Privacy Policy

• SOURCES OF PERSONAL DATA

This Notice applies to personal data that we collect from or about you by the methods described below (see Section 2), from the following sources:

Zenith ZingWebsites . These are consumer-facing websites operated by or for Zenith Zing, including those we operate under our own domains/URLs and mini-sites we manage on third party social networks such as Facebook ("Websites").

Zenith Zingwebsites or mobile application . Includes consumer-facing websites or mobile applications or applications operated by or for Zenith Zing, such as smartphone applications.

E-mail, text messages or other electronic messages. Electronic communications between you and Zenith Zing.

Zenith ZingCAC . Calls to our Customer Care Centers ("CAC").

Zenith Zingboutiques . Physical stores managed by Zenith Zing.

Offline registration forms. Paper registration forms or similar forms that we collect by mail, in-store demonstrations, contests and other promotions or events, among others.

Points of sale. Assistants present in third party stores who will show you and help you with the ordering of your products.

Data from other sources. Third-party social networks (such as Facebook or Google) or market research (if comments are not provided anonymously).

• PERSONAL DATA WE COLLECT ABOUT YOU AND HOW THIS IS DONE

Depending on how you contact Zenith Zing (online, offline, by phone, etc.), we collect various types of information about you, as described below.

Contact details. This includes any information you provide to Us that allows Us to contact you, such as your name, postal address, email address, social media details or telephone number.

Account registration information. Any information that is requested to give you access to your account profile. This includes your identifier, email address, username, password in an unrecoverable form and/or security question and its answer, among others.

Demographic information and interests. Any information that describes your demographic characteristics or behavioral patterns. This includes your date of birth, age or age range, gender, geographic location (e.g., zip code), favorite products, hobbies and interests, and household and lifestyle information, among others.

Technical information about computer/mobile devices. Any information about the computer system or other technological device you use to access one of our websites or applications. This includes the internet protocol (IP) address you use to connect your computer or device to the internet, the type of operating system, and the type and version of web browser. If you access a Zenith Zing website or application through a mobile device such as a smartphone, the information collected will also include your phone's unique identifier, advertising ID, geographic location and other data relating to similar mobile devices.

Website/Connection Usage Information. As you browse and interact with our websites or newsletters, we use automatic data collection technologies to collect certain information about your actions. Such information includes the links you click on, the pages or content you view, the time you view them, as well as other similar information and statistics about your interactions, such as content response times, download errors, and the length of visits to certain pages. This information is collected using automated technologies, such as cookies (both browser and flash) and web beacons. It is also collected through the use of third party tracking services. You have the right to object to the use of such technologies; section 3 provides more information about this.

Market research and consumer feedback. This includes information you voluntarily share with Us about your experience with our products and services.

Consumer Generated Content. This refers to any content that you create and share with Us on third party social networks or upload to one of Our websites or applications. This includes the use of third party social networking applications such as Facebook. Such content refers to photos, videos, personal stories, or other similar media or content, among others, and private posts or messages that you may leave on Zenith Zing' s social media pages. Where permitted, we will collect and post consumer-created content about activities such as contests and other promotions, website community features, consumer-directed events, and third-party social media.

Third Party Social Networking Information. This refers to any information that you share publicly on a third party social network (such as Facebook) or that is part of your profile on such networks, which you have authorized to share this information with Us. By this information We mean your basic account information (such as your name, email address, gender, date of birth, current city, profile picture, username, friends list, etc.) and any additional information or activities that you permit the third party social network to share, among other things. We receive your third-party social network profile information (or part of it) whenever you download or interact with a Zenith Zing web application on one of these networks, such as Facebook. This also occurs when you use a social networking feature integrated into a Zenith Zing website (such as Facebook Connect) or interact with Us through a third-party social network. To learn more about how Zenith Zing obtains your information from a third-party social network, or to opt out of sharing, you should visit the website of the relevant third-party social network.

Financial and payment information. This includes any information we need to complete an order; information you use to make a purchase, such as your debit or credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if available). In all cases, We and our payment processing providers handle financial and payment information in accordance with applicable laws and regulations and security standards such as PCI DSS.

Calls to the CAB. Communications with a CAC may be recorded or listened to, in accordance with applicable law, to meet local operational needs (e.g., for training or quality purposes). You will be informed of the recording at the beginning of the call, if required by law.

Email. We analyze your interactions with our content (e.g., clicking, opening an email) to provide you with information tailored to your interests and preferences.

• COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS

Cookies/similar technologies. Please refer to our cookie notice to learn how to manage your cookie settings, for details of the cookies we use and the purposes for which we use them.

Log Files. We collect information through log files that record website activity and collect statistics about users' browsing habits. These entries are generated automatically and help us troubleshoot bugs, improve performance and maintain the security of our websites.

Web beacons. Web beacons (also known as "web beacons") are small strings of code that send a graphic image on a web page or in an email to transfer data back. The information collected through them may include information such as IP address, as well as information about how a user responds to an email campaign (e.g., the time the email is opened, where the user links to from the email, etc.). We may use web beacons on our websites or include them in emails we send to you. We use web beacon information for various purposes, such as website traffic reporting, unique visitor counts, advertising, email auditing and reporting, and personalization, among others.

• USES OF PERSONAL DATA

The following paragraphs describe the various purposes for which we collect and use your personal data, as well as the different types of personal data collected for each purpose. Please note that not all of the uses described below will be relevant to every individual.

• DISCLOSURE OF YOUR PERSONAL DATA

In addition to the in-country entities or ad hoc partners (in charge of Zenith Zing's operations) mentioned in the Data Controllers and Contact section (see Section 11), we share your personal data with the following types of third party organizations:

Service Providers. These are outside companies we use to help us run our business (such as order fulfillment, payment processing, fraud detection and identity verification, website operations, companies that perform market research, support services, promotions, website development, data analysis, CRC, etc.). Service providers and their selected staff may only access and use your personal data on our behalf for the specific tasks they have been asked to perform, following our instructions, they are required not to disclose and protect your personal data. Where permitted by applicable laws, you may obtain a list of the service providers that process your personal data (see Section 11 to contact Us).

Credit reporting agencies/collection agents. To the extent permitted by applicable law, credit reporting agencies and collection agents are outside companies that we use to help us verify your creditworthiness (particularly for invoiced orders) or to collect outstanding invoices.

Third-party companies that use personal data for their ownmarketingpurposes . Except in situations where you have given your consent, we do not license or sell your personal data to third party companies for their own marketing purposes. Your identity will be disclosed at the time your consent is requested.

Third parties using personal data for legal reasons or due to a merger/acquisition. We will disclose your personal data to third parties for legal reasons or in the context of an acquisition or merger (see Section 4 for more information).

• PRESERVATION OF YOUR PERSONAL DATA

In accordance with applicable laws, we will use your Personal Data for as long as necessary to fulfill the purposes for which it was collected (as described in Section 4 above) or to comply with applicable legal requirements.

Personal data used to provide you with a personalized experience (see Section 4 above for more information) will be retained for as long as permitted by applicable laws.

• STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA

We use a number of reasonable measures (described below) to keep your personal information confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public spaces such as third-party social networks.

Persons who may have access to your personal data. Your personal data will be processed by our staff or authorized agents, in order to obtain certain information depending on the specific purposes for which it was collected (e.g. our staff in charge of customer service matters will have access to your customer record).

Measures taken in operating environments. We store your personal data in operating environments that use reasonable security measures to prevent unauthorized access. We follow reasonable standards to protect personal data. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of data during transmission through our websites/applications.

Actions we expect you to take. It is important that you also do your part to ensure that your personal data is safe and secure. When signing up for an online account, be sure to choose a password that is difficult for others to guess and never give it to anyone else. You are responsible for its confidentiality and your use of your account. If you use a public or shared computer, never choose to remember your username/email address or password. Be sure to log off each time you leave the computer. You should also use the privacy settings or controls we provide on our website/application.

Transfer of your personal data. The storage and processing of your personal data as described above may require that it be transferred/transferred to and/or stored at a destination outside your country of residence, primarily Switzerland. We will also transfer it to countries outside the European Economic Area ("EEA") (such as to other Zenith Zing entities or ad hoc country partners, which include countries that have different data protection standards to those applicable in the EEA. We (i) have put in place standard contractual clauses approved by the European Commission to protect your personal data (and you are entitled to request a copy of these clauses from Us by contacting Us as set out below) and/or (ii) We will rely on your consent (where permitted by law).

• YOUR RIGHTS OVER YOUR PERSONAL DATA

Access to Your Personal Information. When provided by law, you, your successors, representatives and/or proxies have the right to access, review and request a physical or electronic copy of the information collected about you. You also have the right to request information about the origin of your personal data.

These rights can be exercised by sending an email to administracion@zenithzing.com and attaching a copy of your ID card or equivalent information (when requested by us and permitted by law). If the request is submitted by a person other than you, without providing proof that it has been legally made on your behalf, it will be rejected.

Please note that any information you provide to us will be processed only in accordance with and to the extent permitted by applicable laws.

Additional rights (such as modification or deletion of personal data). Where provided by law, you, your successors, representatives and/or proxies may: (i) request deletion, portability, correction or revision of your personal data; (ii) object to data processing; (iii) limit the use and disclosure of your personal data; and (iv) revoke consent to any of our data processing activities.

These rights can be exercised by sending an email to administracion@zenithzing.com and attaching a copy of your ID card or equivalent information (when requested by us and permitted by law). If the request is submitted by a person other than you, without providing proof that it has been legally made on your behalf, it will be rejected.

Please note that any information you provide to us will be processed only in accordance with and to the extent permitted by applicable laws.

In addition, please note that in certain circumstances, we may not be able to delete your personal data without also deleting your user account. We may be required to retain some of your personal data after you have requested deletion in order to comply with our legal or contractual obligations. Applicable laws may also allow Us to retain some to comply with applicable legal obligations.

Where available, our websites have a specialized feature through which you can review and modify the personal information you have provided. Please note that we require our registered consumers to verify their identity (such as login ID/email address or password) before they can access or make changes to their account information. This helps prevent unauthorized access to your account.

We look forward to answering any queries you may have about the way we process your personal data. However, if you have any issues to resolve, you can exercise your right to complain to the competent data protection authorities at www.aepd.es.

• YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA

We strive to give you choices regarding the personal information you provide to us. The following mechanisms give you the following control over your personal data:

Cookies/similar technologies. You can manage your consent through: (i) our consent management solution, or (ii) your browser, which you can set to reject all or some cookies/similar technologies, or to alert you when they are used. See Section 3 above.

Advertising, marketing and promotions. If you wish your personal data to be used by Zenith Zing to promote its products or services, you may indicate this by checking the box(es) provided on the registration form or by answering the questions posed by the persons in charge of conducting demonstrations, CACs or boutique representatives. If you decide that you no longer wish to receive such communications, you may unsubscribe from receiving commercial communications by following the instructions provided in each communication. To unsubscribe from commercial communications sent by any means, including third party social networks, you may unsubscribe at any time by logging into the third party websites/applications or social networks and adjusting your user preferences in your account profile by unchecking the relevant boxes or by calling our CACs. Please note that even if you opt out of receiving marketing communications, you will still receive administrative communications from us. These include order or other transaction confirmations, notifications about your account activities (e.g., account confirmations, password changes, etc.) and other important announcements, among others.

Personalization (offline and online):Where required by law, if you would like your personal data to be used by Zenith Zing to provide you with a personalized experience/targeted advertising and content, you can indicate this through the box(es) you will find on the registration form or by answering the question(s) asked by the persons in charge of conducting demonstrations, CACs or boutique representatives. If you decide that you no longer wish to benefit from this, you may unsubscribe at any time by logging into the websites/applications and adjusting your user preferences in your account profile by unchecking the appropriate boxes or by calling our CACs.

• CHANGES IN OUR NOTICE

If we change the way we handle your personal information, we will update this Notice. We reserve the right to make changes to our practices and this Notice at any time, so we encourage you to check it frequently for updates or changes.

• DATA CONTROLLERS AND CONTACT

To ask questions or comment about this Notice and our privacy practices or to file a complaint about our compliance with applicable privacy laws, please contact Zenith Zing at:

• administracion@zenithzing.com

You can also contact our Data Protection Officer by mail at: CALLE BUENOS AIRES 3 - 35002 LAS PALMAS DE GRAN CANARIA (LAS PALMAS) SPAIN, with reference "Delegado de Protección de datos Zenith Zing".

We will acknowledge and investigate each complaint about how we handle personal data (including a complaint about a breach of your rights under applicable privacy laws).