ZA-HA ("ZA-HA") is committed to protecting the privacy of visitors to our website, http://www.za-ha.com/ (the "Website"). In this Privacy Policy, we explain how we protect your personal information and what happens to it when you visit the site. This Privacy Policy also provides the necessary information so that you may consent to the processing of your personal information explicitly and with full knowledge of the circumstances.

ZA-HA processes all information and data you provide through the Website or otherwise collected by ZA-HA in connection with the use of the services ("Services") described in Section 3 below. This is done in accordance with legal requirements and in an appropriate and transparent manner. As explained below, ZA-HA relies on internationally accepted principles for the processing of personal data, such as purpose limitation, storage restriction, data minimization, data quality, and confidentiality.

Contents

• Data Controller and Data Protection Officer

• Processed Personal Data

  • A. Name, Contact Details, and Other Personal Data

  • B. Job Applications

  • C. Special Categories of Personal Data

  • D. Personal Data of Other Persons

  • E. Browser Data

  • F. Cookies

• Purposes of Data Processing

• Reasons for Processing and Mandatory or Optional Processing

• Recipients of Personal Data

• Transfer of Personal Data

• Retention of Personal Data

• Rights of Data Subjects

• Amendments

1. Data Controller and Data Protection Officer

ZA-HA is the Data Controller in connection with the processing of all personal data via the Website.

If you would like to contact the ZA-HA Data Protection Office, you can do so here: http://www.za-ha.com/.

2. Personal Information Processed

When you use the Website, ZA-HA collects and processes data relating to you (as a person) that identifies you, either alone or together with other information already collected. ZA-HA may also collect and process data about others when you provide it.

This information is referred to as "Personal Information" and may be collected by ZA-HA if you provide it voluntarily (e.g., by subscribing to the newsletter or using ZA-HA services) or simply by analyzing your behavior on the Website.

A. Name, Contact Details, and Other Personal Data

In various areas of the Website—especially when you create an account—you may be asked to provide information such as your name, phone number, email address, date of birth, country of residence, and address. If you register for certain services, you may also be asked for your preferred method of payment (e.g., PayPal, bank transfer, or credit card).

In addition, if you participate in surveys or promotions on the Website, or if you communicate with ZA-HA through the contact information provided, you may be required to provide additional information.

B. Job Applications

If you apply for a job on the Website, you will be asked to provide personal information such as your CV, cover letter, professional qualifications, desired job, and availability. This information will be processed in accordance with the Privacy Policy published on the job application page.

C. Special Categories of Personal Data

Certain areas of the Website (e.g., free text fields) allow you to provide information or requests. These fields may inadvertently or intentionally include sensitive personal data, such as ethnicity, political opinions, religious beliefs, or health information.

ZA-HA asks that you do not disclose sensitive personal data unless absolutely necessary. If you choose to provide such information, ZA-HA requires your explicit consent to process it.

D. Personal Data of Other Persons

If you provide personal data about others (e.g., through free text fields), you are responsible for ensuring you have their consent or a valid legal basis to share this information.

E. Browser Data

The operation of the Website involves the use of computer systems and software that collect information about users as part of routine operations. This data includes IP addresses, location, domain names, and other technical details. While this data is not collected to identify users, it may still be considered personal data.

F. Cookies

For more detailed information on the use of cookies, see the Cookie Policy.

3. Purposes of Data Processing

ZA-HA processes your personal information for the following purposes:

• To confirm your identity and assist with account access (e.g., password recovery).

• To send you information you requested (e.g., newsletters or session invitations).

• For marketing and promotional purposes, including direct marketing, surveys, and market research.

• To create a user profile based on your activity on the Website and provide personalized content.

• To comply with legal obligations.

• To prevent and detect misuse or fraudulent activity on the Website.

4. Reasons for Processing and Mandatory/Optional Processing

The legal basis for processing your personal data depends on the purpose:

• Service Provision: Necessary to fulfill a contract with you.

• Marketing: Based on your consent, which can be withdrawn at any time.

• Soft Spam: ZA-HA may send you emails about similar products unless you opt out.

• Profiling: Based on your consent, obtained via cookies or checkboxes.

• Legal Compliance: Required to fulfill legal obligations.

• Misuse/Fraud: Necessary to prevent fraudulent activity.

5. Recipients of Personal Data

Your personal data may be shared with:

• Service providers (e.g., hosting or email platforms).

• ZA-HA employees or contractors authorized to process data.

• Public authorities, if required by law.

6. Transfer of Personal Data

Given ZA-HA’s global presence, your data may be transferred internationally. ZA-HA ensures appropriate safeguards are in place for such transfers.

7. Retention of Personal Data

ZA-HA retains personal data only as long as necessary for the purposes outlined:

• Service Provision: Retained for the duration of the service.

• Marketing/Profiling: Retained until consent is withdrawn.

• Legal Compliance: Retained as required by law.

• Misuse/Fraud: Retained as long as necessary to prevent fraudulent activity.

8. Rights of Data Subjects

You have the right to:

• Access, correct, or update your personal data.

• Request deletion or restriction of your data.

• Object to processing or withdraw consent.

• File a complaint with the relevant data protection authority.

To exercise your rights, contact ZA-HA at privacy@za-ha.com.

9. Amendments

This Privacy Policy is effective as of April 16, 2018. ZA-HA reserves the right to amend this policy to reflect changes in legislation or business practices. Updates will be published on the Website.