LAST UPDATED: JANUARY 2020
2. WHO WE ARE?
3. WHAT INFORMATION DO WE COLLECT?
We collect information that is directly related to the products and service you choose including information collected automatically and personal information.
Personal information is information about an identifiable individual, or an individual who is reasonably identifiable whether the information is true or not. The kind of personal information we collect may include:
- identifiers such as a real name, alias, postal address, telephone number, and/or e-mail address, zip code, account name;
- demographic details such as age and/or gender;
- internet or other electronic network activity information, including browsing history, search history (for example – the previous Website you visited), and information regarding a consumer’s interaction with an Internet Web site; and application, or advertisement, products you are interested in;
- device information, and information that helps you access Services (such as login information, Wi-Fi network name, IP (Internet Protocol) address (a number which is unique to the machine through which you are connected to the internet), etc.;
- geolocation information such as country, city and address;
- order information and other proof of purchase when you submit a product issue;
- survey information; and
- other information that is necessary to your enquiry.
4. WHEN DO WE COLLECT INFORMATION?
- We may collect personal information from you when you:
- fill in an application form, register with a service;
- deal with us over the telephone or through any Device;
- use an interactive activity, enter a sweepstakes or contest;
- e-mail us;
- submit your personal information details through the Website;
- ask us to contact you after visiting the Website; and
- agree to complete an on-line survey.
5. HOW DO WE COLLECT INFORMATION?
We will collect personal information when you provide to us, and only to the extent necessary to provide the product or service you requested or to carry out our internal administrative operations.
We also receive information via third party when you visit our page on social media sites or channels (e.g. Facebook, Youtube, Instagram, Linkedin etc.).
We may receive personal data about you from various third parties and public sources. Technical Data from the following parties:
- analytics providers, such as Google Analytics;
- search information providers such as Google and Bing；
- app store providers, such as the Apple App Store and Google Play.
We will collect personal information from you by lawful and fair means and not in an unreasonable way.
6. USING PERSONAL INFORMATION
We will collect, hold, use and disclose personal information for the purposes of providing or offering goods and services to you, for any purposes that you may reasonably expect, for any other purpose authorized by law, or for any other purposes with your consent. This may include disclosures to organizations that provide us with technical and support services, and professional advice.
We use personal information in the following ways to:
- provide you with news and information about our products and services;
- provide, deliver, source, administer, and improve our products and services;
- provide marketing offers through direct marketing, database compilation, market research, data analysis and segmentation, and the processing or creation of other marketing information;
- communicate with you such as responding to queries and complaints;
- send you marketing and promotional material that we believe you may be interested in;
- seek your feedback for market research purposes；
- Participation in feedback such as online surveys is completely voluntary and anonymous. It will not be used to gather identifying information about any individual;
- protect intellectual property and our legal rights; or
- protect our rights or property and comply with legal processes, which may include disclosures to law enforcement, regulatory or government agencies.
You may at any time request that we discontinue sending you emails or other communications. Requests should be directed to Customer Service – see Contact Us.
From time to time we may use the personal information we collect from you to identify particular products and services which we believe may be of interest to you. We may then contact you to let you know about these products and services and how they may benefit you. Every directly addressed marketing contact sent or made by ZURU will include a means by which you may unsubscribe (or opt out) of receiving further marketing information. Further, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. Requests should be directed to Customer Service – see Contact Us.
Entrants in Competitions, Contests and Sweepstakes
We may offer competitions, sweepstakes and contests through the Website that may require registration. By participating in a competition, contest or sweepstake, you agree to the terms, conditions and official rules that govern that particular promotion. If you choose to enter a competition, sweepstake or contest, we may disclose personal information to third parties or the public in connection with the administration of such competition, contest or sweepstake, including without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the official rules, such as on a winners’ list.
We collect information from job candidates. This information will contain personal information such as name, address, employment history and reference details.
Generally, we will collect personal information directly from the job candidate but some information may be provided by third parties providing human resource services. Job candidate personal information will be used for recruitment purposes and to evaluate the job candidate’s application. Where we wish to use the information for other purposes we will seek job candidates’ agreement beforehand.
7. SHARE INFORMATION
We will share information within the ZURU Company and subsidiaries.
We may share your personal information with service providers that perform services on our behalf and help us run our business, including running our sites and contest, delivering our emails to you, analyzing the data we collect, and sending you the products and services you requested. We only share the personal information needed for these companies to complete the tasks we request. They are required to protect your information in the same way we do and will not share it or use it for any other purpose.
We don’t and won’t sell your personal information. We do not share your personal information with third parties except for some necessary business purposes permitted by law or you have given us your consent to do so. These third parties have agreed to maintain the confidentiality and security of the information. We won’t share your personal information outside ZURU except:
- When we need to protect the safety, security, rights and property of our company, our customers or third-party partners;
- When we need to meet legal processes or if disclosure of the data is required by law; or
- If a merger, acquisition or sale of assets ever meant we needed to share information with a third party. In this case, we will email you and post a notice on our website to publish the change of owner and we’d also tell you how your data would be used and give you options regarding your personal data.
8. DATA TRANSFERS, STORAGE AND PROCESSING
ZURU conducts business throughout the world through multiple office locations and the personal information that we collect from you may be transferred to, stored at, or processed in our offices around the world or third parties carrying out such services on our behalf. All information we collect from you may be located in countries with privacy laws that may be different from where you live.
9. DATA SECURITY
ZURU is committed to keeping your trust by protecting and securing your personal information. We have in place reasonable commercial standards of technology and operational security to protect all personal information provided to us from misuse, interference, loss, unauthorized access, modification or disclosure. We limit access to personal information to individuals with a business need consistent with the reason the information was provided.
The Internet is not 100% secure. We cannot promise that your use of our sites and apps will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords. This Website may include links to third-party websites like Facebook or Walmart. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every Website you visit.
We will notify you and any applicable regulator of a data breach where we are legally required to do so.
10. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
11. YOUR LEGAL RIGHTS
Request disclosure of your personal information or access to your personal data (commonly known as a “data subject access request”). This enables you to receive additional details or a copy of the personal data we hold about you and to check that we are lawfully processing it. The file containing your personal information will be kept on our servers and those of our service providers.
This right is subject to certain exceptions (see below) allowed by law.
Your right to access your personal information is not absolute. In some circumstances, the law permits us to refuse your request to provide you with access to your personal information. Such circumstances may include where:
- access would pose a serious threat to the life or health of any individual;
- access would have an unreasonable impact on the privacy of others;
- the request is frivolous;
- the information relates to a commercially-sensitive decision-making process;
- access would be unlawful; or
- access may prejudice enforcement activities, a security function or commercial negotiations.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request deletion or erasure of your personal information. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right of data portability. We will provide to you or a third party you have chosen your personal data in a readily useable format or in a structured, commonly used, machine-readable format. Note that this right is to in response to a request for disclosure or only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Do not track right. California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals. We don’t respond to them at this time. We wait the result of work by the privacy community and industry to determine when such a response is appropriate and what form is should take. If you turn on Do Not Track in your website browser, we will respect your choice.
Besides, we don’t have any automated processing including profiling. If you wish to exercise any of the rights set out above, or you have any complaint about our processing of your personal data, please see Contact us. To check and confirm you are the right data subject, please provide us with your name and email address when you email us.
12. CHILDREN’S PRIVACY
We care deeply about making sure children are safe online and have extra privacy processes in place to make sure we’re keeping our younger fans safe when they’re using our Website. In fact, some features have age gated so to prevent children from inadvertently using such features. We also take all reasonable care to secure that we don’t knowingly collect, store, use or process personal information from children who may use those features without proper parental consent.
WHAT KIND OF INFORMATION DOES ZURU COLLECT?
A. Information provided by Children
Children may view much of the Website’s content without providing personal information (for example, first and last name, e-mail or postal address or telephone number (collectively, “Personal Information”).
ZURU may collect a Child’s e-mail address under the following limited one-time use circumstances:
- if your Child sends a request to us, we will keep their e-mail address to respond to them. We will then delete their e-mail address from our system once we have responded to them; or
- if your Child enters a competition, sweepstake or contest, we will ask the Child to give us the Parent’s e-mail address, too, so that we can tell the Parent that the Child has registered for the competition, sweepstake or contest. If we need more than the Child’s e-mail address and first name (or screen name) to enter your Child in the competition, sweepstake or contest, we will notify the Parent, explain what information we need and ask that the Parent provide it. For example, we will ask the Parent for the Parent’s mailing address so that we can send, for your Child, any prizes the Child wins, or for the Parent’s telephone number so that we can tell the Parent when the Child has won. Any information a Parent or the Child gives us in these circumstances will be deleted from our database once the competition, sweepstake or contest is concluded, and after any legally required period for keeping such information has ended.
Other than the one-time use exceptions set out above, if a Child provides more than just the Child’s e-mail address in order to participate in a particular activity, such as receiving e-mail newsletters, we will ask the Child for the Parent’s e-mail address so that we can notify the Parent of the Child’s request and obtain the Parent’s permission. When we ask for the Parent’s permission, we will tell the Parent what we will do with the information the Parent or Child provides us. We will not keep the Child’s e-mail address unless the Parent gives us permission to do so.
B. Information collected through the use of our Website
ZURU collects information on our Website’s visitors collectively including which sections of the Website are most frequently visited, how often and for how long (collectively, “Usage Information”). This is done through cookies and other technologies. This data is used as aggregated, non-Personal Information. Cookies do not contain any Personal Information about a specific user. ZURU uses Usage Information to improve and enhance our online service. You may disable cookies using your browser’s preferences, but some features of the Website may not function if you do so. We do not share this information externally.
PARENTAL CHOICES AND CONTROLS
At any time, Parents or guardians can review the personal information we have collected about the Child, request deletion, or refuse to allow further collection or use of that information. If you need to make a data-related request, contact us at email@example.com. Please let us know your child’s username, email address along with your own email address and digital signature to confirm you are the right Parent. We’ll need to confirm your identity as the parent or guardian of the child before granting access to the child’s personal information. We will respond to your request within 30 days.
WHAT DOES ZURU DO WITH THE INFORMATION WE COLLECT?
We may use a Child’s Personal Information or Usage Information:
- to provide a Child with service he chose like receiving an email newsletter;
- to enable a Child to participate in a variety of the Website’s features or enter competitions, sweepstakes or contests;
- to contact the Child and Parent with regard to the Child’s use of the Website and, in our discretion, changes to the Website and/or Website’s policies; or
REQUESTING PARENTAL CONSENT
If a child under the age of 16 accesses an online channel that’s designed for children by using an age gate, we’ll email the child’s parent or guardian before collecting any personal information from the child. The parent or guardian has the option to agree to the collection and use of the child’s information without consenting to the disclosure of the information to third parties. If a Parent think that a Parent’s child is taking part in an online activity that collects their personal information and the parent/guardian hasn’t received an email to know or seeking parental consent, please contact us at firstname.lastname@example.org. We won’t use email addresses provided for parental consent for any other purpose.
DOES ZURU SHARE ANY INFORMATION?
We may share your Child’s Personal Information to meet legal processes or if disclosure is required by law:
- in the event we are required to respond to subpoenas or other legal process or if in our good faith opinion such disclosure is required by law;
- at the request of governmental authorities conducting an investigation; or
- to protect the personal safety or rights of any individual.
14. CONTACT US
A member of our Customer Service team will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.