This Policy applies to the parent organization Zorka Mobi Ltd, a company incorporated in Limassol, Cyprus with its registered office at: Arch. Makariou III, 155, PROTEAS HOUSE, 2nd floor, Flat/Office 202, 3026, Limassol, Cyprus, as well as its subsidiaries (including partially owned companies in which Zorka Mobi Ltd directly or indirectly controls more than 50% of voting shares) hereinafter, "Zorka Mobi" or “We”.
Zorka Mobi Ltd handles the processing and storage of personal data within the EU and can at any time confirm compliance with EU legislation, as well as the principles set forth in this Regulation.
The Regulations explain what types of customer information we collect online, and how we use this information.
Our Platform is managed in accordance with the General Data Protection Regulation (GDPR), (Regulation (EC) 2016/679), which is binding on the implementation of the legislative act. The GDPR introduces a number of new rules for individuals and reinforces some of the rights enshrined in Directive 95/46 / EC. Directive 95/46/EC will enter into force on May 25, 2018. This Regulation is drawn up in accordance with the requirements of the GDPR and, thus, complies with Directive 95/46 / EC and issued for the purpose of its execution to national acts, until it expires on May 25, 2018
Zorka Mobi Ltd is responsible for managing the data, as well as determining the purposes and methods of processing personal data provided and collected online.
- Zorka Mobi Ltd's data protection policy is based on the following principles:
- Processing of personal data must be carried out in a lawful, conscientious and transparent manner;
- The collection of personal data must be carried out only for established, unambiguous and legitimate purposes and does not provide for additional processing of data incompatible with these purposes;
- The collection of personal data must be appropriate, appropriate and limited to information that is necessary for the purposes in which these data are collected;
- Personal data must be accurate and updated if necessary;
- All reasonable measures must be taken to ensure that inaccurate personal data, depending on the purpose of their processing, will be immediately deleted or corrected;
- Personal data must be stored in such a way that the data subject can be identified no longer than is required to achieve the purposes in which the data was collected;
- All personal data must be stored in such a way as to ensure their confidentiality and safety;
- Personal data should not be transferred to third parties, except when necessary to provide services on the basis of the contract;
- Data subjects should have the right to access personal data, to modify or delete data, to limit processing, to object to it, and to transfer data.
1. Personal data
Personal data means any information that can be attributed to an identified or identifiable individual ("data subject"). Personal data includes all types of information that can be directly or indirectly (ie, using other data) correlated with the data subject, such as name, date of birth, address, email address, phone number, etc.
Transfer of personal data
Personal data is not transferred to third parties, except in circumstances where such transfer is necessary to provide our services. From time to time, we delegate authority to act on our behalf to other companies and our business partners: for example, independent attorneys to apply for compensation or technology companies to process or provide systems and technologies that extend our products and services. In such cases, we give them the necessary information. Service providers only receive the personal data they require to provide services. We do not disclose personal data to third parties in order to enable them to advertise their products and services to our customers. If you do not want your data to be transferred to these companies, contact the legal department at the email address: email@example.com.
2. Your Acceptance
This Policy describes our privacy practices – which information we collect on our visitors and users, how we collect it, what we do with it, how we protect it, and your rights regarding your information.
Please note: you are not obligated by law to provide us with any information. You hereby acknowledge, warrant and agree that any information you do provide us is provided of your own free will and consent, for the purposes and uses described herein.
3. What Information Do We Collect?
When you visit or use our services – you may also provide us with certain information (either automatically through your uses, or by manually submitting it).
4. How Do We Collect Such Information?
We collect such Non-personal and Personal Information for the following purposes:
- To provide and operate the Services;
- To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
- To provide our Users with ongoing customer assistance and technical support;
- To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages (as further detailed below);
- To proof, sponsor and offer certain contests, events and promotions, determine participants’ eligibility, monitor performance, contact winners and grant prizes and benefits;
- To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
- To enhance our data security and fraud prevention capabilities;
- To consider Applicants’ candidacy for working at ZORKA.MOBI (as further detailed in Sections below);
- To comply with any applicable laws and regulations.
5. Where Do We Store Your Information?
We may store and process Personal Information subject to this policy all over in the Worldwide.
ZORKA.MOBI’s data storage providers are committed to protect and secure your data.
ZORKA.MOBI may collect, store and process certain Non-personal and Personal Information of partners and theirs users, solely on our Users’ behalf and at their direction.
For example, each of our Users is able to import their e-mail contacts from third party services like Gmail, or otherwise collect and manage contacts via their User Website.
These contacts are stored at ZORKA.MOBI, on behalf of the User.
For such purposes, ZORKA.MOBI serves and shall be considered as a “Data Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Data Protection Directive) of such all Information.
The Users of our services (participants) controlling and operating such User Websites shall be considered as the “Controllers” of such Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of- Participants Information, including all privacy and data protection laws of all relevant jurisdictions.
Participants are responsible for the security, integrity and authorized usage of your Users-of-Users’ Personal Information, and for obtaining any consents and permissions required for the collection and usage of such information.
ZORKA.MOBI cannot provide legal advice to all Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites, in accordance with the applicable laws and regulations, and that all Users-of participants carefully read those policies and make sure that they consent to them.
If you are a Visitor, User or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly.
For example, if you wish to access, correct, amend, or delete inaccurate information processed by ZORKA.MOBI on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data).
If requested to remove any Users Personal Information, we will respond to such request within thirty (30) days.
Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section below.
Sharing Personal Information with Third Parties
We may share the information of our visitors, users and their users-of-users with various third parties, including certain service providers, law enforcement officials and application developers.
The information may be shared solely in accordance with this policy.
ZORKA.MOBI, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, all our Users with a better experience.
For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
6. Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not own by ZORKA.MOBI, and we therefore cannot ensure its accuracy, completeness or availability).
Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Clear Gifs: We and certain Third Party Services may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however unlike cookies these are not stored on your device, but are instead embedded within our Services.
Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies. Additional information about managing Flash cookies is available here.
(note that this website is not provided by ZORKA.MOBI, and we therefore cannot ensure its accuracy, completeness or availability).
Certain Third Party Services and ad networks may display advertising on our Platform, on ZORKA.MOBI mobile apps, or manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third party Services to provide you with targeted advertising based on your interests and preferences.
User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.
If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.“Do Not Track” Signals:
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.
By subscribing to any Services (including to any of our newsletters, blogs, social media accounts or public events) and providing ZORKA.MOBI with your e-mail address or any other contact information (such as your phone number or social media handle), you expressly agree to receive promotional content, messages or calls from ZORKA.MOBI or our partners (acting on ZORKA.MOBI’s behalf) through such means.
Accordingly, ZORKA.MOBI and its partners shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, marketing calls and similar forms of communication. If you wish not to receive such promotional messages or calls, you may notify ZORKA.MOBI at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
8. Accessing Your Personal Information
You may request to access or correct the personal information you have stored with us, by sending us an e-mail. You may also correct, update or remove certain information, or deactivate your account, through your account or website settings.
We will respond to your request within 30 (thirty) calendar days.
We may retain your Personal Information (as well as your all Users Information) for as long as your User Account is active or as otherwise needed to provide you with our Services.
We may continue to retain such Personal Information even after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
9. Data Retention
We may keep your information for as long as your account is active, and longer as needed (for example, if we are legally obligated to keep it further, or need it to protect our interests).
ZORKA.MOBI has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
However – regardless of the measures and efforts taken by ZORKA.MOBI, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Information or any other User Content you upload, publish or otherwise share with ZORKA.MOBI or anyone else in case of your inappropriate saving of the passwords or setting weak passwords for User Account.
We therefore encourage you to set strong passwords for your User Account, and avoid providing us with any sensitive information which you believe its disclosure could cause you substantial or irreparable harm. Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
11. We collect two types of information regarding our Visitors and Users:
11.1. Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, etc.
11.2. Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”).
The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third-party accounts (such as the e-mail or username for a connected YouTube Channel, Instagram account and their links), correspondences on the Platform, and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services.
For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.
11.3. All Users Information
We may also collect similar information pertaining to visitors and users of our User’s Websites or Services, solely for and on our Users’ behalf.
11.4. ZORKA.MOBI Jobs Applicant Information
ZORKA.MOBI may collect and process information regarding the users of our Partners. We do this solely on our users’ behalf, and at their direction. Our users and Partners are solely responsible for their users-of-users information, including for its legality, security and integrity.
ZORKA.MOBI has no direct relationship with any of its partners’ users. If you are a user-of-partner, please contact such user directly.
Some jurisdictions require us to maintain and store their residents’ information locally. We may also collect, process, store and use such information elsewhere.
12. Third Party Services:
ZORKA.MOBI has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”).
Such Third Party Services may receive or otherwise have access to our Visitors’ and all Users, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business.
ZORKA.MOBI is accountable for personal data that it receives under the Privacy Shield and subsequently transfers to a third party as described in the Privacy Shield Principles. In particular, ZORKA.MOBI remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless ZORKA.MOBI proves that it is not responsible for the event giving rise to the damage.
13. Law Enforcement, Legal Requests and Duties:
ZORKA.MOBI may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
14. Protecting Rights and Safety:
ZORKA.MOBI may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of ZORKA.MOBI, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
Our Services include certain Social Media features and widgets of YouTube and Instagram such as the “Instagram Like” button, the “YouTube Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties are governed by their policies and not ours.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.
15. Social Media Features and Framed Pages:
As part of our Zorka.Market program, we allow third party developers (“Third Party Partners(s)”) to develop and offer their own projects via the ZORKA.MOBI.
16.1. Mobile application (App):
By installing certain ZORKA.MOBI Apps/or Third Party Apps, you also allow their respective provider to share and/or access certain Non-personal and Personal Information.
Such information includes, among others, contact details, messages, business applications and certain activities on the Services and/or User Website, which are stored and thereafter accessible via your User Account.
In order to further protect all Users privacy, we contractually prohibit all Third Party Developers from combining Personal Information collected across different User Websites and Services, and from sharing Users Personal Information other than with other Apps installed on the same User Website or Services, for the purposes of such specific User Website or Services.
ZORKA.MOBI however may still access and use information collected and stored across different User Websites and Apps, as necessary for providing and improving its Services.
You are solely responsible for notifying your Users-of-Users and for obtaining their consent to the collection, processing and use of their Personal Information.
To prevent the collection or sharing of Personal Information, you may either avoid installing Apps to your User Website, revoke the permissions granted to Apps you do install, or simply uninstall them.
You should note however that previously-installed Apps may still retain certain information that was collected prior to the revocation, so if you wish such information to be deleted, we suggest that you contact them directly and request them to do so.
17. ZORKA.MOBI Subsidiaries and Affiliated Companies:
In addition, should ZORKA.MOBI or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
18. Sharing of Personal Information adheres to the EU-US Privacy Shield frameworks.
18.1. Promotional Messages:
18.2. Service and Billing Messages:
ZORKA.MOBI may also contact you with important information regarding Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; notify you of material changes in our Services.
We are committed to securing your personal information, and use various security measures to better protect it.
However, as we can’t guarantee absolute protection – we encourage you to be careful, set a strong password for your account, and avoid submitting any sensitive information which, if exposed, could cause you major harm.
19. Public Forums and User Content
Our Services may offer publicly accessible blogs, communities and support forums. Be aware that any information you provide in any such areas may be read, collected, and used by others who access them.
To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us. at: firstname.lastname@example.org.
In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment while logged in to your related profile with such third party, you will need to login into such application or contact its provider if you want to have the Personal Information you posted through it removed.
In any event, we recommend that you do not post any information (or use any posting means to post information) you would not want to be made public on these areas.
If you upload any User Content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.
We cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website (including, for instance, password-protected areas on your Website).
You understand and acknowledge that, even after its removal, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. Again, we recommend that you do not upload or post any information you would not want to be publicly available.
Please avoid posting any information to any of the public areas on our Services, or to your own website, if you don’t want it to become publicly available.
As noted in our Terms and Conditions, we disclaim all warranties and shall not be liable for any damages (subject to applicable law). This policy shall be governed by the laws of the State of Cyprus.
Any disputes between us may only be brought before the courts of Limassol, Cyprus. We may change this policy at any time.