Privacy Policy

Effective date:06/01/2022

1. Introduction

Welcome to Evolve Bits Inc.

Evolve Bits Inc. (“us”, “we”, or“our”) operates www.zenskar.com (hereinafter referred to as “Service”).

Our Privacy Policy governs your visitto www.zenskar.com, and explains how we collect, safeguard and discloseinformation that results from your use of our Service.

We use your data to provide and improveService. By using Service, you agree to the collection and use of informationin accordance with this policy. Unless otherwise defined in this PrivacyPolicy, the terms used in this Privacy Policy have the same meanings as in ourTerms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of our Serviceand together with the Privacy Policy constitutes your agreement with us (“agreement”).

2. Definitions

SERVICE means the www.zenskar.comwebsite operated by Evolve Bits Inc.

PERSONALDATA means dataabout a living individual who can be identified from those data (or from thoseand other information either in our possession or likely to come into ourpossession).

USAGEDATA is datacollected automatically either generated by the use of Service or from Serviceinfrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on yourdevice (computer or mobile device).

DATACONTROLLER means a natural or legal person who (either aloneor jointly or in common with other persons) determines the purposes for whichand the manner in which any personal data are, or are to be, processed. For thepurpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) meansany natural or legal person who processes the data on behalf of the DataController. We may use the services of various Service Providers in order toprocess your data more effectively.

DATA SUBJECT is any living individual who is thesubject of Personal Data.

THE USER is the individual using our Service. TheUser corresponds to the Data Subject, who is the subject of Personal Data.

3. InformationCollection and Use

We collect several different types ofinformation for various purposes to provide and improve our Service to you.

4. Typesof Data Collected

Personal Data

While using our Service, we may ask youto provide us with certain personally identifiable information that can be usedto contact or identify you (“PersonalData”). Personally identifiable information may include, but is not limitedto:

(a) Email address

(b) First name and last name

(d) Address, State, Province, ZIP/Postalcode, City

(e) Cookies and Usage Data

We may use your Personal Data to contactyou with newsletters, marketing or promotional materials and other informationthat may be of interest to you. You may opt out of receiving any, or all, ofthese communications from us by following the unsubscribe link.

Usage Data

We may also collect information thatyour browser sends whenever you visit our Service or when you access Service byor through a mobile device (“Usage Data”).

This Usage Data may include informationsuch as your computer's Internet Protocol address (e.g. IP address), browsertype, browser version, the pages of our Service that you visit, the time anddate of your visit, the time spent on those pages, unique device identifiersand other diagnostic data.

When you access Service with a mobiledevice, this Usage Data may include information such as the type of mobiledevice you use, your mobile device unique ID, the IP address of your mobiledevice, your mobile operating system, the type of mobile Internet browser youuse, unique device identifiers and other diagnostic data.

LocationData

We may use and store information aboutyour location if you give us permission to do so (“Location Data”). We use this data to provide features of ourService, to improve and customize our Service.

You can enable or disable locationservices when you use our Service at any time by way of your device settings.

TrackingCookies Data

We use cookies and similar trackingtechnologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount ofdata which may include an anonymous unique identifier. Cookies are sent to yourbrowser from a website and stored on your device. Other tracking technologiesare also used such as beacons, tags and scripts to collect and trackinformation and to improve and analyze our Service.

You can instruct your browser to refuseall cookies or to indicate when a cookie is being sent. However, if you do notaccept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

(a) SessionCookies: We useSession Cookies to operate our Service.

(b) PreferenceCookies: We usePreference Cookies to remember your preferences and various settings.

(d) AdvertisingCookies: AdvertisingCookies are used to serve you with advertisements that may be relevant to youand your interests.

Other Data

While using our Service, we may alsocollect the following information: sex, age, date of birth, place of birth,passport details, citizenship, registration at place of residence and actualaddress, telephone number (work, mobile), details of documents on education,qualification, professional training, employment agreements, non-disclosureagreements, information on bonuses and compensation, information on maritalstatus, family members, social security (or other taxpayer identification)number, office location and other data.

5. Use of Data

EvolveBits Inc. uses the collected data for various purposes:

(a) to provide and maintain our Service;

(b) to notify you about changes to ourService;

(d) to provide customer support;

(e) to gather analysis or valuableinformation so that we can improve our Service;

(f) tomonitor the usage of our Service;

(g) to detect, prevent and address technicalissues;

(h) to fulfill any other purpose for whichyou provide it;

(i) tocarry out our obligations and enforce our rights arising from any contractsentered into between you and us, including for billing and collection;

(j) toprovide you with notices about your account and/or subscription, includingexpiration and renewal notices, email-instructions, etc.;

(k) toprovide you with news, special offers and general information about othergoods, services and events which we offer that are similar to those that youhave already purchased or enquired about unless you have opted not to receivesuch information;

(l) inany other way we may describe when you provide the information;

(m) for any other purpose with your consent.

6. Retention of Data

We will retain your Personal Data onlyfor as long as is necessary for the purposes set out in this Privacy Policy. Wewill retain and use your Personal Data to the extent necessary to comply withour legal obligations (for example, if we are required to retain your data tocomply with applicable laws), resolve disputes, and enforce our legalagreements and policies.

We will also retain Usage Data forinternal analysis purposes. Usage Data is generally retained for a shorterperiod, except when this data is used to strengthen the security or to improvethe functionality of our Service, or we are legally obligated to retain thisdata for longer time periods.

7. Transferof Data

Your information, including PersonalData, may be transferred to – and maintained on – computers located outside ofyour state, province, country or other governmental jurisdiction where the dataprotection laws may differ from those of your jurisdiction.

If you are located outside United Statesand choose to provide information to us, please note that we transfer the data,including Personal Data, to United States and process it there.

Your consent to this Privacy Policyfollowed by your submission of such information represents your agreement tothat transfer.

Evolve Bits Inc. will take all thesteps reasonably necessary to ensure that your data is treated securely and inaccordance with this Privacy Policy and no transfer of your Personal Data will takeplace to an organisation or a country unless there are adequate controls inplace including the security of your data and other personal information.

8. Disclosureof Data

We may disclose personal informationthat we collect, or you provide:

(a) Disclosurefor Law Enforcement.

Under certain circumstances, we may berequired to disclose your Personal Data if required to do so by law or inresponse to valid requests by public authorities.

(b) BusinessTransaction.

If we or our subsidiaries are involvedin a merger, acquisition or asset sale, your Personal Data may be transferred.

(i) toour subsidiaries and affiliates;

(ii) tocontractors, service providers, and other third parties we use to support ourbusiness;

(iii) to fulfill the purpose for which youprovide it;

(iv) for the purpose of including yourcompany’s logo on our website;

(v) forany other purpose disclosed by us when you provide the information;

(vi) with your consent in any other cases;

(vii) if we believe disclosure is necessary orappropriate to protect the rights, property, or safety of the Company, ourcustomers, or others.

9. Securityof Data

The security of your data is importantto us but remember that no method of transmission over the Internet or methodof electronic storage is 100% secure. While we strive to use commerciallyacceptable means to protect your Personal Data, we cannot guarantee itsabsolute security.

10. YourData Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the EuropeanUnion (EU) and European Economic Area (EEA), you have certain data protectionrights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj

We aim to take reasonable steps to allowyou to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what PersonalData we hold about you and if you want it to be removed from our systems,please email us at contact@zenskar.com.

In certain circumstances, you have thefollowing data protection rights:

(a) the right to access, update or to deletethe information we have on you;

(b) the right of rectification. You have theright to have your information rectified if that information is inaccurate orincomplete;

(d) the right of restriction. You have theright to request that we restrict the processing of your personal information;

(e) the right to data portability. You havethe right to be provided with a copy of your Personal Data in a structured,machine-readable and commonly used format;

(f) theright to withdraw consent. You also have the right to withdraw yourconsent at any time where we rely on your consent to process your personalinformation;

Please note that we may ask you toverify your identity before responding to such requests. Please note, we maynot able to provide Service without some necessary data.

You have the right to complain to a DataProtection Authority about our collection and use of your Personal Data. Formore information, please contact your local data protection authority in theEuropean Economic Area (EEA).

11. YourData Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in thenation to require commercial websites and online services to post a privacypolicy. The law’s reach stretches well beyond California to require a person orcompany in the United States (and conceivable the world) that operates websitescollecting personally identifiable information from California consumers topost a conspicuous privacy policy on its website stating exactly theinformation being collected and those individuals with whom it is being shared,and to comply with this policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/

According to CalOPPA we agree to thefollowing:

(a) users can visit our site anonymously;

(b) our Privacy Policy link includes theword “Privacy”, and can easily be found on the page specified above on the homepage of our website;

(d) users are able to change their personalinformation by emailing us at contact@zenskar.com.

OurPolicy on “Do Not Track” Signals:

Wehonor Do Not Track signals and do not track, plant cookies, or use advertisingwhen a Do Not Track browser mechanism is in place. Do Not Track is a preferenceyou can set in your web browser to inform websites that you do not want to betracked.

Youcan enable or disable Do Not Track by visiting the Preferences or Settings pageof your web browser.

12. YourData Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, youare entitled to learn what data we collect about you, ask to delete your dataand not to sell (share) it. To exercise your data protection rights, you canmake certain requests and ask us:

(a) What personal information we have aboutyou. If you make thisrequest, we will return to you:

(i) Thecategories of personal information we have collected about you.

(ii) Thecategories of sources from which we collect your personal information.

(iii) The business or commercial purpose forcollecting or selling your personal information.

(iv) The categories of third parties withwhom we share personal information.

(v) Thespecific pieces of personal information we have collected about you.

(vi) A list of categories of personalinformation that we have sold, along with the category of any other company wesold it to. If we have not sold your personal information, we will inform youof that fact.

(vii) A list of categories of personalinformation that we have disclosed for a business purpose, along with thecategory of any other company we shared it with.

Please note, you are entitled to ask usto provide you with this information up to two times in a rolling twelve-monthperiod. When you make this request, the information provided may be limited tothe personal information we collected about you in the previous 12 months.

(b) Todelete your personal information.If you make this request, we will delete the personal information we hold aboutyou as of the date of your request from our records and direct any serviceproviders to do the same. In some cases, deletion may be accomplished throughde-identification of the information. If you choose to delete your personalinformation, you may not be able to use certain functions that require yourpersonal information to operate.

(c) Tostop selling your personal information.We do not sell your personal information for monetary consideration. However,under some circumstances, a transfer of personal information to a third party,or within our family of companies, without monetary consideration may beconsidered a “sale” under California law.

If you submit a request to stop sellingyour personal information, we will stop making such transfers. If you are aCalifornia resident, to opt-out of the sale of your personal information, click“Do Not Sell My Personal Information” at the bottom of our home page to submityour request.

Please note, if you ask us to delete orstop selling your data, it may impact your experience with us, and you may notbe able to participate in certain programs or membership services which requirethe usage of your personal information to function. But in no circumstances, wewill discriminate against you for exercising your rights.

To exercise your California dataprotection rights described above, please send your request(s) by one of thefollowing means:

By email: contact@zenskar.com

By visiting this page on our website:www.zenskar.com

Your dataprotection rights, described above, are covered by the CCPA, short for theCalifornia Consumer Privacy Act. To find out more, visit the official California Legislative Informationwebsite. The CCPA tookeffect on 01/01/2020.

13. ServiceProviders

We may employ third party companies andindividuals to facilitate our Service (“ServiceProviders”), provide Service on our behalf, perform Service-relatedservices or assist us in analysing how our Service is used.

These third parties have access to yourPersonal Data only to perform these tasks on our behalf and are obligated notto disclose or use it for any other purpose.

14. Analytics

We may use third-party Service Providersto monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analyticsservice offered by Google that tracks and reports website traffic. Google usesthe data collected to track and monitor the use of our Service. This data isshared with other Google services. Google may use the collected data tocontextualise and personalise the ads of its own advertising network.

For more information on the privacypractices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

We also encourage you to review theGoogle's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

15. CI/CDtools

Wemay use third-party Service Providers to automate the development process ofour Service.

GitHub

GitHub is provided by GitHub, Inc.

GitHub is a development platform to hostand review code, manage projects, and build software.

For more information on what data GitHubcollects for what purpose and how the protection of the data is ensured, pleasevisit GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.

16. Advertising

We may use third-party Service Providersto show advertisements to you to help support and maintain our Service.

Google AdSense DoubleClick Cookie

Google,as a third party vendor, uses cookies to serve ads on our Service. Google's useof the DoubleClick cookie enables it and its partners to serve ads to our usersbased on their visit to our Service or other websites on the Internet.

Youmay opt out of the use of the DoubleClick Cookie for interest-based advertisingby visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

17. Behavioral Remarketing

Evolve Bits Inc. uses remarketingservices to advertise on third party websites to you after you visited ourService. We and our third-party vendors use cookies to inform, optimise andserve ads based on your past visits to our Service.

Google Ads (AdWords)

GoogleAds (AdWords) remarketing service is provided by Google Inc.

Youcan opt-out of Google Analytics for Display Advertising and customize theGoogle Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Googlealso recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. GoogleAnalytics Opt-out Browser Add-on provides visitors with the ability to preventtheir data from being collected and used by Google Analytics.

Formore information on the privacy practices of Google, please visit the GooglePrivacy Terms web page: https://policies.google.com/privacy?hl=en

Bing Ads Remarketing

BingAds remarketing service is provided by Microsoft Inc.

Youcan opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Youcan learn more about the privacy practices and policies of Microsoft byvisiting their Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement

Twitter

Twitterremarketing service is provided by Twitter Inc.

Youcan opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

Youcan learn more about the privacy practices and policies of Twitter by visitingtheir Privacy Policy page: https://twitter.com/privacy

Facebook

Facebookremarketing service is provided by Facebook Inc.

Youcan learn more about interest-based advertising from Facebook by visiting thispage: https://www.facebook.com/help/164968693837950

Toopt-out from Facebook's interest-based ads, follow these instructions fromFacebook: https://www.facebook.com/help/568137493302217

Facebookadheres to the Self-Regulatory Principles for Online Behavioural Advertisingestablished by the Digital Advertising Alliance. You can also opt-out fromFacebook and other participating companies through the Digital AdvertisingAlliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance ofCanada in Canada http://youradchoices.ca/ or the European Interactive DigitalAdvertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile devicesettings.

Formore information on the privacy practices of Facebook, please visit Facebook'sData Policy: https://www.facebook.com/privacy/explanation

18. Payments

We may provide paid products and/orservices within Service. In that case, we use third-party services for paymentprocessing (e.g. payment processors).

Wewill not store or collect your payment card details. That information isprovided directly to our third-party payment processors whose use of yourpersonal information is governed by their Privacy Policy. These paymentprocessors adhere to the standards set by PCI-DSS as managed by the PCISecurity Standards Council, which is a joint effort of brands like Visa,Mastercard, American Express and Discover. PCI-DSS requirements help ensure thesecure handling of payment information.

The payment processors we work with are:

PayPal orBraintree:

Their Privacy Policy can be viewedat https://www.paypal.com/webapps/mpp/ua/privacy-full

Stripe:

Their Privacy Policy can be viewed at: https://stripe.com/us/privacy

Adyen:

Their Terms and conditions can be viewedat https://www.adyen.com/legal/terms-and-conditions.

19. Linksto Other Sites

Our Service may contain links to othersites that are not operated by us. If you click a third party link, you will bedirected to that third party's site. We strongly advise you to review thePrivacy Policy of every site you visit.

Wehave no control over and assume no responsibility for the content, privacy policiesor practices of any third party sites or services.

20. Children's Privacy

Our Services are notintended for use by children under the age of 13 (“Children”).

We do not knowingly collect personallyidentifiable information from Children under 13. If you become aware that aChild has provided us with Personal Data, please contact us. If we become awarethat we have collected Personal Data from Children without verification ofparental consent, we take steps to remove that information from our servers.

21. Changesto This Privacy Policy

We may update our Privacy Policy fromtime to time. We will notify you of any changes by posting the new PrivacyPolicy on this page.

We will let you know via email and/or aprominent notice on our Service, prior to the change becoming effective andupdate “effective date” at the top of this Privacy Policy.

You are advised to review this PrivacyPolicy periodically for any changes. Changes to this Privacy Policy areeffective when they are posted on this page.

22. ContactUs

If you have any questions about thisPrivacy Policy, please contact us:

By email: contact@zenskar.com.

Privacy Policy

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