Privacy Policy

Effective as of February 27, 2025

Virtually Human Studio Pty Ltd and its affiliates, including Virtually Human Inc. (“Zed” or “we”, “our” or “us”) operates the Zed Champions and the Zed Picks platform, which includes the Zed Champions website, the Zed Picks app and website, and all related social media pages (the foregoing, and all content, features, and materials thereon, shall hereinafter be collectively referred to as the “Platforms”). This Privacy Policy describes how Zed in our capacity as a controller, processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our websites located at www.vhslab.com, www.zedchampsions.com and www.zedpicks.com and social media pages) as well as our marketing activities other activities described in this Privacy Policy (collectively, the “Services”).

This policy describes the type of information we collect from you and/or that you may provide us when you visit and/or use this website/other websites operated by us (individually or collectively, “Sites”). “You/your/user(s)” means you as a user of our Sites.

By accessing the Sites, you acknowledge this Privacy Policy and agree to be bound by this Privacy Policy. If there is anything you do not understand, please email any inquiry to support@zedpicks.com. If at any time you do not agree to this Privacy Policy, please do not use the Sites or provide us with any personal information.

We reserve the right to change or update this Privacy Policy by posting such changes or updates to the Sites or emailing you notice of the changes. Amendments to this Privacy Policy will be posted at this URL and will be effective when posted. You can tell if this Privacy Policy has changed by checking the last modified date that appears at the top of this Privacy Policy. Your continued use of the Sites following the posting of any amendment, modification or change shall constitute your acceptance thereof.

At the time we collect personal information, Zed may provide additional or supplemental privacy policies to individuals for specific products or services that we offer.

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Index

  • Personal information we collect
  • Tracking technologies
  • How we use your personal information
  • How we share your personal information
  • Your choices
  • Other sites and services
  • Security
  • International data transfers
  • Children
  • Data Retention
  • Privacy Rights for California residents
  • Privacy Rights for EEA and UK Residents
  • Changes to this Privacy Policy
  • How to contact us

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Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, email address, and mailing address.
  • Demographic data, such as your country of residence.
  • Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, links to your profiles on social networks, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.
  • Gaming data, such as information related to the games that you play including the types and frequency of game played, number of bets, and betting value.
  • Biometric Data, which is data comprised of facial photos, for the purpose of creating avatars (“Avatar(s)”) within our Platform(s). This data may be collected directly from users or generated through their and their device’s interactions with the Platform(s). Biometric Data may be processed to create personalized Avatars that enhance the user experience within the Platform(s). These Avatars may be customizable and used for various in-app activities and interactions. There is no requirement within the Platform(s) to grant us the use of your Biometric Data, as all Platform Avatars are customizable and can be self-created without the use of such Biometric Data.
  • Government-issued identification number data, such as national identification number (e.g., Social Security Number, tax identification number, passport number) and state or local identification number (e.g., driver’s license or state ID number) and an image of the relevant identification card.
  • Payment data needed to complete transactions, including payment card information or bank account number.
  • Communications data based on our exchanges with you, including when you contact us through the service, communicate with us or other players via chat features, social media, or otherwise.
  • Transactional data, such as information relating to or needed to complete your bets on or through the service, including betting history.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Promotion data, including information you share when you enter a sweepstake, competition, promotion or complete a survey. Please note that if you participate in a sweepstake, contest, or giveaway through the service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity, determine your eligibility, and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each game, sweepstakes and contest that you enter.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information that we obtain from other sources, such as:

  • Public sources, such as public records, social media platforms, and other publicly available sources.
  • Data providers such as data licensors.
  • Partners such as marketing partners and event co-sponsors.
  • Service providers that provide services on our behalf or help us operate the service or our business, such as fraud prevention providers, in-app chat providers, and customer support vendors.
  • Third-party services, such as X or Google, that you use to log into, or otherwise link to, your service account.
    • Data obtained from X may include your username, information related to your followers, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. Our use and disclosure of information received from X’s API will adhere to the X Developer Policy available at https://developer.x.com/en/developer-terms/policy.
    • Data obtained from Google may include your Google username profile picture and an authentication token associated with your Google account on that third-party service that is made available to us based on your account settings on that service. Our use of information received from Google’s APIs will adhere to the Google API Services User Data Policy available at https://developers.google.com/terms/api-services-user-data-policy, including the Limited Use requirements. This Privacy Policy will apply to any Google user data that we collect. The Service will only use access to your Google user data to enable to authenticate to the Service. The Service will not use Google user data for serving advertisements. The Service will not allow humans to read your Google user data unless we have your affirmative agreement for doing so, it is necessary for security purposes such as investigating abuse, we do so to comply with applicable law, or the data is aggregated or anonymized.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

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Tracking technologies

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

  • Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site.

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  • Local storage technologies that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.

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  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

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  • Chat technologies that employ cookies and/or software code to operate the chat features that you can use to communicate with us through the service. Such third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy.

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For information concerning your choices with respect to the use of tracking technologies, see the Your Choices section, below.

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How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

  • provide the Service and operate our business;
  • enable security features of the Service;
  • establish and maintain your user profile on the Service;
  • communicate with you about the service, including by sending service-related announcements, updates, security alerts, and support and administrative messages;
  • communicate with you about events or contests in which you participate; and
  • provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

  • understand your needs and interests;
  • personalize your experience with the Service and our Service-related communications; and
  • remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

  • Direct marketing. Subject to applicable law, we may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.
  • Interest-based advertising. We and our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the Tracking technologies section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

Events, promotions and contests. We may use your personal information to:

  • administer promotions, sweepstakes and contests;
  • communicate with you about promotions or contests in which you participate; and
  • contact or market to you after collecting your personal information at an event.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the Service; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the

Cookies and similar technologies described above.

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How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, fraud prevention, interactive gaming providers, information technology, customer support, online chat functionality providers, email delivery, marketing, consumer research and website analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Linked third-party services. If you log into the Service with, or otherwise link your service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financing of Zed, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Zed as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Your profile and other user-generated content data (except for messages) may be visible to other users of the service and the public. For example, other users of the service or the public may have access to your information if you chose to make your profile or other personal information available to them through the service, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

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Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

  • Browser settings. Changing your internet web browser settings to block third-party cookies.
  • Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
  • Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:
    • Google: https://adssettings.google.com/
    • Facebook: https://www.facebook.com/about/ads
  • Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
    • Network Advertising Initiative:

http://www.networkadvertising.org/managing/opt_out.asp

  • Digital Advertising Alliance: optout.aboutads.info.
  • AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
  • Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Other sites and services

The Service may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

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International data transfer

We have offices in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

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Children

The service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Privacy Rights for California residents

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Shine the light law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to support@zedpicks.com. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

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Privacy Rights for EEA and UK Residents

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This section describes your rights under the EU General Data Protection Regulations and the UK General Data Protection Regulations (together, the “GDPR”) and explains how to exercise those rights.

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Right of Access. Commonly known as a “subject access request”. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

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Right to Correct the personal that we hold about you. This enables you to have any incomplete or inaccurate personal information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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Right of Erasure. You have the right to request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your personal information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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Right to Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your personal information (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal information which override your right to object.

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Right to Opt Out of Marketing. You can ask to stop sending you marketing communications at any time by contacting us at: support@zedpicks.com. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

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Right to Request Transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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Right to Withdraw Consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to Request Restriction of processing your personal information. This enables you to ask us to suspend the processing of your personal information one of the following scenarios:

  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.

No Fee Usually Required

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You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You

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We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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Time Limit To Respond

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We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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Complaints

You have the right to make a complaint at any time to the relevant EU Member State regulator for data protection issues concerning the GDPR. We would, however, appreciate the chance to deal with your concerns before you approach a regulator so please contact us in the first instance.

International Transfers

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We have offices in the United States, as such, we store your there which will involve transferring your personal information to the United States.

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Whenever we transfer your personal information outside of the EU/UK to countries which have laws that do not provide the same level of protection as the GDPR (such as the United States), we will always ensure that a similar degree of protection is afforded to it by implementing a GDPR compliance program within our organization, including employee training, and a certification scheme.

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We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the EU/UK to countries which have laws that do not provide the same level of data protection as the GDPR.

Whenever we transfer your personal data out of the EU/UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that we use specific standard contractual terms approved for use in the EU/UK which give the transferred personal data the same protection as it has in the EU/UK. To obtain a copy of these contractual safeguards, please contact us.

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Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

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How to contact us

  • Email: support@zedpicks.com

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