Privacy Policy

Last updated March 15, 2020

Thank you for choosing to be part of our community at Zapit Limited (“Company” “we” “us” or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices with regards to your personal information please contact us at [email protected]. When you visit our mobile application and use our services you trust us with your personal information. We take your privacy very seriously. In this privacy policy we seek to explain to you in the clearest way possible what information we collect how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully as it is important. If there are any terms in this privacy policy that you do not agree with please discontinue use of our Apps and our services. This privacy policy applies to all information collected through our mobile application (“Apps”) and/or any related services sales marketing or events (we refer to them collectively in this privacy policy as the “Services”). Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when registering at the Apps expressing an interest in obtaining information about us or our products and services when participating in activities on the Apps (such as creating orders or money transfers on our app) or otherwise contacting us. The personal information that we collect depends on the context of your interactions with us and the Apps the choices you make and the products and features you use. The personal information we collect can include the following:

Publicly Available Personal Information:

We collect first name/nickname; email addresses; business email; phone numbers; and other similar data.

Information automatically collected:

Some information — such as IP address and/or device characteristics; transaction history; order history; transfer history — is collected automatically when you visit our Apps. We automatically collect certain information when you visit use or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information such as your IP address browser and device characteristics operating system language preferences referring URLs device name country information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps and for our internal analytics and reporting purposes. Online Identifiers. We collect applications; Radio Frequency Identification (RFID) tags; and other similar data.

Information collected through our Apps:

We may collect information regarding your mobile device push notifications when you use our apps. If you use our Apps we may also collect the following information: Mobile Device Access. We may request access or permission to certain features from your mobile device including your mobile device's camera sms messages storage contacts and other features. If you wish to change our access or permissions you may do so in your device's settings. Mobile Device Data. We may automatically collect device information (such as your mobile device ID model and manufacturer) operating system version information and IP address. Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications you may turn them off in your app's settings.

HOW DO WE USE YOUR INFORMATION?

We process your information for purposes based on legitimate business interests the fulfillment of our contract with you compliance with our legal obligations and/or your consent. We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests in order to enter into or perform a contract with you with your consent and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To facilitate account creation and login process. To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the \WHAT ARE YOUR PRIVACY RIGHTS\ below). To send administrative information to you. We may use your personal information to send you product service and new feature information and/or information about changes to our terms conditions and policies. Fulfill and manage your orders. We may use your information to fulfill and manage your orders payments returns and exchanges made through the App. To protect our Services. We may use your information as part of our efforts to keep our Apps safe and secure (for example for fraud monitoring and prevention). To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent. To enforce our terms conditions and policies for Business Purposes Legal Reasons and Contractual. To respond to legal requests and prevent harm. If we receive a subpoena or other legal request we may need to inspect the data we hold to determine how to respond. To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order. To deliver services to the user. We may use your information to provide you with the requested service. For other Business Purposes. We may use your information for other Business Purposes such as data analysis identifying usage trends determining the effectiveness of our promotional campaigns and to evaluate and improve our Apps products marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent to comply with laws to provide you with services to protect your rights or to fulfill business obligations. We may process or share data based on the following legal basis: Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose. Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. Performance of a Contract: Where we have entered into a contract with you we may process your personal information to fulfill the terms of our contract. Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law governmental requests a judicial proceeding court order or legal process such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). Vital Interests: We may disclose your information where we believe it is necessary to investigate prevent or take action regarding potential violations of our policies suspected fraud situations involving potential threats to the safety of any person and illegal activities or as evidence in litigation in which we are involved. More specifically we may need to process your data or share your personal information in the following situations: Business Transfers. We may share or transfer your information in connection with or during negotiations of any merger sale of company assets financing or acquisition of all or a portion of our business to another company. Business Partners. We may share your information with our business partners to offer you certain products services or promotions. Other Users. When you share personal information (for example by posting comments contributions or other content to the Apps) or otherwise interact with public areas of the Apps such personal information may be viewed by all users and may be publicly distributed outside the Apps in perpetuity. Similarly other users will be able to view descriptions of your activity communicate with you within our Apps and view your profile. Offer Wall. Our Apps may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency gifts or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data such as your geographic area or demographic information. When you click on an offer wall you will leave our mobile application. A unique identifier such as your user ID will be shared with the offer wall provider in order to prevent fraud and properly credit your account.

HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 6 months past the termination of the user's account. When we have no ongoing legitimate business need to process your personal information we will either delete or anonymize it or if this is not possible (for example because your personal information has been stored in backup archives) then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Apps you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. If we learn that personal information from users less than 18 years of age has been collected we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18 please contact us at [email protected].

WHAT ARE YOUR PRIVACY RIGHTS?

In some regions such as the European Economic Area you have rights that allow you greater access to and control over your personal information. You may review change or terminate your account at any time. In some regions (like the European Economic Area) you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable to data portability. In certain circumstances you may also have the right to object to the processing of your personal information. To make such a request please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. If we are relying on your consent to process your personal information you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal. If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you have questions or comments about your privacy rights you may email us at [email protected].

Account Information

If you would at any time like to review or change the information in your account or terminate your account you can: Log into your account settings and update your user account. Upon your request to terminate your account we will deactivate or delete your account and information from our active databases. However some information may be retained in our files to prevent fraud troubleshoot problems assist with any investigations enforce our Terms of Use and/or comply with legal requirements. Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out you may: Access your account settings and update preferences.

DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection use disclosure or disposal of personal information. You will be notified about data breaches when Zapit Limited believes you are likely to be at risk or serious harm. For example a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Zapit Limited becomes aware of a security breach which has resulted or may result in unauthorized access use or disclosure of personal information Zapit Limited will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future we will inform you about that practice in a revised version of this privacy policy.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Yes if you are a resident of California you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83 also known as the “Shine The Light” law permits our users who are California residents to request and obtain from us once a year and free of charge information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request please submit your request in writing to us using the contact information provided below. If you are under 18 years of age reside in California and have a registered account with the Apps you have the right to request removal of unwanted data that you publicly post on the Apps. To request removal of such data please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Apps but please be aware that the data may not be completely or comprehensively removed from our systems.

DO WE MAKE UPDATES TO THIS POLICY?

Yes we will update this policy as necessary to stay compliant with relevant laws. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy you may email us at [email protected] or physical mailbox at Zapit Limited Glenealy Tower No 1. Glenealy Central Honk Kong.

HOW CAN YOU REVIEW UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries you may have the right to request access to the personal information we collect from you change that information or delete it in some circumstances. To request to review update or delete your personal information please submit a request form by clicking here. We will respond to your request within 30 days.

Collection and Use of Game Scores

Our app includes a global leaderboard that allows users to view and compare scores with other players worldwide. To provide this feature, we collect and store certain gameplay data, including user scores, on our secure servers.

Data Collected

Scores: Your game performance data, such as scores and rankings, will be collected when you choose to participate in the leaderboard.

Purpose of Collection

Leaderboard Ranking: The purpose of collecting score data is solely to display your ranking on the global leaderboard, enabling a competitive experience with other users of the app.

User Consent

Before uploading scores to our servers, we will ask for your consent. By agreeing, you allow us to collect and upload your score data. You may opt-out of score collection at any time within the app’s settings, which will remove your scores from the leaderboard.

Data Sharing

We do not share your score data with any third parties. It is used exclusively for leaderboard ranking purposes within the app.

Your Rights

You have the right to withdraw your consent at any time by adjusting the app settings. Withdrawing consent will prevent further score data from being uploaded, and previously uploaded scores may be removed from the leaderboard upon request.