Effective November 26, 2020. Last Revised November 26, 2020

We want you to understand how and why 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”) collects, uses, and shares information about you when you use our website https://yt.zorka.mobi/ (hereinafter, the “Program”). This Privacy Policy is the full version of the privacy statement applicable to online activities on the Program. If You need to contact us in relation to this Privacy Policy please email us to: yt-support@zorka.mobi.

PREAMBLE

If you do not agree with this Privacy Policy (hereinafter, the “Policy”), your choice is not to use the Program. By accessing or using this Program, you agree to this Policy. This Policy may change from time to time; any changes we make to this Policy will be posted on this Program, we may also take any other steps, to the extent required by applicable law, including notifying you and/or seeking your explicit consent to material changes. Changes to this Policy are effective as of the stated "Last Updated" date. Other than where we have sought such explicit consent from you, your continued use of the Program after we make changes will constitute acceptance of, and agreement to be bound by, those changes, so please check the Policy periodically for any updates or changes.

By using the Program Zorka Mobi and You are bound with YouTube Terms of Service (YouTube Terms of Service). Zorka Mobi uses YouTube API services as part of the delivery of the Program. Google collects and stores data in accordance with the Google Privacy Policy (reference and link to the Google Privacy Policy at http://www.google.com/policies/privacy). In addition to deleting stored data via the Program, You can revoke Zorka Mobi's access to your YouTube data via the Google security settings page at https://security.google.com/settings/security/permissions.

Zorka Mobi 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 Policy. Our Program 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 Policy 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 is responsible for managing the data, as well as determining the purposes and methods of processing personal data provided and collected online.

Principles

Zorka Mobi'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 access or/and use the Program;
• 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.

SECTION 1. PERSONAL DATA

1.1. 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 (i.e., using other data) correlated with the data subject, such as name, date of birth, address, email address, phone number, etc.

1.2. Personal data is not transferred to third parties, except in circumstances where such transfer is necessary to access or/and use the Program. 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: yt-support@zorka.mobi.

SECTION 2. YOUR ACCEPTANCE

2.1. 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.

2.2. By accessing or using any of our Program, you signify your consent to this Privacy Policy. You may use our Program only if you fully consent to the practices described in this Policy.

2.3. This Policy describes how Zorka Mobi may collect and use information pertaining to each of our unregistered visitors and registered users (each, a “Visitor”, «Participants» or “User” (respectively), or “you”), in connection with their access to and use of our Program.

2.4. This Policy constitutes a binding and enforceable legal contract between Zorka Mobi and you - so please read it attentively.

2.5. You may visit and/or use the Program only if you fully agree to this Policy - and by accessing and/or using any part of the Program, you signify and affirm your informed consent to this Policy, including to the collection and processing of your Personal Information as defined and explained below.

2.6. 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.

SECTION 3. WHAT INFORMATION DO WE COLLECT?

3.1. 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).

3.2. Information You Provide to Us.

3.2.1. 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), 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, the name of your YouTube Channel and its link), correspondences on the Program, and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Program. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Program we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.

3.2.2. We collect information you provide to us directly when you use the Program. This includes:

Account information

If you create an Account on the Program, we may require you to provide a username and password, email address, the name of your YouTube Channel, the link on your YouTube Channel.

Your username is public, and it doesn’t have to be related to your real name. We also store your user account preferences and settings.

Content for using the Program

The “description box” of the video on your YouTube Channel which was selected by you for the participation in the Program.

Communication with us

We collect the content you submit to the Program. This includes your communications with us. Your content may include text, links, images, GIFs, and videos.

3.3. Information We Collect Automatically. When you access or use our Program, we may also automatically collect 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 Program (“Non-personal Information”). This includes:

Log and usage data

We may log information when you access and use the Program. This may include your IP address, user-agent string, browser type, operating system, referral URLs, device information (e.g., device IDs), device settings, pages visited, links clicked, the requested URL, and search terms. Except for the IP address used to create your account, Zorka Mobi will delete any IP addresses collected after 30 days.

Information collected from cookies and similar technologies

We may receive information from cookies, which are pieces of data your browser stores and sends back to us when making requests, and similar technologies. We use this information to improve your experience, understand user activity, personalize content and advertisements, and improve the quality of our Program. For example, we store and retrieve information about your preferred language and other settings. See the Section 7 of the Policy for more information about how Zorka Mobi uses cookies.

Please note: 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 Program, 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. 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.

3.4. Information Collected from Other Sources:

3.4.1. 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 cybersecurity 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)”).

3.4.2. 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 Program.

3.4.3. Note that while our Program may contain links to other websites or services, we are not responsible for such websites’ or services’ privacy practices, and encourage you to be aware when you leave our Program and read the privacy statements of each and every website and service you visit. This Policy does not apply to such linked third-party websites and services.

3.4.4. 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.

3.4.5. Linked services:

Linked services

If you authorize or link a third-party service to access your Account on the Program, Zorka Mobi receives information about your use of that service when it uses that authorization. Linking services may also cause the other service to send us information about your account with that service. For example, if you sign in to the Program with a third-party identity provider, that provider may share an email address with us. To learn how information is shared with linked services, see the Section 5 of the Policy.

3.5. 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 a user directly.

3.6. Some jurisdictions require us to maintain and store their residents’ information locally. We may also collect, process, store and use such information elsewhere.

SECTION 4. HOW DO WE COLLECT YOUR INFORMATION?

4.1. We collect Non-personal and Personal Information for the following purposes:

• To provide and operate the Program;
• To further develop, customize and improve our Program, 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;
• 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 comply with any applicable laws and regulations.

SECTION 5. WHERE DO WE STORE YOUR INFORMATION?

5.1. We may store and process Personal Information subject to this Policy all over in the Worldwide.

5.2. Zorka Mobi’s data storage providers are committed to protect and secure your data.

5.3. 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.

5.4. For example, each of our Users is able to import their email 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.

5.5. 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.

5.6. 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.

5.7. 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.

5.8. 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).

5.9. If requested to remove any Users Personal Information, we will respond to such a request within thirty (30) days.

5.10. Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section below.

SECTION 6. SHARING PERSONAL INFORMATION WITH THIRD PARTIES

6.1. 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.

6.2. 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 Program 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 Visitors’ and Users’ preferences and authenticated sessions, to better secure our Program, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall efficiency of our Program.

6.3. Please note that Third Party Services placing cookies or utilizing other tracking technologies through our Program may have their own policies regarding how they collect and store information. Such practices are not covered by our Policy and we do not have any control over them.

SECTION 7. COOKIES

7.1. 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 Program.

7.2. 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.

7.3. Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Program, or may otherwise adversely affect your user experience.

7.4. Google Analytics: to collect information on how visitors and registered users use the Program. We use the information to compile reports and to help us improve the Program. The cookies collect information, including the number of visitors to the Program, where visitors have come to the Program from. For more information about Google’s privacy policy, please visit http://www.google.com/intl/en/policies/. If you do not wish to allow the use of Google Analytics cookies at all, Google provides an opt-out plug-in for most common website browsers http://tools.google.com/dlpage/gaoptout.

7.5. 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 Program 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 Program.

7.6. 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.

7.7. Behavioral Targeting/Re-Targeting: Certain Third Party Services and ad networks may display advertising on our Program, 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 Program and different third party Services to provide you with targeted advertising based on your interests and preferences.

7.8. 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.

7.9. 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.

7.10. “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.

SECTION 8. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

8.1. By subscribing to the Program and providing Zorka Mobi with your e-mail address or any other contact information (such as name of your YouTube Channel), you expressly agree to receive promotional content, messages from Zorka Mobi or our partners (acting on Zorka Mobi’s behalf) through such means.

8.2. Accordingly, Zorka Mobi and its partners shall be entitled to send you promotional content or messages by email, direct text messages and similar forms of communication. If you wish not to receive such promotional messages, you may notify Zorka Mobi at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.

SECTION 9. ACCESSING YOUR PERSONAL INFORMATION AND DATA RETENTION

9.1. 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.

9.2. We will respond to your request within 30 (thirty) calendar days.

9.3. We may retain your Personal Information (as well as your all Users Information) for as long as your User Account to the Program is active or as otherwise needed to provide you with our Program.

9.4. We may continue to retain such Personal Information even after you deactivate your User Account to the Program and/or cease to use the Program, 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.

9.5. 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).

SECTION 10. SECURITY

10.1. 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 the Program; 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 Program and protection of our Visitors’ and Users’ privacy.

10.2. 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 your User Account to the Program.

10.3. We therefore encourage you to set strong passwords for your User Account to the Program, 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 Program 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.

SECTION 11. LAW ENFORCEMENT, LEGAL REQUESTS AND DUTIES

11.1. 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.

SECTION 12. PROTECTING RIGHTS AND SAFETY

12.1. 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.

12.2. Our Program 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.

12.3. 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 Program. Each such Partner is required to be bound by Zorka Mobi – Partner Program Agreement, which among others contains restrictions on how they may access, store and use the Non-personal and Personal Information you and/or your Users provide them or us. We encourage you to review any privacy policy accompanying a Third Party App and ask Third Party Developers for any clarifications you may need before deciding whether to install and use their Third Party App. Zorka Mobi does not control and is not responsible for the actions or policies of any Third Party Developers, and your use of any Third Party App is at your own risk.

12.4. 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 Program and/or User Website, which are stored and thereafter accessible via your User Account to the Program.

12.5. 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.

12.6. 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 Program.

12.7. 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.

SECTION 13. ZORKA MOBI’S SUBSIDIARIES AND AFFILIATED COMPANIES

13.1. We may share Personal Information internally within our family of companies, for the purposes described in this Privacy Policy. 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 an event.

SECTION 14. SHARING OF PERSONAL INFORMATION ADHERES TO THE EU-US PRIVACY SHIELD FRAMEWORKS

14.1. Zorka Mobi may also contact you with important information regarding the Program, or your use thereof. For example, we may send you a notice (through any of the means available to us) if the Program is temporarily suspended for maintenance; reply to your support ticket or e-mail; notify you of material changes in our Program.

14.2. 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.

SECTION 15. USER CONTENT

15.1. 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 the Program, 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).

15.2. 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 Program, or to your own website, if you don’t want it to become publicly available.

SECTION 16. FINAL PROVISIONS

16.1. As noted in our Terms and Conditions (https://yt.zorka.mobi/terms), we disclaim all warranties and shall not be liable for any damages (subject to applicable law). We may change this Policy at any time. Your use of the Program, and any disputes arising from it, is subject to this Policy as well as our Terms and Conditions and all of its general provisions including disclaimer of warranty, limitation of liability and indemnity.

16.2. This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by, construed under and enforced in all respects solely and exclusively in accordance with the internal substantive laws of the State of Cyprus, without respect to its conflict of laws principles.

16.3. Any dispute arising out of this Agreement or the interpretation thereof, shall be discussed by the parties in the first instance, and if possible resolved by negotiation. In the event that the matter cannot be so resolved, it shall be submitted to and determined by arbitration by the District court of Limassol, Cyprus.

16.4. We may update this Privacy Policy to reflect changes to our information collection, usage and storage practices.

16.5. This Privacy Policy was written in English.