ZAMDA PRIVACY POLICY

Effective Date: December 31, 2025

This Privacy Policy describes how Zamda LLC ("Zamda," "we," "us," or "our") collects, uses, discloses, and protects your personal information when you use our online marketplace platform and related services (collectively, the "Service"). This Privacy Policy applies to information we collect through our website, mobile applications, and any other platforms we operate. By using the Service, you consent to the data practices described in this Privacy Policy. We are committed to protecting your privacy and complying with applicable data protection laws, including the California Consumer Privacy Act ("CCPA"), the California Privacy Rights Act ("CPRA"), the Children's Online Privacy Protection Act ("COPPA"), and other relevant federal and state privacy regulations.

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly

When you register for an account, create listings, communicate with other users, or use our Service, we collect information that you provide directly to us, including:

(a) Account Information: Name, email address, phone number, username, password, date of birth, and profile information;
(b) Listing Information: Product or service descriptions, titles, categories, prices, photos, videos, location information, and any other content you post in your listings;
(c) Communication Data: Messages, inquiries, reviews, ratings, feedback, and other communications you send through our messaging system or customer support channels;
(d) Payment Information: If you engage in paid transactions, we or our payment processors collect payment card information, billing address, and transaction details;
(e) Verification Information: Government-issued ID, business licenses, or other documents you provide for identity or business verification purposes;
(f) Other Information: Any other information you choose to provide, such as preferences, interests, or survey responses.

1.2 Information Collected Automatically

When you access or use our Service, we automatically collect certain information about your device and usage, including:

(a) Device Information: IP address, device type, operating system, browser type, mobile network information, device identifiers (such as IDFA or Android Advertising ID), and hardware model;
(b) Usage Information: Pages or content you view, searches you conduct, listings you view or save, time and date of access, time spent on pages, clickstream data, and other usage statistics;
(c) Location Information: Precise or approximate geographic location derived from your IP address, GPS, WiFi, or cellular network data (with your consent where required by law);
(d) Cookies and Tracking Technologies: We use cookies, web beacons, pixel tags, local storage, and similar technologies to collect information about your browsing behavior and preferences. See Section 8 for more details.

1.3 Information from Third Parties

We may receive information about you from third-party sources, including:

(a) Social Media Platforms: If you link your account to a social media platform (e.g., Facebook, Google), we may receive information from that platform, such as your name, email address, profile picture, and friend list;
(b) Identity Verification Services: Information obtained from identity verification, fraud prevention, or background check services;
(c) Analytics Providers: Aggregated or de-identified information from analytics and advertising partners;
(d) Public Databases: Publicly available information from government databases, directories, or other public sources.

1.4 Children's Information

Our Service is not directed to children under 13 years of age, and we do not knowingly collect personal information from children under 13 without verifiable parental consent in compliance with COPPA. If we learn that we have collected personal information from a child under 13 without proper consent, we will promptly delete such information. If you believe a child under 13 has provided us with personal information, please contact us at privacy@zamda.net.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

(a) Provide and Improve the Service: To operate, maintain, personalize, and improve our marketplace platform, including creating and managing your account, processing listings, facilitating communications between buyers and sellers, and enhancing user experience;
(b) Communications: To send you service-related notifications, updates, security alerts, account information, promotional materials, newsletters, and other communications. You may opt-out of marketing communications at any time;
(c) Transactions: To process payments, prevent fraud, verify your identity, and facilitate transactions between users;
(d) Safety and Security: To detect, prevent, and address fraud, abuse, security risks, technical issues, violations of our Terms of Use, and illegal activities;
(e) Customer Support: To respond to your inquiries, provide customer support, and resolve disputes; (f) Analytics and Research: To analyze usage patterns, conduct research, measure the effectiveness of our Service, and develop new features and services;
(g) Advertising and Marketing: To display personalized advertisements, measure ad performance, and conduct targeted marketing campaigns based on your interests and behavior;
(h) Legal Compliance: To comply with applicable laws, regulations, legal processes, governmental requests, court orders, and enforce our Terms of Use and other policies;
(i) Business Transfers: In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, we may transfer your information to a successor entity.

3. HOW WE SHARE YOUR INFORMATION

We may share your personal information with third parties in the following circumstances:

3.1 With Other Users

When you create a listing or communicate with other users, certain information (such as your username, profile information, listing details, and messages) will be visible to other users of the Service. Your contact information may be shared with users you engage with for transaction purposes.

3.2 Service Providers

We share information with third-party service providers who perform services on our behalf, including payment processors, hosting providers, email delivery services, analytics providers, advertising partners, customer support platforms, identity verification services, fraud prevention services, and IT security providers. These service providers are contractually obligated to use your information only for the purposes of providing services to us and to protect your information in accordance with this Privacy Policy.

3.3 Legal and Safety Reasons

We may disclose your information to law enforcement, government authorities, or other third parties when we believe in good faith that disclosure is necessary to: (a) comply with a legal obligation, court order, subpoena, or governmental request; (b) enforce our Terms of Use or other agreements; (c) protect the rights, property, or safety of Zamda, our users, or the public; (d) detect, prevent, or address fraud, security, or technical issues; or (e) prevent harm or illegal activity.

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, bankruptcy, or similar business transaction, your information may be transferred to the acquiring or successor entity. We will provide notice if your information becomes subject to a different privacy policy.

3.5 With Your Consent

We may share your information with third parties when you provide explicit consent or direct us to do so.

3.6 Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you with third parties for analytics, research, marketing, or other business purposes.

4. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The retention period depends on the type of information and the purposes for which we use it. For example:

(a) Account information is retained as long as your account is active, plus a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements;
(b) Transaction records and payment information are retained for a minimum of seven (7) years to comply with tax, accounting, and financial regulations;
(c) Communications, support tickets, and dispute records are retained for a reasonable period to provide customer service and resolve issues;
(d) Marketing data is retained until you opt-out or we determine it is no longer necessary;
(e) When you delete your account, we will delete or anonymize your personal information within ninety (90) days, except where we are required to retain it for legal, regulatory, or safety purposes.

5. YOUR RIGHTS AND CHOICES

5.1 Access and Portability

You have the right to access and obtain a copy of your personal information that we hold. You may request a portable copy of your data in a commonly used electronic format.

5.2 Correction

You have the right to correct inaccurate or incomplete personal information. You can update your account information directly through your account settings or by contacting us.

5.3 Deletion

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., legal obligations, fraud prevention, security purposes). To delete your account and associated data, please contact us at privacy@zamda.net. Please note that some information may remain in backup copies for a reasonable period.

5.4 Opt-Out of Marketing

You may opt-out of receiving promotional emails by clicking the "unsubscribe" link in any marketing email or by adjusting your account notification preferences. Please note that even if you opt-out of marketing communications, we may still send you transactional or service-related messages.

5.5 Do Not Sell or Share My Personal Information

We do not sell your personal information to third parties for monetary consideration. However, under California law, sharing information for targeted advertising may be considered a "sale" or "sharing." You have the right to opt-out of such sharing. To exercise this right, please visit our Privacy Center or contact us at privacy@zamda.net. We do not sell or share personal information of individuals under 16 years of age without affirmative authorization.

5.6 Limit Use of Sensitive Personal Information

California residents have the right to limit the use and disclosure of sensitive personal information to purposes necessary to provide the Service. To exercise this right, please contact us at privacy@zamda.net.

6. CALIFORNIA CONSUMER PRIVACY RIGHTS

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

(a) Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and sell about you;
(b) Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions;
(c) Right to Correct: You have the right to request correction of inaccurate personal information;
(d) Right to Opt-Out: You have the right to opt-out of the sale or sharing of your personal information;
(e) Right to Limit: You have the right to limit the use and disclosure of sensitive personal information;
(f) Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

How to Exercise Your Rights:

To exercise any of the above rights, please submit a verifiable consumer request by:
(a) Emailing us at privacy@zamda.net;
(b) Visiting our Privacy Center on our website;
(c) Calling us at the phone number provided on our website (if available).

We will verify your identity before processing your request. You may designate an authorized agent to make a request on your behalf by providing written authorization. We will respond to verifiable requests within forty-five (45) days, with a possible extension of an additional forty-five (45) days if necessary.

7. SECURITY OF YOUR INFORMATION

We implement reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

(a) Encryption of data in transit using SSL/TLS protocols;
(b) Encryption of sensitive data at rest;
(c) Regular security assessments and vulnerability testing;
(d) Access controls and authentication mechanisms;
(e) Employee training on data security and privacy practices;
(f) Incident response and breach notification procedures.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activities that occur under your account.

8. COOKIES AND TRACKING TECHNOLOGIES

We use cookies, web beacons, pixel tags, local storage, and similar tracking technologies to collect information about your browsing behavior and preferences. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and improve your user experience.

Types of Cookies We Use:

(a) Essential Cookies: Necessary for the operation of our Service, such as authentication, security, and session management;
(b) Performance Cookies: Collect information about how you use our Service to help us improve functionality and performance;
(c) Functional Cookies: Remember your preferences and settings to provide a personalized experience;
(d) Advertising Cookies: Used to deliver targeted advertisements based on your interests and browsing behavior.

Managing Cookies:

You can control or delete cookies through your browser settings. Most browsers allow you to refuse or accept cookies, delete existing cookies, and set preferences for certain websites. Please note that disabling cookies may affect the functionality of our Service. For more information about managing cookies, visit your browser's help section or www.aboutcookies.org.

Third-Party Analytics and Advertising:

We use third-party analytics services (such as Google Analytics) and advertising platforms (such as Google Ads, Facebook Ads) to collect usage data and display personalized advertisements. These third parties may use cookies and similar technologies to track your activities across websites and over time. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout. To opt-out of interest-based advertising, visit www.aboutads.info/choices or www.networkadvertising.org/choices.

9. INTERNATIONAL DATA TRANSFERS

Our Service is operated in the United States. If you are located outside the United States, please be aware that information we collect will be transferred to, processed, and stored in the United States, where data protection laws may differ from those in your country. By using our Service, you consent to the transfer of your information to the United States and its processing in accordance with this Privacy Policy and applicable U.S. laws.

10. THIRD-PARTY LINKS AND SERVICES

Our Service may contain links to third-party websites, services, or applications that are not owned or controlled by Zamda. This Privacy Policy does not apply to third-party websites or services. We are not responsible for the privacy practices or content of third parties. We encourage you to review the privacy policies of any third-party websites or services you visit..

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational, legal, or regulatory reasons. When we make changes, we will update the "Effective Date" at the top of this Privacy Policy and post the revised policy on our Service. If we make material changes, we will provide additional notice, such as by email or through a prominent notice on our Service. Your continued use of the Service after the effective date of the revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically.

11. CHANGES TO THIS PRIVACY POLICY

12. CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

CONTACT:

Sacramento, California, USA
E-mail: support@zamda.net

ZAMDA LLC

BY USING ZAMDA, YOU AGREE TO COMPLY WITH THIS POLICY. VIOLATIONS = ACCOUNT TERMINATION.