Privacy Policy
**PRIVACY POLICY**
*Effective Date: April 30, 2024*
*To download and/or print this Privacy Policy (“Privacy Policy”), click [here](link).*
Thank you for visiting a website, mobile application, online or offline service, or any other place where this policy is referenced (collectively, the “Service(s)”) owned or operated by Zeitsight JE3 Ltd Inc. or one of its business divisions (collectively, “ZJ3”). This Privacy Policy provides information about how ZJ3 collects, uses, and discloses personal information, including the choices ZJ3 offers with reZJ3ct to that information.
By visiting or otherwise using the Service, you agree to the Service’s Terms of Use and consent to ZJ3’s collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service. If you do not agree and consent, please discontinue use of the Service, and uninstall Service downloads and applications.
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**CONTENTS**
1. Personal Information We Collect
2. Sources From Which We Collect Personal Information
3. How We Disclose Personal Information
4. How Long We Keep Personal Information
5. California Privacy Rights
6. Privacy Rights for Consumers in Covered States Other Than California
7. Data Security
8. International Transfer
9. Children’s Privacy
10. Your Choices
11. Changes to This Privacy Policy
12. Contact ZJ3
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**1. PERSONAL INFORMATION WE COLLECT**
As used in this Privacy Policy, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.
Generally, we collect the following categories of Personal Information, which we use for the business or commercial purposes shown below. Note that the Personal Information we collect about you may vary depending on the Service and the nature of your interactions with us, and may not include all of the examples listed.
As described in more detail in our Children’s Privacy Policy, some of our Services may collect Personal Information from children under 13, which may be considered sensitive under some state privacy laws.
In addition to the purposes described above, we may collect, use, and disclose Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or for other purposes described in any other privacy notice or with your consent. Additionally, we may use and disclose Personal Information to third parties in connection with a sale, assignment, merger, reorganization, or other corporate transaction relating to all or part of our business.
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**2. SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION**
We collect the categories of Personal Information listed above from the following categories of sources: directly from you, from our affiliates (including other ZJ3 affiliated entities (“ZJ3 group companies”), and service providers that help us run our business, including data analytics companies, ad networks, social networks, internet service providers, and data resellers such as data management platforms. We also collect Personal Information via Tracking Technologies when you use our websites or mobile apps. ZJ3 uses cookies and other tracking technologies (such as web beacons and software development kits) to collect and store information about your interactions with our Service (collectively, “Tracking Technologies”). Our websites also support third-party cookies placed by our service providers and third parties, such as advertising partners. This means that our service providers and advertising partners can collect and use information regarding your interactions with our websites as further detailed below.
ZJ3 is giving you notice of the use of Tracking Technologies and your choices regarding them as explained in Section 10 so that your consent is meaningfully informed.
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**B. Targeted Advertising, Sales, and Sharing of Personal Information**
We may share each of the following categories of Personal Information with third parties such as advertising networks, internet service providers, certain data analytics providers, operating systems and platforms, social networks and ZJ3 group companies which may not share common branding:
– Identifiers
– Personal records
– Commercial information
– Internet or other electronic network activity information
– Geolocation data
– Audio, visual, or similar information
– Inferences
ZJ3 does not sell Personal Information in exchange for money. ZJ3 shares Personal Information with third parties in compliance with the law to deliver targeted ads and other tailored communications to consumers, for certain type of analytics services, for purposes for which the recipient may use the information for our benefit and the benefit of other businesses, and for other similar reasons provided in this Privacy Policy. Some of these uses of Personal Information may be considered “sales” or “sharing” for targeted/cross-context behavioral advertising under US state privacy laws. If you are a resident of a California, Colorado, Connecticut, or Virginia and would like to opt out of these uses of your Personal Information, please see the instructions provided within the state-specific Sections below.
ZJ3 does not have actual knowledge that it sells the Personal Information of consumers under 16 years of age without affirmative authorization.
**4. HOW LONG WE KEEP PERSONAL INFORMATION**
We keep the categories of Personal Information described above for as long as necessary or permitted for the purposes described in this Privacy Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
– Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
– Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
– The Personal Information is reasonably necessary to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
– We are otherwise required or permitted to keep your information by applicable laws or regulations.
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires.
**5. CALIFORNIA PRIVACY RIGHTS**
**A. CCPA Rights**
If you are a California consumer, your rights under the California Consumer Privacy Act (“CCPA”) are set forth below.
– If you are our employee, please see our California Employee Privacy Notice for additional disclosures.
– California job applicants can find additional disclosures [here](link).
– Business contacts should review our B2B Privacy Notice.
– If you used to work for us and wish to submit a request relating to your Personal Information, please click [here](link).
If you are a California consumer who would like to submit a deletion, correction or right-to-know request, you can click [here](link) or contact us at 1-800-782-6588. If you would like to opt out of sales of Personal Information or sharing of Personal Information for cross-context behavioral advertising, or if you would like to limit use of your sensitive Personal Information, please see the instructions [here](link). If you have visited the ZJ3 studios in Culver City, California in person, please click [here](link). Please note that if you submit a request to delete, request to know or request to correct, ZJ3 will need to take reasonable steps to verify your identity before the request will be processed, which may include logging into your account or providing us with 2-3 pieces of Personal Information which we will match to information we maintain about you. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.
Right to Delete. As a California resident you have the right to request that ZJ3 delete Personal Information which ZJ3 has collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.
Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
– The categories of Personal Information we have collected about you, including:
– The categories of sources from which the Personal Information was collected
– Our business or commercial purposes for collecting, selling, or sharing Personal Information
– The categories of recipients to which we disclose Personal Information
– The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
– The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information
– The specific pieces of Personal Information we have collected about you
Right to Opt Out. California residents have the right to opt out of the sale of their Personal Information and sharing of Personal Information for cross-context behavioral advertising. If you would like to opt out of sales and sharing of Personal Information taking place via cookies and pixels, you will need to click [here](link) and opt out of cookies by using the “Cookie Consent Tool” for each ZJ3 website you visit. We also accept certain opt-out preference signals sent from your browser that will opt you out of the sale and sharing of your Personal Information. Depending on how you have interacted with our services and our ability to identify you, this may only opt you out of sales and sharing that take place via cookies.
Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to limit our use and disclosure of sensitive Personal Information to uses that are reasonably necessary to perform services, provide goods to you, or as otherwise permitted by CCPA.
Right to Non-Discrimination. California consumers have the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA.
Metrics About Our Responses to CCPA Requests. To view information about the CCPA rights requests that ZJ3 received in the previous calendar year, please click [here](link).
**B. California Notice of Financial Incentive**
In certain instances, ZJ3 offers benefits that may qualify as financial incentive programs (“FIP”) under California law. California consumers who opt in to the FIP may withdraw from the FIP at any time by contacting ZJ3 [here](link). Participation in an FIP is voluntary. If you choose to participate in an FIP, ZJ3 may retain, use and/or disclose Personal Information it may have collected about you as described in this Privacy Policy, including identifiers, personal records, commercial information, internet or other electronic network activity information, geolocation data, characteristics of protected classifications (age and gender), and inferences. ZJ3 is required to explain how the value you receive from the FIP is reasonably related to the value that we receive from the Personal Information you provide to ZJ3. For the Wheel Watcher’s Club (“WWC”), in exchange for the benefits described [here](link), ZJ3 uses the Personal Information you provide to send sponsored emails and display ads which
, in ZJ3’s good-faith estimation, generate average revenue per member during the lifetime of membership that reasonably correlates to the benefits you receive that may include: multiple chances to win monetary prizes and other prizes in our giveaways, exclusive offers from ZJ3’s prize providers and partners, discounts at the Wheel of Fortune eStore, news about Wheel of Fortune hosts, contestants and the show, messages from the hosts, and details about how to apply to be a contestant.
**C. California’s “Shine the Light” Law**
ZJ3 only knowingly shares personal information (as defined by California’s “Shine the Light” law), with non-affiliated third parties (i.e., parties other than ZJ3 group companies except as otherwise required by applicable law) for their own direct marketing purposes if you specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out, to such sharing at the time you provide personal information or choose to participate in a feature on the Service. If you do not opt in or if you opt-out at that time, ZJ3 will not knowingly share the personal information that was collected in connection therewith with such identified non-affiliated third party(ies) (or ZJ3 group companies where required by applicable law) for its/their own direct marketing purposes, but may continue to seek your consent to sharing with the same or other non-affiliated third parties (or ZJ3 group companies where required by applicable law) for their own direct marketing purposes from time-to-time. Each consent notice and opportunity will be treated separately so it is possible that you may consent to some sharing but not to others.
In addition, California residents may request information about ZJ3’s compliance with the Shine the Light law and the ZJ3 group companies with which ZJ3 may have shared personal information for their direct marketing purposes by contacting ZJ3 [here](link) or by sending a letter to Zeitsight JE3 Ltd Inc. at 10202 W. Washington, Jimmy Stewart Building, Culver City, CA 90232 (Attention: Privacy Program, Ethics & Legal Compliance Department). Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that ZJ3 is only required to respond to one such request per customer each year, and ZJ3 is not required to respond to requests made by means other than through the provided e-mail address or mail address.
**6. PRIVACY RIGHTS FOR CONSUMERS IN COVERED STATES OTHER THAN CALIFORNIA**
If you are a consumer who lives in Colorado, Connecticut, or Virginia (“Covered States”), you have the right to submit certain requests relating to your Personal Information as described below. Please click [here](link) or contact us [here](link) to submit requests for deletion, access, correction or appeals, or [here](link) to opt out of targeted advertising. Please note that we may need to authenticate your identity before your request can be processed. For authentication, you may be asked to log into your account or to provide certain Personal Information that we will match against our records.
Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and our purposes for processing it.
Right to Delete. You have the right to request that we delete your Personal Information, subject to certain exceptions.
Right to Access and Data Portability. You have the right to confirm whether we are processing your Personal Information, to access your Personal Information, and to obtain a copy of Personal Information you provided to us in a portable format.
Right to Opt Out. You have the right to opt out of the following uses of your Personal Information: (a) targeted advertising; (b) the sale of Personal Information; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. ZJ3 does not sell Personal Information for money and does not profile individuals in furtherance of decisions that produce legal or similarly significant effects under applicable state privacy laws. To opt out of targeted advertising and/or non-monetary “sales” of Personal Information, please use the links provided above. If you are an authorized agent submitting an opt-out request on behalf of a consumer where allowed by law, please follow the instructions provided above and within our webform. We use commercially reasonable efforts to authenticate the identity of the consumer to whom the request relates and the authorized agent’s authority to act on the consumer’s behalf.
Right to Appeal. Sometimes we are unable to process requests relating to your Personal Information, in which case, your request will be denied. If you are a resident of a Covered State whose privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request [here](link).
Information for Nevada Residents. Nevada law provides residents the right to opt out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, telephone number, email address, and other information through which a person may be contacted. Our uses of your covered information are not sales under Nevada law. If you have any questions or if you would like to receive notice by email in the event we should engage in “sales” of covered information under Nevada law in the future, please contact us using the contact information provided below.
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**7. DATA SECURITY**
ZJ3 takes reasonable measures to protect Personal Information we collect from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and online digital storage are not completely secure and ZJ3 cannot guarantee the security of your information collected through the Service.
**8. INTERNATIONAL TRANSFER**
ZJ3 is based in the United States. If you are using our Service outside the United States, please be aware that information we obtain about you may be transferred to and processed in the United States or other jurisdictions outside your own, and may be accessed by the courts, law enforcement and national security authorities in those jurisdictions. By using our Service or otherwise providing your Personal Information to us, you acknowledge and consent to the international transfer and processing of your Personal Information as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your Personal Information transferred to the United States or other countries may be different from the laws in your country. For our international Privacy Policies, please click [here](link).
**9. CHILDREN’S PRIVACY**
ZJ3 does not knowingly collect Personal Information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. For more information, please see our Children’s Privacy Policy, which is incorporated into this Privacy Policy by reference. If you are a parent or guardian and believe ZJ3 has collected Personal Information from a child in a manner not permitted by COPPA, please contact ZJ3 [here](link) and ZJ3 will remove such data to the extent required by COPPA.
Any California residents under the age of eighteen (18) who have registered to use the Service, and who have posted content or information on the Service, can request removal by contacting ZJ3 [here](link), detailing where the content or information is posted and attesting that you posted it. ZJ3 will then make reasonable, good faith efforts to remove the post from proZJ3ctive public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that ZJ3 does not control.
**10. YOUR CHOICES**
**A. Accessing and Changing Information**
If you have registered an account with ZJ3, ZJ3 provides you with tools and account settings to access, correct, delete, or modify certain information associated with your account. ZJ3 will make good faith efforts to make such requested changes in ZJ3’s then-active databases as soon as practicable. Further, we reserve the right to retain data as required by applicable law, and for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
**B. Choices About Tracking Technologies**
– **Tracking Technologies Generally:** Cookies and tracking pixels, among other Tracking Technologies, may generally be blocked, disabled, or removed by tools available as part of most browsers. You can also manage the use of some Tracking Technologies such as cookies and tracking pixels by using ZJ3’s Cookie Consent Tool. Please be aware that each website uses its own cookies, so cookie preferences should be set for each ZJ3 website. If you choose to use our Cookie Consent Tool, a preference cookie will be placed on your device in order to maintain your settings. If you later delete cookies from your device, you will also remove the preference cookie. Therefore, in order to remain opted out of Tracking technologies, you will have to go back to the Cookie Consent Tool and renew your choices.
– **Do-Not-Track Signals:** Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus as to what “Do Not Track” means in this context. Like many online services, ZJ3 currently does not alter its practices when it receives a “Do Not Track” signal from a browser.
– **Analytics and Advertising:** In addition to exercising your choices through our Cookie Consent Tool, you may exercise choices regarding the use of cookies from Google Analytics by going to [https://tools.google.com/dlpage/gaoptout](https://tools.google.com/dlpage/gaoptout) or downloading the Google Analytics Opt-out Browser Add-on. You can personalize the ads you receive or opt out of ads from Google by visiting the Google Ads Settings page. You may exercise choices regarding the use of cookies from Microsoft by going to [http://privacy.microsoft.com/en-us/privacystatement](http://privacy.microsoft.com/en-us/privacystatement). You may choose whether to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising online, visit [http://www.aboutads.info/choices/](http://www.aboutads.info/choices/), and [http://www.aboutads.info/appchoices](http://www.aboutads.info/appchoices) for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see [http://www.networkadvertising.org/choices/](http://www.networkadvertising.org/choices/). Opting out does not mean that you will no longer receive ads, but that the ads you see will no longer be relevant to your preferences. Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or browser, or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-outs may not, or may no longer be effective.
– **Mobile Apps:** With reZJ3ct to ZJ3’s mobile apps, you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device.
**C. Choices About Communications**
You can opt out of receiving certain promotional communications (emails or text messaging) from ZJ3 at any time by: (i) for promotional emails, clicking on the unsubscribe link and following the instructions provided, or changing your communication preferences within your account settings; and (ii) for text messages, following the instructions provided in text messages from ZJ3 (i.e., text the word, “STOP”). Please note that your opt-out is limited to the email address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other types of communications may continue. Even if you opt-out of receiving all promotional communications, ZJ3 may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or ZJ3’s ongoing relationship with you.
**11. CHANGES TO THIS PRIVACY POLICY**
ZJ3 reserves the right to revise this Privacy Policy at any time. Any changes will be effective upon the posting of the revised Privacy Policy unless otherwise stated. Your continued use of the Service indicates your consent to the Privacy Policy then posted. If you do not agree, please discontinue use of the Service and uninstall Service downloads and applications.
**12. CONTACT ZJ3
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If you have any questions about this Privacy Policy, please contact ZJ3 [here](link) or at Zeitsight JE3 Ltd Inc. 10202 W. Washington, Jimmy Stewart Building, Culver City, CA 90232 (Attention: Privacy Officer).
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