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PRIVACY POLICY

1. ABOUT THIS POLICY

 1.1 This is the Privacy & Cookies Policy (“Policy”) for ZujuGP.

1.2 In this Policy, “ZujuGP”, “we”, “us” or “our” refers to Mint Media Sports Limited and its affiliates.

 1.3 We will only use your personal data where you have given us your consent or where we have other lawful basis for doing so, and in the manner set out in this Policy.

1.4 This Policy sets out the manner in which and for what purposes we collect, use, disclose and process your personal data when you access or use our website or mobile and web-based applications (collectively, “Applications”), services, or when you otherwise provide us with your personal data, regardless of the medium through which such personal data is provided. If the stated purposes of processing are altered for any reason after we have collected your personal data, we will seek for your consent for such further processing where required by applicable data protection law.

1.5 By providing us with your personal data, you acknowledge that our collection, use, disclosure and processing of your personal data will be in accordance with this Policy, including, for the avoidance of doubt, the cross jurisdictional transfer of your data. If you object to how we will collect, use and share your personal data as set out in this Policy, please DO NOT provide any personal data to us.

1.6 This Policy supplements but does not supersede or replace any consents you have provided to us, or any other agreements or arrangements that you have with us, in respect of your personal data.

1.7 Our Applications may contain links to websites that are not owned or maintained by us. These links are provided only for your convenience. This Policy only applies to our Applications. When visiting and being redirected to these third party websites or engaging third party service providers, their privacy policies apply. We recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these third party service providers. We are not liable to you in respect of any data you transfer to these third parties websites or your engagement and use of third party service providers.

1.8 Please note that our webstore is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.


 1.9 If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more insight, you may also want to read Shopify’s Terms of Service or Privacy Payment gateways and other payment transaction processors, also have their own privacy policies in respect to the information required for your purchase-related transactions. Certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

2. AMENDMENTS TO THIS POLICY

2.1 We may amend this Policy from time to time without notice to you, in compliance with applicable laws or as we update our data usage and handling processes. You are encouraged to re-visit our Policy from time to time to keep yourself updated on these changes. The updated Policy will take effect when made available through . The updated Policy will supersede earlier versions and will apply to your personal data provided to us previously. If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why we use your personal data, we will notify you by way of a prominent notice on our website or, if we have your email address, by email.

3. COLLECTING PERSONAL DATA

3.1 What is personal data. “Personal Data” is data that can be used to identify a natural person. Personal Data we collect and for what purpose will depend on the type of services provided to you and may include:

  • Identification information such as first and last name, date of birth, nationality, country of residence, gender, photograph/images;

  • Contact details such as postal address, billing address, phone number and email address;

  • Membership information such as your username and password or any other information about you when you sign up as a ZujuGP member, and when you use our Applications, as well as information related to how you use our Applications;

  • Financial information such as bank account information;

  • Family information such as marital status, number of children, identity of spouse;

  • Marketing and communications data, such as your preferences in receiving marketing from us and third parties, your communication preferences and history of communications with us, our service providers, and other third parties;

  • Usage and transaction data, such as details about your searches, orders, the advertising and content you interact with on the Applications, and other products and services related to you; and

  • Aggregate data on content you engage with.

 3.2 Provision of personal data. We may collect personal data (1) that you voluntarily provide to us; or (2) from third parties; or (3) through your use of our digital technologies and services (please see Section 4 How We Collect Personal Data for further details). What type of personal data we collect depends on the purposes for which the personal data is collected and what you have chosen to provide.

Where our collection is based on consent, you can choose not to provide us with personal data. You also have the right to withdraw your consent from us to continue collecting, using, disclosing and processing your personal data, by contacting us as outlined in Section 11.1. However, if you do withdraw your consent, it may then not be possible for us to fulfil the purposes for which we require the personal data, including processing your transactions or providing you with the products and services that you require.

 3.3 Providing personal data belonging to others. In certain circumstances, you may also provide us with personal data of persons other than yourself. If you do so, you warrant that you have brought this Policy to his/her attention, informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Policy.


 3.4 Accuracy and completeness of personal data. You are responsible for ensuring that all personal data that you provide is true, accurate and complete, and to inform us of any changes to your personal data.


 3.5 Minors Our Applications and/or services are not intended to be accessed or used by children, minors or persons who are not of legal age in the relevant jurisdiction. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us.


 4. HOW WE COLLECT PERSONAL DATA


 4.1 Personal data you provide. We collect personal data that is relevant to our relationship with you. We may collect your personal data directly or indirectly through various channels, such as when:

  • you download or use our Applications and services

  • you register or create a ZujuGP membership account;

  • you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;

  • you authorise us to obtain your personal data from a third party;

  • you enter into agreements with us;

  • you transact with us, contact us or request that we contact you through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;

  • you request to be included in an email or our mailing list;

  • your images are captured via CCTV cameras while you are within our premises;

  • your images are captured via photographs or videos taken by us or our representatives when you attend events organised by us;

  • when you attend events or functions organised by us;

  • we seek information about you and receive your personal data in connection with your relationship with us,; and/or

  • you submit an application for employment, internship or secondment, or when you provide documents or information including your resume in connection with the aforesaid application.

  • The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

 4.2 Personal data provided by others. Depending on your relationship with us, we may also collect your personal data from third party sources, for example, from:

  • our business partners such as third parties providing advertising, marketing, promotional, payment management and e-commerce services to us;

  • your family members or friends who provide your personal data to us on your behalf;

  • your referees, educational institutions or previous employers (if you have applied to us for a job); and/or

  • public agencies or other public sources.

4.3 Automated Data Collection Technologies. Our Applications may contain or we may deploy certain technologies (including those described at Section 6 below) that collect data from you, such as your Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Applications that you visit, the time and date of your visit, your time spent on our Applications, unique device identifiers and other diagnostic data.

 

5. WHAT WE DO WITH PERSONAL DATA

5.1 What we do. We collect, use, disclose and process your personal data where:

  • you have voluntarily provided us with your personal data;

  • you have given us consent;

  • necessary to comply with our legal or regulatory obligations, e.g. responding to valid requests from public authorities;

  • necessary to support our legitimate business interests, provided that this does not override your interests or rights; and

  • necessary to perform a transaction you have entered into with us, or provide a service that you have requested or require from us.

 5.2 Purposes. We collect, use, disclose and process your personal data for purposes connected or relevant to our business, or to manage your relationship with us. Such purposes would include:

  • carrying out your transactions with us and our business partners, taking steps as may be directed by you, or to provide products and/or services to you;

  • facilitating your use of our Applications, including verifying and establishing your identity, and authenticating, operating and maintaining user accounts;

  • providing you with relevant information and updates concerning our products and/or services, including such products and/or services that are made available to you on our Applications;

  • providing our products and services and processing payment or credit transactions;

  • communicating with you and assisting you with your enquiries, feedback, complaints, disputes and requests;

  • resolving any disputes, investigating any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct;

  • administrative purposes, e.g. accounting, risk management and record keeping, business research, data, planning and statistical analysis, and staff training;

  • security purposes, e.g. protecting our Applications and platforms from unauthorised access or usage and to monitor for security threats;

  • providing and maintaining our Applications;

  • monitoring the usage of our Applications;

  • performing data analytics and related technologies on data, to enable us to deliver relevant content and information to you, and to improve our Applications;

  • managing and engaging third parties or data processors that provide services to us, e.g. IT services, delivery services, messaging marketing, and other professional services;

  • managing the safety and security of our premises;

  • if you were applying to us for employment, taking steps in connection with your recruitment and on-boarding as our employee;

  • carrying out our legitimate business interests;

  • such purposes that may be informed to you when your personal data is collected;

  • complying with legal or regulatory obligations; and/or

  • other reasonable purposes related to the above.

Where personal data is used for a new purpose and where required under applicable law, we shall obtain your consent for the new purpose.

5.3 Legitimate business We may also collect, use, disclose and process your personal data for the following purposes to support our legitimate business interests, provided that this does not override your interests or rights, which include:

  • managing our business and relationship with you, and providing services to our customers;

  • protecting our rights and interests and those of our employees and/or members;

  • complying with legal or regulatory obligations, internal policies and procedures;

  • enforcing our terms and conditions and obligations owed to us, or protecting ourselves from legal liability;

  • offer additional employment opportunities to job seekers or employees of ZujuGP;

  • manage our investor and shareholder relations; and

  • carrying out corporate restructuring plans or processing or sharing your personal data to facilitate acquisitions, mergers or transfers of our business.

5.4 Marketing purposes. We may use your personal data for direct marketing. In order for us to market products, events and services which are of specific interest and relevance to you, we may analyse and rely on your personal data provided to us, or data collected from your interactions with us. However, no marketing, whether direct, jointly, or by a third party, using your personal data would be carried out unless you have provided us with your consent to use your personal data for such marketing purposes (unless we are exempted by applicable law from having to obtain your express consent). In particular, we will not transfer your personal data to a third party for direct marketing, unless you have provided us with your consent.If you do not want us to use your personal data for the purposes of marketing you can withdraw your consent at any time by sending an email to support@zujugp.com. Your withdrawal will be effective on the date of our acknowledgement of receipt.

5.5 Use permitted under applicable laws. We may also collect, use, disclose and process your personal data for other purposes, without your knowledge or consent, where this is required or permitted by law. Your personal data may be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim. We will not delete your personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

5.6 Contacting you. When using your personal data to contact you for the above purposes, we may contact you through the Application or via e-mail, telephone or any other means. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us by support@zujugp.com.


 6. USE OF AUTOMATED DATA COLLECTION TECHNOLOGIES

6.1 In order to improve our products or services, we collect data by way of “cookies”. A cookie is a small file of letters and numbers that we store via your browser on the hard drive of your computer or mobile device. There are three main types of cookies:

  • Session cookies: specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don't have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;

  • Persistent cookies: record information about your preferences and are stored in your browser cache; and

  • Third party cookies: placed by someone other than us which may gather data across multiple websites or sessions.

6.2 How we use cookies. We use cookies for the following purposes:

  • Strictly necessary: These cookies are essential for you to browse our Applications and use its features. The information collected relates to the operation of the Applications (e.g. website scripting language and security tokens) and enables us to provide you with the service you have requested.

  • Functionality: These cookies remember the choices you have made, for example the country you visit our Applications from, your language and any changes you have made to text size and other parts of the web pages that you can customise to improve your user experience and to make your visits more tailored and enjoyable. [The information these cookies collect may be anonymised and cannot be used to track your browsing activity on other websites]

  • Performance/analytics: These cookies collect information on how users use our Applications, for example which pages you visit most often, whether you receive any error messages and how you arrived at our website. Information collected by these cookies is used only to improve your use of our Applications. These cookies are sometimes placed by third party providers of web traffic and analysis services. We use Google Analytics. For information on how Google processes and collects your information and how you can opt out, please click here.[1]

  • Targeting or advertising: These cookies collect information about your browsing habits and inferred interests to make advertising more relevant to you. They are also used to limit the number of times you see an advert as well as to measure the effectiveness of an advertising campaign. These cookies are usually placed by third party advertising networks. They remember the other websites you visit and this information is shared with third party organisations, for example advertisers.

  • Social Media: These cookies allow users to share our content on our Applications on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies of the social media providers for how their cookies work.

We may also automatically collect and store certain information about your interaction with our Applications including IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps and related data.

6.3 Other technologies. In addition to cookies, we use some other similar technologies as follows:

    • Web Beacons: small graphic images included on our Applications or emails or those of third parties to provide analytics information.

    • Social widgets: buttons or icons provided by third party social media networks which may collect browsing data and will be received by the third party and are controlled by the third party.

    • SDKs: these are mobile application third party software development kits used in our apps. They enable us to collect information about app activity and the device it runs on.

    • Local shared objects: these are sometimes called flash cookies and can be stored on your browser. They are used to maintain preferences and usage records.

 

6.5 Refusing or deleting cookies. Most internet browsers are set up by default to accept cookies. However if you want to refuse or delete them (or similar technologies) please refer to the help and support area on your browser for instructions on how to block or delete cookies (for example: Internet Explorer, Google Chrome, Mozilla Firefox, Safari, Opera, etc.). Please note you may not be able to take advantage of all the features of our Applications, including certain personalised features, if you delete or refuse cookies.

6.6 Mobile Opt-out. If you access our Applications through a mobile device, you can enable a "do not track" feature so as to control interest-based advertising on an iOS or Android mobile device by selecting the Limit Add Tracking option in the privacy section of your Settings on iOS or via advertising preferences on Android devices (e.g. in Google Settings). This will not prevent the display of advertisements but will mean that they will no longer be personalised to your interests.

6.7 If you are a resident in the EU. For more information on managing cookies, please visit www.youronlinechoices.eu which has further information about behavioral advertising and online privacy.

6.8 Changes to our uses of Cookies. If we change anything important about this Section 6 on cookies, we will notify you through a pop-up on the website for a reasonable length of time prior to and following the change. You may review this Section by visiting the sites and clicking on the “Privacy Policy” link.


 7. DISCLOSURE OF PERSONAL DATA

7.1 Disclosure to related parties. We may disclose or share your personal data with our ZujuGP affiliates in order to provide our services to you and for management and compliance purposes.

7.2 Disclosure to third parties. We may also disclose your personal data to third parties in connection with purposes described in Section 5, including without limitation the following circumstances:

  • disclosing your personal data to third parties who provide services to us (including, but not limited to, data providers, technology providers, insurance providers, financial institutions, credit card payment processors and professional service providers (including accountants, lawyers and auditors));

  • disclosing your personal data to third parties in order to fulfil such third party products and/or services as may be requested or directed by you;

  • disclosing your personal data to third parties that we conduct joint marketing and cross promotions with;

  • disclosing your personal data to regulatory authorities, governments, law enforcement agencies or public agencies;

  • If we are discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;

  • If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you; and

  • If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

 

7.3 When disclosing personal data to third parties, we will (where appropriate and permissible) enter into contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws and/or ensure that they only process your personal data in accordance with our instructions.

8. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES

 8.1 Transfers We may transfer your personal data to different jurisdictions in connection with the purposes described in Section 5:

  • from the jurisdiction where it is collected (or where you are located) to any other jurisdictions that we operate in; and

  • to third parties in other jurisdictions.

8.2 Safeguards. Where we transfer your personal data across jurisdictions, we will ensure that your personal data is protected in accordance with this Policy and applicable laws regardless of the jurisdictions they are transferred to, but in any event to a level that is no less stringent than the jurisdiction from which the personal data is transferred. When we transfer your personal data internationally and where required by applicable law we put in place appropriate safeguards including EU Model Clauses or rely on EU Commission adequacy decisions. You may obtain details of these safeguards by contacting us.

9. SECURITY AND RETENTION OF PERSONAL DATA

  • Unauthorised access. While we take reasonable precautions to safeguard your personal data in our possession or under our control, you agree not to hold us liable or responsible for any loss or damage resulting from unauthorised or unintended access that is beyond our control, such as hacking or cybercrimes.

  • Vulnerabilities. We do not make any warranty, guarantee, or representation that our systems and your use of our Applications are safe and protected from malware and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk.

  • Period of retention. We retain your personal data only for as long as is necessary to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including data analytics, audit, accounting or reporting purposes. How long we keep your personal data depends on the nature of the data, e.g. we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Some information may also be retained for longer, e.g. where we are required to do so by law in the relevant jurisdiction.

  • Anonymised data. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.

10. YOUR RIGHTS

10.1 Rights you may enjoy. Depending on the jurisdiction that you are in or where we operate, you may enjoy certain rights under applicable law in relation to our collection, use, disclosure and processing of your personal data. Such rights include:

  • Access: you may ask us if we hold your personal data and, if we do, you may request access to your personal data. This enables you to receive a copy of and information on the personal data we hold about you.

  • Correction: you may request that any incomplete or inaccurate personal data we hold about you is corrected.

  • Erasure: you may ask us to delete or remove personal data that we hold about you in certain circumstances.

  • Restriction: you may withdraw consent for our use of your personal data, or ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy.

  • Portability: you may request the transfer of certain of your personal data to another party under certain conditions.

  • Objection: where we are processing your personal data based on a legitimate interest (or those of a third party) you may object to processing on this ground.

If you wish to exercise your rights, you may contact us to in accordance with Section 11.1 below. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request.

10.2 Limitations We may be permitted under applicable laws to refuse a request. For example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.

 

11. CONTACT US

11.1 Contact Data Protection Officer. If you have any feedback or issues in relation to your personal data, or about this Policy, or wish to make a complaint to us, you may contact our Data Protection Officer at :

Email    :           support@zujugp.com

This does not affected your statutory rights. For example, if the GDPR applies to you, you may also have a right to lodge a complaint with a European supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where you work or where an alleged infringement of Data Protection law has taken place.

When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond.

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