Privacy Policy

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

In principle, ZA-HA processes all information and data you provide to ZA-HA through the Website or otherwise collected by ZA-HA through the Website in connection with the use of the Services (" Services") described in more detail in Section 3 below, in accordance with the Terms of Use legal requirements and in an appropriate and transparent manner. In doing so, as explained below, ZA-HA relies on internationally accepted principles for the processing of personal data such as limitation of purpose, restriction of storage, minimization of data volume, data quality and confidentiality.

CONTENT

1. Data controller and data protection officer

2. 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

3. Purposes of data processing

4. Reasons for the processing as well as mandatory or exempted processing

5. Recipient of personal data

6. Forwarding of personal data

7. Storage of personal data

8. Rights of data subjects

9. amendments

1. Data Controller and Data Protection

Officer ZA-HA (see the beginning of the Privacy Policy) 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 that has already been collected. ZA-HA can also collect and process data about others when you provide these ZA-HA.

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

Personal data that ZA-HA may process through the Website are:

A. Name, contact details and other personal information

In various areas of the Website - especially when you create an account on the Website - you are asked to provide information such as name, telephone / mobile number, email address, date of birth, country of residence, address, etc to indicate. If you register for certain services, you may also be asked for your preferred method of payment - PayPal, bank transfer, or credit card.

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

B. Job applications

If you register to apply for a job on the website, you will be asked to provide a variety of personal information, such as employment information ( eg CV, cover letter, professional qualifications, expectations and desired job, earliest possible entry, URLs etc.). The personal information you provide for this purpose will be processed by ZA-HA in accordance with the Privacy Policy published there.

C. Special categories of personal information

In certain areas of the website (such as the invitation request form), there are free text fields that you can use to provide ZA-HA with information or requests. Here also personal data can be entered.

As far as these text boxes are editable without any prescriptions, you could also (by mistake or intentionally) enter more sensitive personal information, such as data that allows for inferences about ethnicity, political opinions, religious or philosophical beliefs, or membership in a union. The content you upload through these text boxes may also (by mistake or intentionally) contain sensitive information about you, such as genetic data, biometric data, or health, sexual or sexual orientation information.

ZA-HA, please do not disclose any such sensitive personal information on the website, unless you deem it absolutely necessary. Because passing on such information is purely optional, please always keep in mind that ZA-HA needs your explicit permission to process this type of personal information. ZA-HA therefore urges you to give your explicit permission to process this type of personal information if you decide to divulge it.

D. Other people's personal information

As discussed in the previous section, you will find free text boxes in certain areas of the site where you can post messages to ZA-HA. These communications may (by mistake or intentionally) contain other persons' personal information.

If you choose to share personal information with others, you are the independent data controller of that personal information and assume all the associated legal responsibilities and responsibilities. This implies, among other things, that you must fully indemnify ZA-HA for any complaints, claims or claims for damages resulting from the processing of such personal data by third parties whose personal data you have provided through the Website.

Because ZA-HA does not collect this type of data directly from others (but collects it indirectly from you), you must obtain permission from these individuals before you share information about them with ZA-HA. If you fail to do so, you must otherwise ensure that there are other reasonable grounds why you have the right to share this information with ZA-HA.

E. Browser data

The operation of the website, as with all websites on the Internet, involves the use of computer systems and software that collects information about the users of the website as part of routine operation. While ZA-HA does not collect this information in order to associate you with certain users, it is still possible to identify those users either directly through this information or through other collected data. For this reason, these data should also be considered as personal data.

These data include, for example, various characteristics of your operating system and your IT environment such as IP address, location (country), the domain name of your computer, the URI addresses (Uniform Resource Identifier) of the resources you visit the website request time, such time requirements, type of request to the server, extent of the file received upon request, the numeric code to the status of the response of the server (successful, errors, etc.) and so on.

These data are used to compile statistical information about the use of the website, to ensure correct operation and to detect errors and / or misuse of the website. Except for the latter purpose, this data will not be stored for more than 7 working days.

F. Cookies For

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

3. Purposes of Data Processing

ZA-HA intends to use your personal information collected through the Website for the following purposes:

To confirm your identity and to assist you if you have lost or forgotten username and / or password for any of ZA-HA's services by logging in; so we can send you the ZA-HA information, if you've subscribed to it, to send you information that you specifically requested; or so that you can request a session invitation.

products

For future marketing or promotional purposes, such as direct marketing, market research and surveys via e-mail, SMS or telephone, banners, instant messaging, via an operator, traditional mails, through the ZA-HA social media pages related to ZA-HA products and services or to the selected third party (" Marketing ").

For future marketing or promotional purposes directly through marketing emails to you about products and services similar to those you have already purchased or requested on the Site (" Soft Spam ").

To create a user profile for you as a website user about the use of cookies and to collect and analyze information about the selection of pages and information you have made on the website and about your general activities on the website. This profile will then be used to provide you with information about other websites / services that you think we may be interested in and to show you information and advertising that may be of interest to you. The algorithms used in this processing are regularly reviewed to ensure fair and unbiased processing (" profiling ").

To comply with legal requirements that require ZA-HA to collect and / or further process certain types of personal data (" Legislative Compliance ").

To prevent and detect misuse of the Website or fraudulent activity that occurs through the Website (" misuse / fraud ").

4. Reasons for processing and mandatory / optional processing

The legal basis for the processing of your personal data by ZA-HA for the purposes stated in Section 3 are as follows:

Provision of services : Processing is essential for these purposes in order to provide the services and thus to be able to fulfill a contract with you. You are therefore required to provide ZA-HA with your personal information for these purposes. If you do not, ZA-HA will not be able to provide services for you.

Marketing : Processing for this purpose may only be done with your permission. You are under no obligation to give ZA-HA this permission, and it will not affect you if you do not (except that you will not receive any further marketing information from ZA-HA). Any granted approval may be withdrawn at any time ( see Section 8 ).

Soft Spam : Processing for this purpose occurs because ZA-HA would like to send you, by email, information about products and services similar to those you have already purchased or requested on the Site. You may block these emails and it will have no effect on you (except that you will no longer receive such emails from ZA-HA) if you do so by disagreeing with the link provided below in the emails.

Profiling : Processing for this purpose is subject to your approval, which is obtained through the banner cookie and / or a special check box. You are not required to give ZA-HA permission to use your personal information, and it will not affect you if you do not (except that you will not be able to benefit from the increased personalization of your website experience). Any granted approval may be withdrawn at any time ( see Section 8 ).

Legal compliance : Processing for this purpose is necessary for ZA-HA to fulfill its legal obligations. If you provide ZA-HA with personal information, ZA-HA must process it in accordance with applicable laws, for example, by storing and transferring personal information to authorities for taxation, customs, or other regulatory purposes.

Abuse / Fraud : Information collected for this purpose will only be used to prevent and detect fraudulent activity or misuse of the Website (for potentially criminal purposes).

5. Recipient of personal data

Your personal data may be forwarded to the following persons or groups of persons / organizations (" recipients "):

Individuals, companies or law firms who assist and advise ZA-HA on accounting, administration, legal issues, tax matters, finance and debt collection related to the Services, and who normally act as ZA-HA contract data processors;

Companies engaged in the provision of the services (for example, hosting providers or e-mail providers);

Persons authorized to perform technical maintenance (such as maintenance of network equipment or electronic communications networks);

Persons instructed by ZA-HA to process personal data strictly necessary for activities related to the provision of the Services and who have undertaken to maintain secrecy or are subject to such obligation by law (such as ZA-HA employees);

Other companies of the ZA-HA Group for internal administrative purposes, such as the management of personal customer or employee data and

Public organizations or authorities to which Personal Information may be transferred in accordance with applicable laws or regulations of such organizations or authorities.

6. Transfer of Personal Information

Given ZA-HA's global presence and business, your personal information may be shared with recipients in different countries. ZA-HA therefore uses appropriate security measures to ensure that the personal data is transmitted legally and securely. For example, we base our decisions on these matters, as well as the usual privacy clauses of the European Commission or other security measures and terms that are considered appropriate for the relevant transfer. You can request further information by contacting us on our website.

7. Retention of personal data

Personal data processed for the purpose of providing services will only be retained by ZA-HA for as long as absolutely necessary for these purposes - but this may be a longer period of time, if necessary, for ZA-HA's interests a possible liability in connection with such provision of services.

Personal data used for marketing or profiling will be held by ZA-HA from the date on which you have given your approval to the date on which you revoke the granted and periodically renewed license. Once the authorization is revoked, the personal data will no longer be used for such purposes, but may continue to be retained by ZA-HA, in particular to the extent necessary to protect ZA-HA's interests with regard to potential liability in connection with such processing.

Personal data processed for the purpose of soft spam will be retained until such time as you refuse such processing using the link provided at the end of these emails.

Personal data processed for legal compliance purposes will be retained by ZA-HA for the period specified by applicable law or applicable law.

Personal data processed to prevent abuse / fraud will be retained by ZA-HA for as long as absolutely necessary to fulfill its purpose.

8. Rights of the persons concerned

As a data subject, you have the following rights at any time to ZA-HA:

You may access your personal data (or a copy thereof) processed by ZA-HA and information about its processing;

You may correct or update your personal information processed by ZA-HA if it is inaccurate or incomplete;

You may request the deletion of your personal data processed by ZA-HA if you find the processing unnecessary or otherwise unlawful;

You may request a restriction on the processing of your personal data if you believe that it has been processed in an inappropriate, unnecessary or unlawful manner or if you have objected to the processing;

You may exercise your transferability rights, including the right to receive from ZA-HA a copy of your personal information in a structured, common, machine-readable format and the right to have your personal information sent to another data controller;

The processing of your personal data for reasons of your particular situation, which you consider to be contrary to processing by ZA-HA, contradicts or

Revoke your consent to processing ( marketing and profiling ).

Please note that most of the personal information that you provide to ZA-HA, for example, your email preferences, can be changed at any time by accessing the user profile (if any) that you can create on the website.

When requesting services, you may have determined the medium for marketing communication (fax, telephone, SMS, e-mail, post, social media). You can do that for marketing Remove approval granted from the user profile (if available) using different communication paths by deactivating the selected options. You may also revoke the approval granted for marketing via email or reject soft spam by clicking on the link provided at the end of each email. The same applies to the ZA-HA newsletter that you receive as a service.

The consent to profiling through cookies may be revoked as described in Section 2.f or, if issued on check box by changing the preferences in your user profile that you can create on the site.

You may also exercise your above rights in writing at any time by sending an e-mail to privacy@http://www.za-ha.com/.

We also point out that, as the data subject, you are always entitled to complain to the Inspectorate responsible for the protection of your personal data if you believe that the processing of your personal data via the Website is not lawful.

9. Changes

This Privacy Policy entered into force on April 16, 2018. ZA-HA reserves the right to change this Privacy Policy in whole or in part or to adapt its content to any changes in relevant legislation. ZA-HA will promptly notify you of such changes and they are binding upon publication on the Site. ZA-HA recommends that you regularly consult the privacy policy to view the most up-to-date version so that you are always aware of how ZA-HA collects and uses personal information.

Website Privacy Policy

ZA-HA, with registered offices at (" ZA-HA "), is committed to protecting the privacy of users of the websites http://www.za-ha.com/ (the " Website "). ZA-HA's policy regarding your privacy, as well as your personal information will be handled when using the website. This Privacy Policy therefore seeks to provide you with information that will allow you to understand the personal information in an explicit and informed manner.

In general, any information or data provided by ZA-HA on the website or in the context of the use of ZA-HA's services (" Services ") as better defined in the Section 3 below, wants to be processed by ZA-HA in a lawful, fair and transparent manner. ZA-HA takes into consideration the principles of international law.

CONTENTS

1. Data controller and Data Protection Officer

2. Personal Data processed

A. Name, contact details and other Personal Data

B. Job applications

C. Special categories of Personal Data

D. Other persons' personal data

E. Browsing data

F. cookies

3. Purposes of processing

4. Grounds for processing and mandatory or discretionary nature of processing

5. Recipients of Personal Data

6. Transfer of Personal Data

7. Retention of Personal Data

8. Data subjects' rights

9, Amendments

1. Data Controller and Data Protection Officer

ZA-HA, as identified at the top of this Privacy Policy, is the data controller for the website.

To get in touch with ZA-HA's Data Protection Officer, please contact: admin http://www.za-ha.com/

2. Personal Data processed

When you use the Web site, ZA-HA wants to collect and process information about you (as an individual) which allows you to collect it yourself. ZA-HA may therefore be able to collect and process information about other persons in this same manner, if you choose to provide it to ZA-HA. ZA-HA's Services or simply by analyzing your personal information may be considered as " Personal Data " or "ZA-HA's Services" Behavior on the website.

Personal Data which can be processed by ZA-HA through the website are as follows:

A. Name, contact details and other Personal Data

In various sections of the Website - including, in particular, if you decide to create an account on the Website - you want to submit information as your name, phone / mobile numbers, e- mail address, date of birth, country of residence and address etc. When subscribing to or signing up for services, you may be asked to provide PayPal or bank transfer or credit card.

In addition, whenever you participate in surveys and other promotions which may be available on the Website, as well as whenever you communicate with ZA-HA through the contact details provided in the Website or with Customer Service, ZA-HA may collect additional information which you choose to provide ,

B. Job applications

When registering to apply for a position at ZA-HA on the website, you are also asked to provide various types of Personal Data, including professional / employment details (eg. resume, cover letter, professional qualifications, candidate's expectations and wished workplace, availability to start, URLs, etc.). The personal data that you wish to use will be processed by ZA-HA.

C. Special categories of personal data

Certain areas of the website (: such as the form to request a an invitation) include free text fields where you can Provide ZA-HA with some information or needs, Which you may use to communicate personal data.

These areas are completely free, you may use them to disclose (inadvertently or not) more sensitive categories of personal data, search as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also include inappropriate or disparate information about you, as well as other types of sensitive information relating to you, as well as your genetic data, biometric data or data regarding your health, sex life or sexual orientation.

ZA-HA asks that you do not disclose any sensitive Personal Data on the Website unless you consider this to be strictly necessary. ZA-HA needs your consent to process on a sort of personal data basis. ZA-HA would like to share your personal information with you.

D. Other Personnel Personal Data

As mentioned in the previous section, certain areas of the website include free text fields where you can write messages to ZA-HA. These messages may (inadvertently or not) include Personal Data related to other persons.

Personal data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify ZA-HA against any complaints, which may arise from the processing of this Personal Data, brought by the third parties.

As ZA-HA ZA-HA does not collect this information directly from these third parties (but rather collects them, you, from you), you must make sure that you have obtained your consent. ZA-HA this information.

E. Browsing data

The site's operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collects information about the website's users as part of their routine operations. While ZA-HA does not collect this information, it is not possible to identify it directly or by any means.

This information includes various parameters related to your IT system, including your IP address, location (country), the domain name of your computer, the URI (Uniform Resource Identifier) requests made, the methods used to submit requests to the server, the measures received in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on ,

These data are used to compile statistical information on the website, as well as to ensure its correct operation and / or abuse of the website. Save from this last purpose, these data do not persist for more than 7 working days.

F. Cookies

Relevant information on cookies are available in the Cookie Policy.

3. Purposes of processing

ZA-HA intends to use your Personal Data, collected through the Website, for the following purposes:

ZA-HA newsletter subscription Subscribe to ZA-HA's registration services, to register your identity, to subscribe to ZA-HA's registration services as a service and which contains only informational material, to send you any information; and provide any other services which you may request;

For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via email, sms, over the phone, instant messaging, through operator, traditional mail, through ZA-HA's official social media pages, concerning ZA-HA's products and services, as well as those of selected third parties (" Marketing ");

For future marketing, promotional and publicity purposes, by sending you direct mail marketing communication Regarding products and services similar to Those you have purchased or requested through the use of the website ( " Soft spam ");

To create a profile of the site as a website user, through the use of cookies and by collecting and analyzing information on the website. ZA-HA believes that you may be interested in, and that you may be interested in, and that you are interested in. All algorithms involved in this processing are regularly tested, to ensure the processing of the fairness and control for bias (" profiling ");

For compliance with laws which impose upon ZA-HA the collection and / or further processing of certain types of Personal Data (" Compliance ");

To prevent or detect any misuse of the website, or any fraudulent activity carried out through the website (" misuse / fraud ").

4. Grounds for processing and mandatory / discretionary nature of processing

ZA-HA's legal bases for processing your personal data, according to the purposes Identified in Section 3 , are as follows:

Service Provision : Processing for these purposes is necessary to provide the services and, therefore, is necessary for the performance of a contract with you. ZA-HA your Personal Data for these purposes; however, if you do not, ZA-HA does not want to provide any services to you.

Marketing : processing for these purposes is based on your consent. ZA-HA is using your personal data for the purposes of this application, and you do not want to give it back. Any consent given may be withdrawn at a later stage (please see Section 8 for more information).

Soft Spam : ZA-HA of sending you direct e-mail marketing the products and services that you are using. You can block these communications, and you will not receive any further communications from the ZA-HA, by opposing them.

Profiling : processing for this purpose is done by means of the banner cookie and / or with a specific tickbox. It is not necessary for you to give consent to your Personal Data for this purpose ). Any consent given may be withdrawn at a later stage (please see Section 8 for more information).

Compliance : ZA-HA to comply with its legal obligations. When you provide any Personal Data to ZA-HA, ZA-HA must process it in accordance with the applicable law, which may include your personal data.

Misuse / Fraud : Information collected for the purpose of preventing or detecting fraudulent activities or misuse of the website (for potentially criminal purposes).

5 . Recipients of Personal Data

Your Personal Data may be shared with the following list of persons / entities (" Recipients "):

Persons, companies or professional firms providing ZA-HA with advice and consultation regarding accounting, administrative, legal, tax, financial and debt collection.

Entities engaged in order to provide the services (eg, hosting providers or e-mail platform providers);

Persons authorized to perform technical maintenance (including maintenance of network equipment and electronic communications networks);

Persons authorized by ZA-HA to process Personal Data needed to carry out activities strictly related to the provision of the services, who have an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (eg, employees of ZA-HA);

Other companies within the ZA-HA Group for internal administrative purposes, including the processing of clients 'or employees' personal data; and

Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;

Transfer of Personal Data

Considering ZA-HA's worldwide presence and business operations, your personal data may be transferred to several different countries. ZA-HA implements appropriate safeguards to ensure the lawfulness and security of personal data transfers, as well as by relying on adequacy of the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand , ZA-HA.

7. Retention of Personal Data

Personal Data Processed for Service Provision ZA-HA for the period strictly necessary for fulfillment purposes - in any case, as the Personal Data are processed for the provision of the Services, ZA-HA may continue to store this Personal ZA-HA's interests are related to the provision of services.

Personal Data processed for Marketing and Profiling will be kept by ZA-HA from the moment you give consent until the moment you withdraw your consent. Once consent is withdrawn, Personal Data will no longer be used for these purposes.

Personal Data processed for Soft Spam wants to be kept up to date at the bottom of all such communications.

Personal Data processed for compliance by ZA-HA for the period required by the specific legal obligation or by the applicable law.

Personal Data processed

Misuse / Fraud wants to be kept by ZA-HA for as long as it is strictly necessary to fulfill the purposes for which it was collected.

8. Data subjects' rights

Under the Regulation, you are entitled to exercise ZA-HA, at any time:

Access your Personal Data processed by ZA-HA, as well as information on the processing of your Personal Data;

Correct or update your Personal Data processed by ZA-HA, where it may be inaccurate or incomplete;

Request erasure of your Personal Data processed by ZA-HA, where you feel that the processing is unnecessary or otherwise unlawful;

Request the restriction of the processing of your personal data, where the personal data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;

Personal Data provided to ZA-HA, in a structured, commonly used and machine-readable format, as well as the transmission of personal data to another data controller;

ZA-HA from processing your Personal Data; Object to the processing of your Personal Data; or

Withdraw your consent to processing (for marketing and profiling ).

Please note that most of the personal data you provide can be changed at any time, including your e-mail preferences, by accessing, where applicable, the user profile you can create on the website.

When requesting for the services, you may have selected the means of communication through which you desired the marketing to be carried out ( ie fax, phone, sms , email, mail, social media). You may withdraw the consents for the marketing through the different means of communication from the user profile, where applicable, by de-selecting the relevant options. So you can withdraw consent for Marketing via e-mail or object to Soft Spam by selecting the appropriate link included at the bottom of every e-mail message received. The same applies to the ZA-HA newsletter.

Consent for Profiling via cookies may be withdrawn as described in Section 2.f or, via via tick box, by changing, at any time, the preferences of the user profile you can create on the website.

In any case, you are entitled to file a complaint with the appropriate authorities for the protection of personal data, if you believe that the personal data is carried out through the website is unlawful.

9. Amendments

This Privacy Policy entered into force on 04/01/2019. ZA-HA reserves the right to either partially or completely amend this Privacy Policy, or as it may, as a result of changes in applicable law. ZA-HA wants inform you of such changes as soon as they are introduced and they are published on the website. ZA-HA collects and uses Personal Data. ZA-HA collects and uses Personal Data.

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