ZCG WEB PRIVACY POLICY

Cookie Disclosure Policy

Effective: May 25, 2018

We collect information during and, occasionally, at other times.

Z Capital Group, L.L.C. (“ZCG”) takes your privacy very seriously. Please carefully read this Privacy Policy and familiarize yourself with our privacy practices regarding your personal information and how we will use it. This Privacy Policy applies to the Our site, including mobile sites or apps (collectively, the “Sites”). By visiting the Sites, you accept this Privacy Policy and Cookie Disclosure Policy, which are hereby incorporated. If you do not agree with these policies, do not use the Sites.

What information we collect

You may be asked to provide your name, email address, mailing address, phone number, and similar information.

Uses and Disclosure of Personal Information

We may use third-party service providers or other third-party organizations helping to support our mission that may collect or store to complete your request, e.g. completing a transaction or to outsource one or more of the functions described above.

Research

We may contract with a market-research firm to conduct occasional online surveys. When you're within our sites, you may see a pop-up window offering you the optional opportunity of participating in a survey. If you do not wish to participate, simply click the "No, Thank You" link and you will not see this window again. If you choose to participate, you'll be prompted to answer a series of online questions. You will be prompted to enter your e-mail address for validation purposes but no other personal information (name, address, etc.) will be collected as part of the survey.

Cookie Technology

We also employ cookie technology to help subscribers move faster through our site. When you use one of our sites, we pass several cookies to your computer. A cookie is a string of information that's sent by a Web site and stored on your hard drive or temporarily in your computer's memory. The cookie is deleted when a user chooses the log out feature to terminate their session. We also employ cookie technology to store subscribers' User Names and Passwords. Read our cookie disclosure statement and view a cookie-by-cookie breakdown.

Some web browsers may transmit “Do Not Track” signals to websites visited by the user. Our information collection and disclosure practices will continue to apply as described in this policy, regardless of any “Do Not Track” signals that are sent by certain browsers.

Third Party Web Sites

Our Sites may contain links to other Web sites provided by third parties. Please be aware that we do not control these third-party Web sites or any of the content contained on those Web sites. Once you have left our Sites, we cannot be responsible for the privacy practices of such other Web sites. We encourage you to exercise caution and to read the privacy policy for the Web site you visit. The inclusion of hyperlinks to third party Web sites on our Sites in no way constitutes an endorsement by us of such Web sites’ content, actions or policies.

Data Storage, Access, and The Right to be Forgotten

We store and process data on our servers in the United States, even though the European Union has not recognized that the United States provides adequate data protection laws. Individuals in the Europe Union have certain data subject rights which may be subject to limitations and/or restrictions. These rights may include the right to: (i) request access to and rectification or erasure of their personal data; (ii) obtain restriction of processing or to object to processing of their personal data; and (iii) the right to data portability. If you wish to exercise one of the above-mentioned rights, please send us your request via email to: compliance@zcg.com. Individuals in Europe may also have the right to file a complaint about the processing of their personal data with their local data protection authority. Please also let us know if you have any questions, concerns, disputes, or issues. Our Data Protection Officer is Martin Auerbach and can be reached at compliance@zcg.com or by physical mail at Financial Times Building, 1330 Avenue of The Americas, 16th Floor, New York, NY 10019.

We store personal data for different periods of time consistent with the purposes for which they were originally collected, as subsequently further authorized, or when required or allowed under applicable law.

We do not subject data subjects to decisions that have legal effects on them due solely to automated processing of personal data.

For United States residents, we undertake marketing only in compliance with the CAN-SPAM Act, the Telephone Consumer Protection Act, and other applicable law. For European Union residents, we undertake marketing only with your expressive affirmative consent and in compliance with applicable data privacy laws. EU residents will not be added to the marketing lists unless they have already provided express affirmative consent consistent with applicable data protection laws.

Security

We are committed to maintaining your confidence and trust, and currently do not collect any personal identifiable information. However, no transmission or electronic storage of information is guaranteed to be secure. We therefore urge you to always use caution when transmitting information over the Internet.

Children

The Sites are not directed toward children under 18 years of age nor do we knowingly collect information from children under 18. If you are under 18, please do not use the Sites or submit any personally identifiable information to us.

Your California Privacy Rights

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year.

Data Controller, Data Protection Officer

We are responsible for your privacy protection. If you have questions regarding our website, the following information, or if you would like to contact our privacy protection representative, please contact us at compliance@zcg.com.

Changes and Updates

We may revise this Privacy Policy from time to time. We will post any changes on this page and update the date at the top, so be sure to check back periodically to stay aware of any modifications. Your continued use of the Sites after changes have been posted will constitute your acceptance of this Privacy Policy and any changes.

Contact Us

If you have any questions, concerns, or suggestions regarding this Privacy Policy, or to update any information you have provided us, please send us an email at compliance@zcg.com.