This Privacy Policy (“Privacy Policy”), is an integral part of our (“EULA”) and governs the processing and transfer of personal data collected or processed. (“Company”, “we”, “us” or “our”) when you accessing or using our mobile application or our services, all as detailed in the applicable EULA (respectively the “App” and “Service”).

Any capitalized terms not defined herein shall have the meaning ascribed to them in the EULA.

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it, and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

In the event, you are a California resident and the CCPA applies to you – please also review.

If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us

This Privacy Policy explains our data collection practices that apply to any users of our App or our Services (“you” or “your”).

To operate our Services and App, we use several service providers as detailed in this Policy (collectively “Service Providers”):

• In-app payment providers;
• Advertising partners;
• Fraud prevention and analytic tools; and
• Tracking tools.

We contractually ensure our Service Providers comply with applicable data protection laws.

1. OVERVIEW OF THE INFORMATION WE PROCESS FROM YOU

We may collect two types of data and information from you, depending on your interaction with us. The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, session duration and page impressions, etc.

The second type of information is identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

Personal Data we collect from you

TYPE OF DATA	PURPOSES OF PROCESSING FOR	FOR EU PERSONS - LEGAL BASIS UNDER THE GDPR
Contact Information: In the event you contact us for support or any other inquiries, by sending us an email or by any other means of communications we may make available to you, you will be requested to provide us with your full name and email address. In addition, you can choose to provide us with additional information as part of your correspondence with us.	We will use this information solely to respond to your inquiries and provide you with the support or information you have requested. The correspondence may be used to improve our customer service, and in the event, we believe it is required to provide you with any further assistance (if applicable).	Our legitimate interest.
Registration Information: If you are required to register and create an account through our App, we will collect the Personal Data that you are required to provide us during the registry process, such as your full name and email address. Further, during the registration process, you will be supplied with a username and password for your account, at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your details and password. You represent and warrant that you will not provide us with inaccurate, misleading, or false, information.	This information will be processed to perform our contract with you, to set up your account with us, and enable you to use our Services. In addition, we may process your Personal Data for our legitimate interests, for example, to send you marketing and promotional messages and offers related to our Services. You can unsubsccaneceiving such correspondence from us by contacting us at: Please note that if you choose to unsubscribe from direct marketing, we may still retain your contact details and send you relevant service-related information such as invoices and subscription rates.	The registration information is processed to perform our contract with you and the direct marketing is subject to our legitimate interest.
GPS Location Information: Certain features may require access to your GPS location permissions. In addition, in certain features, we will use your “Access Fine Location” permission in the background while you are using the App so that we are able anthem wifi networks and connections to provide the Services.	This information will be processed to provide the Services as well as for advertising purposes. In addition, we will use your Fine Access Locationtoo to offer you different WIFI networks depending on your location. Please note that this information can run in the background of your mobile device, and show you an applicable list of WIFI networks. You may choose to block your background location through your device setting.	We will process this data solely upon your active explicit consent through in-app notifications.
Push Notifications: We may store Firebase Cloud Messages token. If you wish to stop getting push notifications, you may do so simply by disabling disablingifications on your device’s settings oruninstallingl the app.	This information will be processed to allow us to send push notifications to users from our server.	As the token is Non-Personal Data it does not require a lawful basis.
In-App Payment Information: When you make a payment through our App and offered Services, all payments are in-app payments and are subject to the applicable App Store terms and privacy policy. Google Terms of Service Google Privacy Policy App Store Terms of Use App Store Privacy Policy	We use in-app payment processors; the registration and payment information are solely processed by the applicable app store provider. We do not store nor process any Personal Data when you process the payment. We receive an order number that is connected to a user ID that was generated when installing the app (nonidentifiable).	NA
Log Data and Unique Identifiers: In case of an error in the App, we collect data and information (through third-party service providers) such as “Log Data” or “Crash Data”. This data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.	In most cases, this data will not include Personal Data, however, we treat this information as Personal Data as we may be able to reasonably identify you.	We process this data set for our legitimate Interest in protecinterest App and Services and optimize the App and Services.
List of Installed App: When you install our App, we may collect information from your device, which may include a list of your installed applications. This data may contain identifying information and therefore we treat it as Personal Data.	We use this data to maintain, support, improve, protect and manage our App and Services.	We will base the processing of this data set on your consent through the organic in-app permissions.
Profiling Data: When you use our App we may display advertisements, our partners, the advertisers may place an SDK (as detailed below) and collect certain data on you to display advertisements. If you wish to prevent the display of advertisements or other identifiers for interest-based advertising, you may change your device settings to reset such advertisement or opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings). Please note that if you reset your advertising settings or opt-out of interest-based advertising, you may still see advertisements in our App, but those ads will not be targeted for you. Please note that such actions may result in a less enjoyable user experience.	Our partners will process this data to manage and deliver advertisements more effectively and personally, including contextual, behavioral, and interestbasedd advertising based on your activity, preferences, or other data available to us or to our business partners and advertisers, including for re-targeting purposes.	We process this information based on your consent as required under your jurisdiction provided through our cookie manager or similar technologies.
Technical Data: We also collect certain technical Non-Personal Data which relates to your use of our Apps such as the type and version of device, application, or browser used, operating system, or time zone setting, country, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs.	We use this data to maintain, support, improve, protect and manage our App and Services. This information does not include Personal Data.	As the technical data is Non-Personal Data it does not require a lawful basis.

2. HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the App and Services, we may collect information as follows:

2.1. Automatically – we may use SDK (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our App and Services.

2.2. Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through the Services, contact us communications, etc.

3. SHARING DATA WITH THIRD PARTIES

We will not share your Personal Data with third parties, other than as specifically mentioned herein:

• Subject to your consent - we may share your Personal Data upon your explicit consent. Once we share your Personal Data under these circumstances, that data becomes subject to the other third party’s privacy practices.
• Policy enforcement and third party rights - we may share your Personal Data in the event required to enforce our policies and agreements or to establish and exercise our rights to defend against legal claims, including investigations of potential violations and to detect or prevent illegal activities or other wrongdoing, security or technical issues. In addition, we may share your Personal Data to prevent harm to the rights or safety of our users or any applicable third party.
• Law enforcement - we may share your Personal Data, solely to the extent needed to comply with any applicable law, regulation, legal process, or governmental request.
• Affiliate company and corporate transaction – in the event required, we may share your Personal Data with our parent company, any subsidiaries, joint ventures, or other companies under a common control (“Affiliated Companies”) or in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). Our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Policy.
• Service Providers - we may disclose Personal Data to our service providers to perform requested services on our behalf. Certain of our service providers shall include servers, payment processors, advertisement services, governmental agencies, and representatives. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services and are all signed on applicable data protection agreements limiting their use of Personal Data.

4. SDK & TRACKING TECHNOLOGIES

Our Services and some of our Service Providers utilize “cookies” or “software development kits (“SDK”)” anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps and Services as a whole.

 

PRIVACY POLICY

[Last Amended: July 18, 2021]

This Privacy Policy (“Privacy Policy”), is an integral part of our End User License Agreement (“EULA”) and governs the processing and transfer of personal data collected or processed by Zippo Apps Ltd. (“Company”, “we”, “us” or “our”) when you accessing or using our mobile application or our services, all as detailed in the applicable EULA (respectively the “App” and “Service”).

Any capitalized terms not defined herein shall have the meaning ascribed to them in the EULA.

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it, and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

In the event, you are a California resident and the CCPA applies to you – please also review our CCPA Privacy Notice.

If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us.

This Privacy Policy explains our data collection practices that apply to any users of our App or our Services (“you” or “your”).

To operate our Services and App, we use several service providers as detailed in this Policy (collectively “Service Providers”):

• In-app payment proIn-app;
• Advertising partners;
• Fraud prevention and analytic tools; and
• Tracking tools.

We contractually ensure our Service Providers comply with applicable data protection laws.

1. OVERVIEW OF THE INFORMATION WE PROCESS FROM YOU

We may collect two types of data and information from you, depending on your interaction with us. The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, session duration and page impressions, etc.

The second type of information is identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

Personal Data we collect from you

TYPE OF DATA	PURPOSES OF PROCESSING FOR	FOR EU PERSONS - LEGAL BASIS UNDER THE GDPR
Contact Information: In the event you contact us for support or any other inquiries, by sending us an email or by any other means of communications we may make available to you, you will be requested to provide us with your full name and email address. In addition, you can choose to provide us with additional information as part of your correspondence with us.	We will use this information so to respond to your inquiries and provide you with the providing or information you have requested. The correspondence may be used to improve our customer service, and in the eve, not we believe it is required to provide you with any further assistance (if applicable).	Our legitimate interest.
Registration Information: If you are required to register and create an account through our App, we will collect the Personal Data that you are required to provide us during the registry process, such as your full name and email address. Further, during the registration process, you will be supplied with a username and password for your account, at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your details and password. You represent and warrant that you will not provide us with inaccurate, misleading, or false information.	This information will be processed to perform our contract with you, to set up your account with u,s and enable you to use our Services. In addition, we may process your Personal Data for our legitimate interests, for example, to send you marketing and promotional messages and offers related to our Services. You can unsubsccaneceiving such correspondence from us by contacting us. Please note that if you choose to unsubscribe from direct marketing, we may still retain your contact details and send you relevant service-related information such as invoices and subscription rates.	The registration information is processed to perform our contract with you and the direct marketing is subject to our legitimate interest.
GPS Location Information: Certain features may require access to your GPS location permissions. In addition, in certain features, we will use your “Access Fine Location” permission in the background while you are using the App so that we can locate the wifi networks and connection to provide the Services.	This information will be processed to provide the Services as well as for advertising purposes. In addition, we will use your Fine Access Location to offer to WIFI networks depending on your location. Please note that this information can run in the background of your mobile device, and show you an applicable list of WIFI networks. You may choose to block your background location through your device setting.	We will process this data solely upon your active explicit consent through in-app notifications.
Push Notifications: We may store Firebase Cloud Messages token. If you wish to stop getting push notifications, you may do so simply by disabling push notifications on your device’s settings or uninstalling the app.	This information will be processed to allow us to send punotificationsion to users from our server.	As the token is Non-Personal Data it does not require a lawful basis
In -App Payment Information: When you make a payment through our App and offered Services, all payments are in-app payments and are subject to the applicable App Store terms and privacy policy. Google Terms of Service Google Privacy Policy App Store Terms of Use App Store Privacy Policy	We use-app payment processors; the registration and payment information are solely processed by the applicable app store provider. We do not store nor process any Personal Data when you process the payment. We receive an order number that is connected to a user IDthath was generated when installing the app (nonidentifiable).	NA
Log Data and Unique Identifiers: In case of an error in the App, we collect data and information (through third-party service providers) such as “Log Data” or “Crash Data”. This data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.	In most cases, this data will not include Personal Data, however, we treat this information as Personal Data as we may be able to reasonably identify you.	We process this data set for our legitimate interest in protecting our App and Services and optimizing the App and Services.
List of Installed App: When you install our App, we may collect information from your device, which may include a list of your installed applications. This data may contain identifying interest base information and therefore we treat it as Personal Data.	We use this data to maintain, support, improve, protect and manage our App and Services.	We will base the processing of this data set on your consent through the organic in-app permissions.
Profiling Data: When you use our App we may display adadvertisementsour partners, the advertisers may place an SDK (as detailed below) and collect certain data on you to display advertisement. If advertisements event the display of advertisements or other identifiers for interest-based advertising, you may change your device settings to reset such advertisement or opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings). Please note that if you reset your advertising settings or opt-out of interest-based advertising, you may still see advertisements in our App, but those ads will not be targeted for you. Please note that such actions may result in a less enjoyable user experience.	Our partners will process this data to manage and deliver advertisements more effectively and personally, including contextual, behavioral, and interest-based advertising based on your activity, preferences, or other data available to us or to our business partners and advertisers, including for re-targeting purposes.	We process this information based on your consent as required under your jurisdiction provided through our cookie manager or similar technologies.
T echnical Data: We also collect certain technical Non-Personal Data which relates to your use of our Apps such as the type and version of device, application, or browser used, operating system, or time zone setting, country, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs.	We use this data to maintain, support, improve, protect and manage our App and Services. This information does not include Personal Data.	As the technical data is Non-Personal Data it does not require a lawful basis.

2. HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the App and Services, we may collect information as follows:

2.1. Automatically – we may use SDK (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our App and Services.

2.2. Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through the Services, contact us communications, etc.

3. SHARING DATA WITH THIRD PARTIES

We will not share your Personal Data with third parties, other than as specifically mentioned herein:

• Subject to your consent - we may share your Personal Data upon your explicit consent. Once we share your Personal Data under these circumstances, that data becomes subject to the other third party’s privacy practices.
• Policy enforcement and third party rights - we may share your Personal Data in the event required to enforce our policies and agreements or to establish and exercise our rights to defend against legal claims, including investigations of potential violations, and to, detect or prevent illegal activities or other wrongdoing, security or technical issues. In addition, we may share your Personal Data to prevent harm to the rights or safety of our users or any applicable third party.
• Law enforcement - we may share your Personal Data, solely to the extent needed to comply with any applicable law, regulation, legal process, or governmental request.
• Affiliate company and corporate transaction – in the event required, we may share your Personal Data with our parent company, any subsidiaries, joint ventures, or other companies under a common control (“Affiliated Companies”) or in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). Our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Policy.
• Service Providers - we may disclose Personal Data to our service providers to perform requested services on our behalf. Certain of our service providers shall include servers, payment processors, advertisement services, governmental agencies, and representatives. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services and are all signed on applicable data protection agreements limiting their use of Personal Data.

4. SDK & TRACKING TECHNOLOGIES

Our Services and some of our Service Providers utilize “cookies” or “software development kits (“SDK”)” anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps and Services as a whole.

AccDataotection and privacy laws may grant you certain rights with regards to your Personal Data, all according to your jurisdiction. The rights may include one or all of the following: (i) request to amend your Personal Data we store accessing; (ii) review and access your Personal Data that we hold; (iii) request to delete your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) restrict or object to the process your Personal Data; (v) exercise your right of data portability (vi) contact to a supervisory authority in your jurisdiction and file a complaint; and, and) withdraw consent (to the extent applicable). If you wish to submit a request to exercise your rights, please fill out the Data Subject Request Form (“DSR”) available.

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you to fortify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

6. DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all by applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, with or without previous notice to you.

7. SECURITY

We take great care in implementing physical, technical, and administrative security measures for the services that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.

If you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data, please contact us at our email. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) if we discover a security incident related to your Personal Data.

8. DATA TRANSFER

We use Google Cloud which is located in the EU, US, and Asia.  Further, certain processing activities are conducted in Israel, or other countries. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred under the provisions of the standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact us at our email.

9. CHILDREN

Our App and Services are intended for a general audience and are not directed to persons under 13 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 13 years old. If we become aware that a person under 13 years old has provided us with Personal Data, we will delete such data from our databases.

 

11. CHANGES AND UPDATES

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. I  we made any substantial changes to this Privacy Policy, we will make reasonable efforts to provide you with notification concerning such changes if we are required to do so by applicable law. The changes to this Privacy Policy will go into effect as of the date listed in the “Last Amended” heading located at the top of this Privacy Policy.

12. CONTACT US

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us niti8358@outlook.com