1. OUR COMMITMENT TO PRIVACY

This privacy policy (“Privacy Policy”) discloses the information that is collected by Zatun or its third parties, the ways in which Zatun, or our third parties processes and, sometimes, shares such information, and your rights and options with respect to such information.

Services

This Privacy Policy covers information collected from users of any of Zatun’s websites, applications, online services and other interactive properties, that links to this Privacy Policy and all features, content, and other services that we own, control and make available through such websites, applications, services and properties. Before using or submitting information to the Services please review this Privacy Policy carefully, as well as the terms of use related to each of the specific Services, which governs your use of the Services. A specific Service may have additional terms and policies regarding privacy for that specific Service, so in that instance, those additional privacy terms and policies will also apply. Should there be a conflict between this Privacy Policy and those additional privacy terms and policies, then the additional privacy terms and policies will control.

Advertisements, Content, Promotions and Services

The Services may include, without limitation, advertisements and promotions, displayed on or through such Services (collectively, “Advertisements”), text, images, photos, audio, music, videos, materials, comments, or other content displayed on or shared through the Services, whether provided by or on behalf of Zatun, or uploaded or posted by users (collectively, “Content”), and sweepstakes, contests, rewards programs, special offers or other promotions (collectively, “Promotions”).

Other Websites and Mobile Applications

Except where otherwise expressly indicated herein or on the Services, this Privacy Policy applies only to information collected on the Services and does not apply to information collected outside of the Services by other websites or mobile applications or by other third parties for which you may have a contractual relationship. Before using or submitting information to other websites or mobile applications or such third parties, please review their privacy policies carefully.

Members

Certain areas of a Service contain information intended only for users who create an account, join or otherwise register to use these areas on such Service (“Members”) and Zatun reserves the right to limit these areas to Members. This Privacy Policy addresses Zatun’s privacy practices relating to general use of the Services, as well as use of the Services by Members.

2. INFORMATION ZATUN COLLECTS

Zatun collects the following types of information from users of one or more of the Services:

Personal Information

Zatun may collect and process any information that you choose to enter on a Service or provide to Zatun in any other way that would allow Zatun to identify you or contact you (collectively “Personal Information”). The Personal Information that you provide will be used by Zatun only in accordance with this Privacy Policy. Examples of Personal Information Zatun may collect from you and uses are:

1. The information you provide to become a Member;
2. The e-mail addresses of those who upload, post or share Content on a Service;
3. The names and e-mail addresses of those who communicate with Zatun by e-mail;
4. Information you provide to Zatun in surveys and polls on a Service;
5. Information you provide to Zatun in an entry form for some Promotions offered on a Service and information provided by winners or recipients of those Promotions for a required background check or for tax purposes;
6. In certain circumstances, payment and identity verification information, such as credit card number or other payment information in connection with a purchase made through a Service; and
7. Information about other people that you provide in connection with your use of a Service or Services or sharing Content.

You can choose not to provide Zatun with certain Personal Information, but then you may not be able to take advantage of many features of a Service, such as posting comments, uploading or sharing Content, registering to use certain restricted areas of a Service, participating in Zatun’s online community, entering or participating in Promotions, or receiving e-mail alerts or newsletters.

Automatic Information

Zatun may collect and process certain types of information whenever you interact with Zatun through the Services. Zatun automatically receives and records your browser information, gameplay activity, motion sensor information, motion tracker information, operating system information, IP address, device ID, type of virtual reality equipment used, specific virtual reality platform, cookie information and the page you requested. This information will not be stored in a manner that is personally identifiable with you.

Aggregate Information

In connection with your visit or use of the Services, Zatun may automatically collect usage information, such as the numbers and frequency of users and their characteristics and information about similar groups of users, certain age groups or users that live in a particular geographical area. This data is only used in the aggregate as a statistical measure and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies discussed below.

E-mail, Sharing and Communications

When you send an e-mail to Zatun, either through the button on a Service or otherwise, Zatun may retain your e-mail address and the contents of the e-mail that you send. When you post, upload or share Content through the Services or communicate with other users through a Service, Zatun may retain copies of your Content. If you want to keep the information in your e-mail(s), posting(s), upload(s), share(s) or communication(s), private or proprietary, please do not send post, upload, share, or communicate, such information or Content to Zatun or through any Service. To help Zatun make its e-mails more interesting and helpful, Zatun also may receive a confirmation when you open e-mail from Zatun if your computer or device supports this type of program.

Purchases

If you interact with a Service which allows for the purchase or goods or services, Zatun may retain the information regarding your purchase, but Zatun will not retain any credit card information (although such credit card information may be retained by a third party which processes transactions for Zatun).

Social Network Profile Information

If you interact with Zatun, a Service, Content, Promotions, through a social network or by connecting your Member account with your social network account, then you may be permitting Zatun to access certain information from your social network profile (such as your name, e-mail address, your friend list, photos, age, gender, location, birthday, social networking ID, current city, or the people/sites you follow). If you don’t want to allow a social network to share such information with

Zatun and other third parties, please review the privacy settings and instructions of the applicable social network before you connect your Member account with your social network account.

3. INFORMATION COLLECTED BY THIRD PARTIES

Zatun may allow third parties to display or provide Advertisements, Content, Promotions or other services on or through a particular Service, such as, for example, our website. Zatun, its partners and/or advertisers, or social networks, may use third party servers to serve or present the Advertisements, Content, Promotions or the Services and to conduct research about the Advertisements, Content, Promotions or Services. Any of these third party servers may collect non-personal information, such as your browser, operating system, date/time of viewing, IP address, device ID, or clickstream data. Zatun cannot control the activities of such third parties, websites or social networks.

Furthermore, Zatun may use third party services to enable online purchasing or e-commerce functionality, which involves the sale of Zatun’s or third party products and services. These third party services may provide credit card or other payment processing services where they collect Personal Information and other financial information from you.

PLEASE NOTE THAT THIS POLICY DOES NOT COVER THE COLLECTION AND USE OF INFORMATION BY SUCH THIRD PARTY SERVICES, SERVERS OR SOCIAL NETWORKS. PLEASE REFER THE PRIVACY POLICIES OF EACH SUCH THIRD PARTY.

4. TRACKING TECHNOLOGIES

Zatun or its third parties may use tracking technologies, such as cookies and Web Beacons, to collect information about users who visit or use the Services and view or interact with Advertisements, Content, and Promotions.

Cookies

Zatun uses “cookies” to help you access and navigate the Services more efficiently and to statistically monitor how many people are using a Service.

1. A “cookie” is a small file or tool stored on your computer or device containing information that allows Zatun to deliver customized information to you. Zatun uses both “session” and “persistent” cookies on the Services. Session cookies are temporary bits of information that are erased once you exit your web browser or turn off your computer or device. Persistent cookies are more permanent bits of information that are placed on the hard drive (or other storage media) of your computer or device and stay there unless you delete the cookie. Persistent cookies store information on your computer or device for a number of reasons, such as retrieving certain information you have previously provided (i.e., username and password), helping to determine what areas of a Service you find most valuable and customizing such Service based on your preferences on an ongoing basis.
2. You may set your browser to notify you of or decline the receipt of cookies. Certain features of a Service, including certain Content, or Promotions, may not, however, function properly or be available if your browser is configured to disable cookies. Many companies offer programs that help you to visit websites or mobile versions of such sites anonymously. While Zatun will not be able to provide you with a personalized experience if Zatun cannot recognize you, Zatun wants you to be aware that these programs are available.

5. HOW ZATUN USES INFORMATION

When you provide Zatun with your Personal Information, Zatun may use it to manage Zatun’s registry of Members, facilitate communication between Zatun and you and/or between Members of a Service, notify you of features or special events and provide you with other information Zatun feels may be of interest to you. Zatun also uses information collected to customize, analyze, adjust and improve our Services, Content, and Promotions and to meet Zatun’s users’ needs and expectations. Zatun also may use the information to oversee adherence to Zatun’s guidelines for user content which are provided in the terms of use for the Services to enforce Zatun’s agreements with you, to prevent fraud and other prohibited or illegal activities and for other legally permissible purposes. These uses of your Personal Information may include, without limitation, the following:

Public Areas

A Service may feature groups, discussions, member profiles, comment areas, blogs and similar areas where users can share information about themselves and their opinions, as well as post questions and Content that may contain Personal Information (“Public Areas”). Other visitors to a Service may view information posted in Public Areas. Further, Zatun may include all or a portion of the information posted in Public Areas in the newsletters described in this Privacy Policy. By using the Public Areas, you hereby acknowledge and agree that any information you share in a Public Area (including, without limitation, Personal Information) is available to the public. Information you post to a Public Area may be viewed, accessed, or collected by, or disclosed to, third parties and may be used by others in ways neither you nor Zatun are able to control or predict, including, without limitation, to contact you for unauthorized purposes.

Email, Sharing and Communications

A Service may offer the ability to share Content or communicate directly with other users via e-mail and other communications. If you use e-mail or other communications, Zatun will use the recipient’s e-mail address or other means of identification in order to send the Content and Zatun will also ask for your e-mail address or other means of identification. Zatun does not use the recipient’s e-mail address or other means of identification for any other purpose unless the recipient gives Zatun permission to do so.

Member Areas

If you have access to certain areas of a Service because you are a Member (“Member Areas”), the Member Areas may contain groups, discussions, member profiles, comment areas, blogs and similar areas where Members can share information about themselves and their opinions, as well as post or share Content. Personal Information or Content you post or share through a Member Area may be viewed, accessed, or collected by, or disclosed to, other Members and may be used by other Members in ways neither you nor Zatun are able to control or predict, including, without limitation, disclosure of your Personal Information or Content to the public or to contact you for unauthorized purposes. Zatun uses the Personal Information you provide when registering to become a Member to send you Zatun publications, information about Member benefits and special offers, features included in the Member Areas and other information that Zatun believes is relevant and useful to its Members. By using the Member Areas, you hereby acknowledge and agree that any information you share in a Member Area (including, without limitation, Personal Information) is available to other Members and to Zatun for use as provided herein.

Profiles

If you register to become a Member of a Service, the information that you provide to Zatun may be associated with one or more profiles, which may be stored on our or third party servers. These profiles, or a portion thereof, may be viewed by other Users of a Service, including, but not limited to those who are not Members of such Service.

E-Newsletters

If you register at a Service or subscribe to any features or services, you may choose to receive a newsletter via e-mail from Zatun or other notifications via a mobile application which may include information such as highlights from different areas on a Service, and information about new features, Content, Promotions or other Services. You can unsubscribe from the newsletter at any time by clicking on the “manage your preferences” link at the bottom of any e-mail newsletter sent to you and following the instructions. You also may unsubscribe at any time by logging in to the applicable Service where you created your profile and changing your preferences. Furthermore, you may elect to turn off notifications in a mobile application.

Promotions

Often times, Promotions offered on a Service are sponsored by unaffiliated third parties. Information that you provide as part of an entry into a Promotion sponsored by an unaffiliated third party will be shared with the sponsor if Zatun advises you of such in the Promotions official rules. Some Promotions also may require consent to the release of information contained within the entry form for background check purposes or tax purposes if you become a winner. You should carefully review the official rules of each Promotion that you enter as they may contain additional important information about Zatun’s or the sponsor’s use of your Personal Information.

Features and Services

Zatun may retain other third parties and individuals to provide features and Services consistent with Zatun’s Privacy Policy on Zatun’s behalf. Examples include customer support specialists, web hosting companies, fulfillment companies (e.g., companies that fill product orders or coordinate mailings), data analysis firms and e-mail service providers.

Editorial

Zatun also may use your Personal Information in response to a solicitation for editorial, online or for marketing and promotional purposes in connection with such solicitation. If such information is used online, on a mobile application or in a telecast, no Personal Information, other than name, city and state, will be disclosed without your consent.

Social Network Features

Zatun and the Content, Promotions and Services, may include features that connect to social networks and allow you to share or like Content, Promotions or Services with your friends or other users of the social networks. These social networks may collect information, such as your IP address, which page you are visiting on a Service, the videos you viewed, or the Content, Promotions or Services that you shared, and may set a cookie to enable the features to function properly. The social network providing the features on a Service may be able to collect information about you, even if you don’t use those features. To control this sharing of information, please review the privacy policy of the relevant social network.

Ecommerce and Subscriptions

Zatun may also use cookies to enable you to use a “shopping cart” if you want to enroll in a subscription or purchase goods or services while on a Service, to store your preferences associated with purchased goods or services or other Content offered from a Service and to offer you products, programs, or Promotions based on purchases, subscriptions and Service usage behavior that you and/or other customers have exhibited. If you purchase a subscription or goods and services through a Service, your Personal Information and payment information (other than credit card or debit card information) will be collected and stored by us with your account.

Videos

Certain cookies that are set when some video products are accessed on a Service, called local shared objects or Flash cookies, may not be managed using the settings in your web browser. If you set your browser options not to accept cookies or local shared objects, you may not be able to take advantage of certain ecommerce Services, videos on a Service. You agree that Zatun may share your viewing of videos with, or obtain information about your viewing of videos from, analytics providers and advertising partners and third-party social media sites unless you withdraw your consent.

Reports

The aggregate information collected by Zatun may also be used to create profiles of the audience for a Service that include anonymous statistical demographic information but no Personal Information. This aggregated information is used to, among other things, determine trends and needs and supply market research to potential advertisers and partners to help them understand our Services’ audiences. For example, Zatun may create a report that tells advertisers that thirty percent of Zatun’s Members are females under forty years, so that they can determine which of their Content, Promotions or Services are most appropriate for Zatun’s Members.

Administration

From time to time, in Zatun’s sole discretion, Zatun may use your Personal Information to send you important administrative information regarding the Services or changes to Zatun’s terms and policies. Because this information may be important to your use of the Services, you may not opt out of receiving such communications.

6. WITH WHOM ZATUN SHARES INFORMATION

Zatun may share your Personal Information with third parties, as follows:

Advertisers

If you “opt in” to receive information about identified advertisers or their services or products, Zatun may share your Personal Information with them. If you have questions about how these companies use your Personal Information, Zatun encourages you to review and understand their respective privacy policies. You may at any time “opt out” of having your Personal Information as part of Zatun’s marketing mailing list or otherwise.

Advertising Partners

Advertisements appearing on a Service may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer or device each time they send you an online Advertisement to compile information about you or others who use your computer or device. This information allows ad networks to, among other things, deliver targeted Advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by the Services and does not cover the use of cookies by any advertisers, each of whom maintain their own privacy policy.

Service Providers

Zatun engages service providers to perform functions and provide services to us or on our behalf, including Promotions, Advertisements, and other programs. Zatun may share your Personal Information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your Personal Information only on our behalf and pursuant to our instructions.

Payment Processors

Zatun shares your payment information with payment services providers to:

1. Process payments,
2. Prevent, detect and investigate fraud or other prohibited activities,
3. Facilitate dispute resolution such as chargebacks or refunds, and
4. For other purposes associated with the acceptance of credit or debit cards.

If such information is stored with Zatun, Zatun may share your credit or debit card number with payment services providers or card networks to monitor card transactions at participating merchants and track redemption activity for the purposes of providing card-linked services.

Government, Law Enforcement or Third Parties

Zatun may disclose any information, including without limitation Personal Information that Zatun deems necessary, in its sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. Zatun also may exchange information, including without limitation Personal Information, with other companies and organizations for credit fraud protection, risk reduction and related activities or to protect the rights, property of safety of Zatun and its agents, employees or affiliates or others. Zatun reserves the right to disclose a user’s Personal Information if Zatun believes the user is in violation of Zatun’s terms of use, even without a subpoena, warrant or other court order.

7. SALE OR TRANSFER OF INFORMATION

In the event of a sale, merger, liquidation, dissolution or sale or transfer of substantially all of the assets or equity of Zatun or the Services, Personal Information and/or other information collected about you from the Services may be sold, assigned or transferred to the party acquiring all or substantially all of the equity and/or assets of Zatun or the Service(s) in order to permit the party to continue the operation of the applicable Service or Services. Subject to your ability to opt-out, you consent to the sale and transfer of your information as described in this paragraph.

8. ACCESSING, CORRECTING OR REMOVING YOUR PERSONAL INFORMATION

If you are a Member and would like to review or update your profile, please log in to and select the profile in which you would like to review, modify or delete information (i.e., the Personal Information you have provided to us). If you would like to delete your profile, please contact us at legal@zatun.com.

Choice

Zatun respects the privacy of your Personal Information. If you tell Zatun that you do not wish to have this information used as a basis for further contact with you, Zatun will respect your wishes. You also may choose not to provide Zatun with certain information, but that may result in you being unable to use certain features of a Service. You may instruct Zatun to stop sending you certain promotional materials (e.g., e-mail messages, newsletters, postcards and letters) by following the unsubscribe instructions provided in those materials or by turning of the notification feature on a mobile application. Zatun may, however, continue to contact you to provide service to your account. Please note that if you use more than one name or e-mail address when communicating with Zatun or participating on a Service, you may continue to receive communications from Zatun to any name and/or e-mail address which you have not specified in your opt-out request.

Correcting or Removing Your Personal Information

For Personal Information Zatun holds, you can request that we correct the data if it is inaccurate or remove the data if we are not required to retain it by law or for legitimate business purposes. For example, under the Data Protection Directive, you are entitled to obtain information (a) confirmation as to whether data relating to you is being processed and information as to the purposes of the processing, the categories of data, and the recipients to whom the data are disclosed; (b) communication of the data undergoing processing and of any available information as to their source; and (c) knowledge of the logic involved in any automatic processing of data concerning you.

Zatun may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Under the Data

Protection Directive, we may charge you a €5 fee to comply with your request.

Zatun provides you with the following options for correcting or removing your Personal Information from Zatun’s database for marketing purposes:

You can send an e-mail to legal@zatun.com.

Canceling Your Account or Subscription

To cancel your account or subscription, you can: (a) e-mail customer@zatun.com, subject “Cancel My Account” or “Cancel My Subscription” and include the e-mail address that you registered your account or subscription with (if different from the e-mail address you’re sending the e-mail from); or (b) via your online Member account page. Remember that even after you cancel your account, copies of some information from your account may remain visible in some circumstances – where, for example, you have shared information with a third-party application or website. Zatun may also retain backup information related to your account on our servers for some time after cancellation for fraud detection or to comply with applicable law or our internal security policies. Because of the nature of caching technology, your account may not be instantly inaccessible to others, and there may be a delay in the removal of the content from elsewhere on the Internet and from search engines.

Data Retention

Zatun will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law or unless otherwise limited by law.

9. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

Third Party Links

The Services may contain links to third-party web sites. Please be aware that Zatun cannot control and is not responsible for the information collection practices of such web sites, which may differ from those of Zatun. Zatun encourages you to review and understand the privacy policies of these websites before providing any information to them.

Data Security

Zatun (either itself or through third party service providers) maintains a variety of commercially reasonable physical, electronic and procedural safeguards designed to protect your Personal Information from unauthorized access and disclosure. For example, Zatun uses accepted tools and techniques to protect against unauthorized access to Zatun’s systems. You should be aware that Zatun has no control over the security of other sites on the Internet that you might visit or with which you might interact even when a link may appear to another site from one of the Services. Zatun wants you to feel confident using the Services but no system can be completely secure. Therefore, although Zatun takes steps to secure your information, Zatun does not promise, and you should not expect, that your Personal Information, searches or other communications will always remain secure. In the event of a breach of the confidentiality or security of your information, including your Personal Information, Zatun will notify you as necessary and if possible so you can take appropriate protective steps. Zatun may notify you under such circumstances using the e-mail address(es) that Zatun has on record for you and/or by regular mail (if available). You also should carefully handle and disclose your Personal Information.

Children

The Services are intended for general audiences and are not intended for children under thirteen (13) years of age. Zatun requires that only persons thirteen (13) years of age or older use any of the Services. By using any Service, you hereby represent that you are at least thirteen (13) years old. Zatun does not knowingly market to, solicit information, accept service or collect information from children under the age of thirteen (13). A Service may ask users for their birth dates to ensure that such Service is not collecting information from children under age thirteen (13) or to identify when additional steps may need to be taken in connection with information collected from children under age thirteen (13). When a Service has actual knowledge that it collects information from children or offers a service directed toward children. In the event that Zatun learns that we have collected Personal Information from a child under age thirteen (13) without parental consent, we will delete that information as quickly as possible. If you believe that we might have any Personal Information from or about a child under thirteen (13), please contact us at: legal@zatun.com.

Changes to this Privacy Policy

At any time without prior notice, Zatun may update this Privacy Policy to reflect changes in Zatun’s practices. When Zatun posts changes to this Privacy Policy, Zatun will revise the “Last Updated” date at the top of this page. Zatun encourages you to bookmark this Privacy Policy and to periodically review it to inform yourself of changes to it or any of Zatun’s other policies. Any changes to Zatun’s Privacy Policy will become effective upon Zatun’s posting of the updated policy.

Use of any Service that inks to this Privacy Policy constitutes your acceptance of the terms of this Privacy Policy then in effect.

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties.

Contacting Zatun

If you have any questions about this Privacy Policy, the practices of the Services or your dealings with us, please feel free to contact Zatun at:

Zatun

1, Laxmikunj, B/H N.I.D

Museum, Paldi, Ahmedabad

Gujarat – 380007

India.

Attention: Legal – Privacy

legal@zatun.com.