ZERO&

ZERO& Mobile App Privacy Policy

 Last modified: July 1, 2021

Introduction

Fuji INC. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

·      The types of information we may collect or that you may provide when you download, install, register with, access, or use the mobile application of ZERO& (the “App”).

·      Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in this App and in email, text, and other electronic communications sent through or in connection with this App.

This policy DOES NOT apply to information that:

·      We collect offline or on any other Company apps or websites, including websites you may access through this App.

·      You provide to or is collected by any third party (see the Section titled Third-Party Information Collection below).

·      Becomes available from other sources, including:

·      Social media networks;

·      Online advertising companies;

·      Service providers who help us with third-party identity verification, credit confirmation and fraud detection;

·      Credit bureaus and financial institutions;

·      Mailing list providers; and

·      Publicly available sources.

Our websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time (see the Section titled Changes to Our Privacy Policy below). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Children Under the Age of 13

The App is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@enjoyfuji.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see the Section titled Your California Privacy Rights below for more information.

Information We Collect and How We Collect It

We collect information from and about users of our App:

·      Directly from you when you provide it to us.

·      Automatically when you use the App.

·      Directly from you as part of your communications.

Information You Provide to Us 

When you download, register with, or use this App, we may ask you provide information:

·      By which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”).

·      That is about you but individually does not identify you, such as your age group, location, food preference, purchase and browsing history.

This information includes:

·      Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App, subscribing to our service, posting material, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App.

·      Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

·      Your responses to surveys that we might ask you to complete for research purposes.

·      Details of transactions you carry out through the App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App.

·      Your search queries on the App.

·      Information that you provide to refer a friend or family to use the App, including the name and contact of such referred person.

·      Information that you provide in surveys or contests, in connection to with personal information may be required.

You may also provide information for publication or display (“Posted”) on public areas of the app or websites you access through the App (collectively, “User Contributions“). Your User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection and Tracking

When you download, access, and use the App, it may use technology to automatically collect:

·      Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.

·      Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.

·      Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

·      Location Information. This App collects real-time information about the location of your device. We leverage your location data to provide better user experience, more relevant information and product offerings based on your location.

If you do not want us to collect this information, do not download the App or delete it from your device. For more information, see the Section titled Your Choices About Our Collection, Use, and Disclosure of Your Information below. Note, however, that opting out of the App’s collection of location information will disable its location-based features.

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). See the Section titled Do Not Track Disclosure below for information on how we respond to browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

·      Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.

·     Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Information Received as Part of Communications

When you use the App, complete electronic forms, communicate with merchants or contact us, by online chat, email, phone or text, we may automatically collect and store certain information about you and the activity you engaged in, for example: your name and contact information; your order details; information that you voluntarily provide to us; the nature of your communication; the purpose of the interaction, and the action we took in response to your inquiry or request.

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

·      Advertisers, ad networks, and ad servers.

·      Analytics companies.

·      Your mobile device manufacturer.

·      Your mobile service provider.

·      Your payment service provider.

·      Your identity service provider.

These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the Section titled Your Choices About Our Collection, Use, and Disclosure of Your Information below.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

·      Provide you with the App and its contents, and any other information, products or services that you request from us.

·      Fulfill any other purpose for which you provide it.

·      Give you notices about your account/subscription, including expiration and renewal notices.

·      Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

·      Notify you when App updates are available, and of changes to any products or services we offer or provide though it.

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

·      Estimate our audience size and usage patterns.

·      Store information about your preferences, allowing us to customize our App according to your individual interests.

·      Speed up your searches.

·      Recognize you when you use the App.

For more information, see the Section titled Your Choices About Our Collection, Use, and Disclosure of Your Information below.

We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

·      To our subsidiaries and affiliates.

·      To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

·      To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our App users is among the assets transferred.

·      To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see the Section titled Your Choices About Our Collection, Use, and Disclosure of Your Information below.

·      To fulfill the purpose for which you provide it.

·      For any other purpose disclosed by us when you provide the information.

·      With your consent.

·      To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

·      To enforce our rights arising from any contracts entered into between you and us, including the App EULA and for billing and collection.

·      If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

·      Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.

·      Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may become inaccessible or not function properly.

·      Promotion by the Company. If you do not want us to use your email address, phone number or address to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to privacy@enjoyfuji.com. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@enjoyfuji.com.

·      Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request to privacy@enjoyfuji.com.

·      Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by sending us an email stating your request to privacy@enjoyfuji.com.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see the Section titled Your California Privacy Rights below for more information.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the App and visiting your account profile page.

California residents may have additional personal information rights and choices. Please see the Section titled Your California Privacy Rights below for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights around our collection, use, and sharing of their personal information. If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow us to retain and use certain personal information notwithstanding your deletion request. You can learn more about how to submit a data rights request to privacy@enjoyfuji.com. We will not discriminate against you for exercising your rights under the CCPA.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@enjoyfuji.com.

Do Not Track Disclosure

We do not have a mechanism in place for responding to browser “do not track” signals or other similar mechanisms used to limit collection of information.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

privacy@enjoyfuji.com.