PRIVACY POLICY

Last updated: Jan 11, 2024

1. OUR COMMITMENT TO YOUR PRIVACY

At Zap.app, we prioritize your privacy. It is the foundation of our service design and development, allowing you to trust our products and focus on building meaningful connections. We value the trust you place in us when providing your information, and we take this responsibility seriously. We are unwavering in our commitment to your privacy. Every product and service we create is designed with your privacy in mind. We collaborate with experts in legal, security, engineering, product design, and other fields to ensure that your privacy is always respected. Transparency is essential to us in how we handle your data. We understand the common issues of insufficient information and complex language found in privacy policies of many online services. In contrast, we have taken the opposite approach by using plain language in our Privacy Policy and related documents. We genuinely want you to read and comprehend our policies and understand our privacy practices. We work diligently to safeguard your information. We have dedicated teams focused on keeping your data secure. We consistently update our security practices and invest in efforts to enhance the safety of your information.

2. PRIVACY POLICY

Welcome to the Privacy Policy of Zap.app. We appreciate your time and thank you for reading it. We value the trust you have placed in us by sharing your information, and we are committed to maintaining that trust. This commitment begins with ensuring that you understand the information we collect, why we collect it, how it is used, and the choices you have regarding your information. This Policy provides a clear description of our privacy practices, minimizing the use of legal and technical jargon. WHERE THIS PRIVACY POLICY APPLIES This Privacy Policy applies to all websites, apps, events, and other services operated by Zap.app. For simplicity, we refer to all of these as our "services" in this Privacy Policy. To ensure clarity, we have included links to this Privacy Policy on all relevant services. Certain services may have their own unique privacy policy. In such cases, the specific service's privacy policy will apply instead of this Privacy Policy.

3. INFORMATION WE COLLECT

It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. If you want additional info, we go into more detail below. Information you give us You choose to give us certain information when using our services. This includes: When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender and date of birth. When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos. To add certain content, like pictures, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information. When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials. When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter. If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service. Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services. Information we receive from others In addition to the information you provide us directly, we receive information about you from others, including: Other Users Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you. Other Partners We may receive info about you from our partners, for instance where Zap.app ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success). Information collected when you use our services When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details: Usage Information We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive). Device information We collect information from and about the device(s) you use to access our services, including: ◦ hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); ◦ information on your wireless and mobile network connection, like your service provider and signal strength; ◦ information on device sensors such as accelerometers, gyroscopes and compasses. Other information with your consent If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools. Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Zap.app, do not currently respond to DNT signals.

5. HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples. To administer your account and provide our services to you Create and manage your account Provide you with customer support and respond to your requests Complete your transactions Communicate with you about our services, including order management and billing To help you connect with other users Analyze your profile, activity on the service, and preferences to recommend meaningful connections to you and recommend you to others; For more information on our profiling and automated decision-making, please see our FAQ Show users’ profiles to one another To ensure a consistent experience across your devices Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them. To provide new Zap.app services to you Register you and display your profile on new Zap.app features and apps Administer your account on these new features and apps To serve you relevant offers and ads Administer sweepstakes, contests, discounts or other offers Develop, display and track content and advertising tailored to your interests on our services and other sites Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you To improve our services and develop new ones Administer focus groups and surveys Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior) Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users). To prevent, detect and fight fraud or other illegal or unauthorized activities Address ongoing or alleged misbehavior on and off-platform Perform data analysis to better understand and design countermeasures against these activities Retain data related to fraudulent activities to prevent against recurrences To ensure legal compliance Comply with legal requirements Assist law enforcement Enforce or exercise our rights, for example our Terms To process your information as described above, we rely on the following legal bases: Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you. Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes. Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

6. HOW WE SHARE INFORMATION

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. Read on for more details about how your information is shared with others. With other users You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publically viewable since neither you nor we can control what others do with your information once you share it. If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings. With our service providers and partners We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, and security operations. We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners. We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations. For corporate transactions We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control. When required by law We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person. To enforce legal rights We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing. With your consent or at your request We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information. We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy

7. CROSS-BORDER DATA TRANSFERS

The sharing of information described in Section 6 may involve the transfer of data across borders, including to the United States of America and other jurisdictions. For example, if the service allows users from the European Economic Area ("EEA"), their personal information may be transferred to countries outside the EEA. To facilitate such transfers, we utilize standard contract clauses approved by the European Commission or other appropriate safeguards. These standard contractual clauses are binding commitments between companies involved in the transfer of personal data, ensuring the privacy and security of your data.

8. YOUR RIGHTS

We want you to have control over your information, and we provide you with the following tools: - Access/Update tools within the service: We offer tools and account settings that enable you to access, correct, or delete the information you have provided to us and that is associated with your account directly within the service. If you have any questions regarding these tools and settings, please contact our customer care team for assistance. - Device permissions: Mobile platforms have permission systems that govern the collection of specific types of device data and notifications, such as contact lists, location services, and push notifications. You can modify your device settings to grant or deny consent for the collection of such information or the display of corresponding notifications. Please note that certain services may lose full functionality if you choose to modify these settings. - Account deletion: You have the option to delete your account by using the corresponding functionality within the service. We want you to be aware of your privacy rights, and here are some key points to remember: - Reviewing your information: Applicable privacy laws may grant you the right to review the personal information we hold about you (referred to as the right of access, right of portability, or similar terms depending on the jurisdiction). You can request a copy of your personal information by submitting a request here. - Updating your information: If you believe that the information we have about you is inaccurate, or if we no longer have a legitimate basis for using it and you wish to request rectification, deletion, or object to its processing, please contact us here. For your protection and the protection of all our users, we may require proof of identity before fulfilling the above requests. Please note that we may reject requests for certain reasons, such as if the request is unlawful or if it would infringe upon trade secrets, intellectual property, or the privacy of another user. If you request information related to another user, such as a copy of messages received from that user through our service, the other user will need to provide their written consent to our Privacy Officer before we can release the information. Additionally, we may be unable to accommodate certain requests to object to the processing of personal information if doing so would prevent us from providing our service to you. For example, we require your date of birth to provide our service. - Uninstall: You can cease all information collection by uninstalling the app using the standard uninstall process for your device. However, if you reinstall the application on the same device, we will be able to link your previous transactions and activities to the unique identifier associated with your device. - Accountability: In certain countries, including the European Union, you have the right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can contact may be based on your habitual residence, place of work, or where we are established.

9. RESIDENTS OF CALIFORNI

If you are a resident of California, you have the right to request a notice that discloses the categories of personal information we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request here. Please allow 30 days for a response. For your protection and the protection of all our users, we may require proof of identity before fulfilling such a request.

10. HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures. We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately here In order to ensure that our systems and your information are protected against unauthorized access, theft and loss, we implemented a bug bounty program. For more information about our bug bounty program, please click here.

11. HOW LONG WE RETAIN YOUR INFORMATION

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore. In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless: we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations); we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years); there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account. Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

12. CHILDREN’S PRIVACY

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.

13. PRIVACY POLICY CHANGES

As we continuously strive to find new and innovative ways to assist you in forming meaningful connections, this Privacy Policy may undergo changes over time. We are committed to keeping you informed about any significant changes before they become effective, allowing you ample time to review and assess the modifications.