Privacy Policy

ZCE LLC, an Illinois limited liability company doing business as “Zlatkin Cann Entertainment” and “Zlatkin Wong” (“ZCE,” “Zlatkin Cann Entertainment,” “Zlatkin Wong,” “Firm,” “we,” “our,” or “us”), is committed to ensuring that the Firm acts in accordance with applicable data protection and privacy laws when we collect and use information provided to us or information about visitors (“Users”, “you”, “your”) to our website. This Privacy Policy applies to your use of any of ZCE’s services, ZCE’s website, or as a result of your relationship with one or more of the Firm’s clients, or to any information collected from third parties including but not limited to all websites or apps that post a link to this Privacy Policy (collectively, “Sites”).

This Privacy Policy explains the types of information we collect, the purposes of processing that information, the legal basis for processing that information, how we use that information, and with whom we share such information. This Privacy Policy describes the measures we take to protect the security of the information and the rights that you have as a data subject with regard to this information. You may contact us to update your contact information, remove your name from our mailing lists, or get answers to questions you may have about our privacy practices by emailing us at info@zce.law.

Please read this Privacy Policy carefully. By continuing to interact with our Site, you are acknowledging the practices described in this Privacy Policy.

UPDATES TO OUR PRIVACY POLICY

This Privacy Policy may be updated periodically. We may modify this Privacy Policy at any time in our sole discretion. If we make material changes to this Privacy Policy that change our rights to use personal information we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominent posting on our sites. If we intend to further process your personal data for a purpose other than that for which the personal data were collected, prior to that further processing, we will provide you with information about that other purpose and with additional information necessary to ensure fair and transparent processing.

INFORMATION WE COLLECT DIRECTLY FROM YOU

We collect personal information about you when you interact with our Sites, including the following:

Data Collected	Purpose of Collection
Information about the devices associated with you used to access the Sites, such as a computer, mobile phone, or tablet	For permitted business purposes, such as administration, functioning, and improvement of the Sites; to analyze the Sites’ performance and functioning; to prevent fraud; to enforce the Sites’ Terms of Use; to comply with all applicable laws and corporate reporting obligations; to enforce the Firm’s agreements; to analyze how you use the Sites and to perform other market research.
Web browser type and version you use and any additional browsing information	For permitted business purposes, such as administration, functioning, and improvement of the Sites; to analyze the Sites’ performance and functioning; to prevent fraud; to enforce the Sites’ Terms of Use; to comply with all applicable laws and corporate reporting obligations; to enforce the Firm’s agreements; to analyze how you use the Sites and to perform other market research.
IP address, which may provide geolocation data	For permitted business purposes, such as administration, functioning, and improvement of the Sites; to analyze the Sites’ performance and functioning; to prevent fraud; to enforce the Sites’ Terms of Use; to comply with all applicable laws and corporate reporting obligations; to enforce the Firm’s agreements; to analyze how you use the Sites and to perform other market research.
How you use and interact with the Sites, including what you have searched for and viewed on the Sites	For permitted business purposes, such as administration, functioning, and improvement of the Sites; to analyze the Sites’ performance and functioning; to prevent fraud; to enforce the Sites’ Terms of Use; to comply with all applicable laws and corporate reporting obligations; to enforce the Firm’s agreements; to analyze how you use the Sites and to perform other market research.
Any information you provide to us by email or otherwise, including your name, address, email address, telephone number, and company name, when you contacted us, and the contents of your communication	To provide and communicate with you about our services; to send you further information regarding legal developments, our Sites, and our services; to add you to mailing lists and send you marketing materials we believe may be of interest to you.

Some or all of the information above may be shared with third parties as set forth below.

We collect certain information by automated means when you visit our Sites, such as how many users visited our Sites and the pages accessed. By collecting this information, we learn how to best tailor our Sites to our visitors. We collect this information through various means such as “cookies” and “web beacons”:

Cookies. As described in our Cookie Policy, we use “cookies” on some of the Sites. Cookies are pieces of code placed on your devices when you visit certain websites. We use cookies to tell us, for example, whether you have visited us before or if you are a new visitor and to help us identify features of the Sites in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website. Most web browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of the features and functionality of the Sites.
Web Beacons. As described in our Cookie Policy, certain pages on our website contain “web beacons” (also known as Internet tags, pixel tags, and clear GIFs). These web beacons allow third parties to obtain information, such as the IP address of the computer that downloaded the page on which the beacon appears; the URL of the page on which the beacon appears; the time the page containing the beacon was viewed; the type of browser used to view the page; and the information in cookies set by the third party.

LEGAL BASES FOR PROCESSING INFORMATION

We process this information where we have a legal basis to do so. The legal basis that we rely on may be one of the following:

The majority of the personal information we collect is provided by you voluntarily on the Sites, for example when you sign up to join a mailing list or register for an event, and is therefore collected with your consent and permission;
The processing is necessary to perform a contract with you or to fulfill a request you have made;
The processing is necessary to comply with a legal obligation that applies to the Firm under the law of the European Union (EU); or
The processing is necessary for purposes that are in the Firm’s legitimate interests in order to, for example, protect our business and better understand our customers.

If you notify us that you do not wish to be contacted for marketing purposes, we will not send you marketing information. Our Sites do not collect personal information about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our Sites, and we do not alter any of our data collection and use practices upon receipt of such a signal.

INFORMATION WE SHARE

We will not share your information with third parties outside of the international affiliation of ZCE without your consent, except as follows:

Where we are required to by virtue of a legal, regulatory or professional obligation;
With third parties who perform services on the Firm’s behalf. For example, we share information with vendors, such as those that provide systems, web hosting (including microsites), IT services, marketing support and other internal / external advisors. We may authorize them to collect information on our behalf. Some vendors may be located outside of the United States;
In accordance with our engagement terms, where you are a client of ZCE;
Where disclosed in the Firm’s Cookie Policy;
To law enforcement authorities or other government officials;
When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
If necessary to protect the vital interests of a person;
To enforce our Legal Notices and Terms of Use;
To protect our property, services, and legal rights;
To prevent fraud against the Firm, our affiliates, business partners, or authorized dealers; or
To support auditing, compliance, and corporate governance functions.

Any such third parties are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements. These third parties have no independent rights to the data.

LINKS TO OTHER WEBSITES

The Sites may provide links to other websites for your convenience and information. These websites may operate independently from our Sites. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not part of this website, we are not responsible for their content, any use of the websites, or the privacy practices of any of those websites.

INFORMATION WE TRANSFER

Our website is generally operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to the United States. Please also be aware that by using the Sites and giving us your information, you consent to such transfer. You also understand that the U.S. may not provide the same level of protections as the laws of your country. You accept that the transmission of personal information and other data via the internet is not completely secure. ZCE cannot guarantee the security of your information when it is in the process of being transmitted to and from the Sites. Any questions regarding our Privacy Policy should be directed to info@zce.law.

EUROPEAN UNION RESIDENTS’ RIGHTS

Natural persons located in the European Union have the right to request access to the personal information we have collected about you for the purposes of reviewing, modifying, or requesting erasure of the information. EU residents also have the right to request a copy of the information we have collected about you. In certain situations, you may also request that we restrict or cease processing your information.

If you would like to make a request to access, review, or correct the personal information we have collected about you, please contact us at info@zce.law.

To help protect your privacy and security, we will take reasonable steps to verify your identity before granting access to your information.

EU residents will be notified of any actions taken on your personal information in response to a request submitted for modification, deletion, or restrictions on the processing of your personal information.

When data processing is based on your consent as a resident of the EU, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal. You also have a right to data portability when the data processing is based on a contract between you and the Firm and the data was processed by automated means. You may exercise these rights by submitting a request to info@zce.law.

EU residents have the right to lodge a complaint with the appropriate privacy or data protection regulator in your jurisdiction.

HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical, and physical safeguards to protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide when visiting or using the Sites.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law provides you with certain rights. California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal information by us to third parties for those third parties’ direct marketing purposes. To make such a request, please send a detailed description of the specific content or information to info@zce.law or send written request to Management, Zlatkin Cann Entertainment, 4245 N. Knox, Chicago IL 60641. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal, even when requested.

Beginning on January 1, 2020, pursuant to California Civil Code 1798.100 et seq., the California Consumer Privacy Act of 2018 (“CCPA”), California residents have the following, additional rights:

Your Right to Access to Specific Information and Data Portability. You may request that we disclose certain information to you about our collection and use of your personal information in the past 12 months. Once we receive and confirm your personal information request, we will disclose to you:

The categories and specific pieces of personal information we collected about you;
The categories of sources for the personal information we collected about you;
Our business or commercial purpose for collecting that personal information;
The categories of third parties with whom we share that personal information; and
If we sold or disclosed your personal information for a business purpose, two separate lists identifying: (a) the categories of your personal information collected and sold, and the categories of the third parties to whom the data was sold; and (b) the categories of your personal information that was disclosed for business purposes.

To make such a request, please send an email with a detailed description of your request to info@zce.law.

Your Right to Request Deletion. You may request that we delete any of the personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your personal information request, we will delete such personal information from our records, unless an exception applies.

We may deny your request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information; provide a good or service that you requested; take actions reasonably anticipated within the context of our ongoing business relationship with you; or otherwise perform our contract with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with California Penal Code Section 1546 et seq. (the California Electronic Communications Privacy Act);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Your Right to Opt-Out of Sale. We do not sell personal information to third parties. If that should change, we will make available to you a method to opt-out of such sale.

Exercising Your CCPA Rights. To exercise any of the CCPA rights described above, please submit a verifiable personal information request to us by:

Calling us at 312-809-6989;
Emailing us at info@zce.law; or
Writing to us at the mailing address provided below.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may submit a personal information request. You may also make a personal information request on behalf of your minor child.

You may only submit two personal information requests within a 12-month period. The verifiable personal information request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or an authorized representative. For a request by the actual person, we will typically require a copy of a valid state-issued identification card, together with any email or physical address you have submitted to us. For an authorized representative, we will typically require a copy of the registration with the California Secretary of State referenced above, a valid power of attorney or a court appointment document; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Response Timing and Format. We endeavor to respond to a personal information request within 45 days of our receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. If provided electronically, we will select a format to provide your personal information that is in a portable and readily useable format. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your personal information request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Your Right to Non-Discrimination. Unless permitted or required by law, if you exercise any of your rights under the CCPA, we will not:

Deny you our services;
Charge you different prices or rates for our services;
Provide you a different level or quality of services; or
Suggest that you may receive a different price or rate for services, or a different level or quality of services.

RETENTION OF INFORMATION

We retain all personal information for the duration of the relevant business relationship or, where required, in accordance with our information management policies and schedules. When deleting personal information based on a request by the data subject, we will make reasonable attempts to ensure that all instances of the information are deleted in their entirety. For requests for access, corrections, or deletion, please refer to the “European Union Residents’ Rights” section of this policy.

ZCE maintains necessary documentation to demonstrate compliance with its obligations and to allow audits, including inspections, to be carried out by the Firm or another auditor it has mandated.

We shall keep a written data processing activity register, listing data processing activities by category.

HOW TO CONTACT US AND MAKE REQUESTS

If you have any requests, questions or comments about this Privacy Policy, please contact info@zce.law. If you would like to update your contact information or preferences, have your information removed from our mailing lists, or no longer wish to receive marketing e-mails that we may send based on information collected via product registration cards or other sources, you may do so by (a) unsubscribing via the links contained in emails from us; (b) contacting us at info@zce.law; or (c) writing to us at Zlatkin Cann Entertainment, ATTN: Management, 4245 N. Knox Ave., Chicago, IL 60641.

BUSINESS STRUCTURE CHANGES

We reserve the right to disclose and transfer all information related to our Sites, including personal data:

To a subsequent owner, co-owner, or operator of one or more of the Sites; or
In connection with a merger, consolidation, restructuring or other transaction involving the Firm, including without limitation, during the course of any due diligence process.

CHILDREN’S PRIVACY

Our site is a general audience site not directed at children under the age of 16. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 16, we will promptly delete the information.

Effective Date: July 6, 2023