Privacy policy

 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 Zipo 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”).

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

For the purpose of operating 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 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 for the purpose of responding to your inquiries and provide you with the support or information you have requested. The correspondence may be used in order to improve our customer service, and in the event we believe it is required in order 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 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 for the purpose of performing 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 are able to unsubscribe from receiving 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.

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 in order 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 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 the Personal Data.

4. USER RIGHTS

According to data protection and privacy laws may grant you with 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 (vii) 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 here and send it to our email 

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify 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.

5. DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with 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.

6. 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.

7. DO NOT TRACK DISCLOSURE

The App and the App’s Services do not respond to Do Not Track signals. For information about Do Not Track,

8. CONTACT US

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at  tomhelm09@gmail.com.