing in connection with

the Service;

 To protect the personal safety of users of the Service or the public;

and/or

 To protect against legal liability.

Exercising Your Rights Under the GDPR

If applicable, you may exercise any of your rights under the GDPR by

submitting a verifiable data subject request to us by using the details in the

Contact Information section below. You may make a request related to

your Personal Information or on behalf of someone for which you have

authorization. You must include your full name, email address, and attest

to the fact that you are a citizen or resident of the EEA by including your

country of citizenship or residence in your request. We may require you to

confirm your identity and/or legal standing for the request as well as your

residency in the EEA in order to obtain the information. We will respond to

your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding

to such requests, and we may deny your request if we are unable to verify

your identity or authority to make the request.

Should you wish to raise a concern about our use of your information (and

without prejudice to any other rights you may have), you have the right to

do so with your local supervisory authority; however, we hope that we can

assist with any queries or concerns you may have about our use of your

Personal Information first by contacting us at hiidev.zinger@gmail.com.

For more information about the GDPR, please contact your local data

protection authority in the EEA.

Your Additional Data Protection Rights Under the Lei

Geral de Proteção de Dados (LGPD)

If you are located in the national territory of Brazil, you have certain

additional data protection rights. These rights include:

 The right to confirmation of the existence of the processing;

 The right to access the data;

 The right to correct incomplete, inaccurate or out-of-date data;

 The right to anonymize, block, or delete unnecessary or excessive

data or data that is not being processed in compliance with the

LGPD;

 The right to the portability of data to another service or product

provider, by means of an express request;

 The right to delete personal data processed with the consent of the

data subject;

 The right to information about public and private entities with which

the controller has shared data;

 The right to information about the possibility of denying consent

and the consequences of such denial; and

 The right to revoke consent.

Legal Bases for Processing Data Under the LGPD

Zinger’s legal bases for collecting or processing your Personal Information

are as follows:

 We need to provide a service to you;

 You have given us your consent to do so;

 The processing is in our legitimate interests and it is not overridden

by your rights; or

 To comply with the law.

Duration of Processing

Zinger will process and retain your Personal Information only for as long

as is necessary for the purposes set out in this Privacy Policy. We will

retain and use your Personal Information to the extent necessary to comply

with our legal obligations (for example, if we are required to retain your

Information to comply with applicable laws), resolve disputes and enforce

our legal agreements and policies.

Zinger will also retain Personal Information and usage data for internal

analysis purposes. Usage Data is data collected automatically either

generated by the use of the Site or from the Site infrastructure itself (for

example, the duration of a page visit). Usage Data is generally retained for

a shorter period of time, except when this data is used to strengthen the

security or to improve the functionality of our Site or we are legally

obligated to retain this data for longer periods.

Exercising Your Rights Under the LGPD

If applicable, you may exercise any of your rights under the LGPD by

submitting a verifiable data subject request to us by using the details in the

Contact Information section below. You may make a request related to

your Personal Information or on behalf of someone for which you have

authorization. You must include your full name, email address, and attest

to the fact that you are a citizen or resident of Brazil in your request. We

may require you to confirm your identity and/or legal standing for the

request as well as your residency in order to obtain the information. We

will respond to your request within 15 days.

Links to Third-Party Content

As a convenience to our visitors, the Websites and Apps may link to a

number of sites, services and other content that are operated and

maintained by third parties. These third parties operate independently from

us, and we do not control their privacy practices. You are encouraged to

use common sense when sharing your Personal Information, and you

should be aware when you leave our Site to visit another Site. None of the

links on this Site should be deemed to imply that Zinger endorses the

content or has any affiliation with the persons or entities associated

therewith. This Privacy Policy does not apply to third-party content. We

encourage you to review the privacy policies of any third party to whom

you provide information.

Social Networking Services

Zinger may work with certain third-party social media providers to offer

you their social networking services through our Websites and Apps. For

example, you can use third-party social networking services such as

Facebook to log into your Zinger account. These social networking

services may be able to collect information about you, including your

activity on our Websites and Apps. These third-party social networking

services also may notify your friends, both on our Websites and Apps and

on the social networking services themselves, that you are a user of our

Websites and Apps or about your use of our Websites and Apps, in

accordance with applicable law and their own privacy policies. If you

choose to access or make use of third-party social networking services, we

may receive information about you that you have made available to those

social networking services, including information about your contacts on

those social networking services.

Policy Updates

This Privacy Policy may be revised from time to time as we add new

features and services, as laws change, and as industry privacy and security

best practices evolve. We display an effective date on the policy in the

upper left corner of this Privacy Policy so that it will be easier for you to

know when there has been a change. If we make any material change to

this Privacy Policy regarding use or disclosure of Personal Information, we

will provide advance notice through the Websites and Apps. Small

changes or changes that do not significantly affect individual privacy

interests may be made at any time and without prior notice. If you are

concerned about how your Personal Information is used, please visit our

Site often for this and other important announcements and updates.

Contact Information

If you have any questions about this Privacy Policy, please contact us at:

Email: hiidev.zinger@gmail.com