Ownership and data controller
The Zappar Services are owned and operated by Zappar Limited, a company incorporated and registered in Scotland (company number SC394617). Our contact details are shown below in the section headed “Your Rights”.
Information that We collect from You
Collection and user registration:
If You use Zappar Services We may collect certain information from You.
In particular, some features of the Zappar Services may require You either to (1) confirm your country and age and/or (2) register before You can access those features (e.g. BunnyMail™, photo share). As part of the confirmation or registration process You may be asked to provide certain information about Yourself. This could be one or more of the following items of personal information:
- Your name,
- Your date of birth,
- Your email address,
- Your post code,
- Your country of residence,
- Username and password.
We may also collect the following kinds of information from You whether or not You register with Us:
- device information,
- profile information,
- payment information, and
- User Generated Content
See below for further details.
Use of Content:
When You use the Apps or the Site in order to access Content, We will process Your Data necessary for using the functionalities therein and for access to and subsequent transmissions of the Content.
User Generated Content:
Certain features of the Zappar Services allow You to create, submit, post, display, transmit or share content (e.g. photos, videos, comments, messages, and other materials) on or through the Zappar Services (“User Generated Content”). Such features include BunnyMail™. The ZAPPAR App also contains a gallery screen displaying User Generated Content. This means that your User Generated Content may be visible to and capable of use by other users of the Zappar Services and will be stored on Our secure servers for the purposes of making the Zappar Services available.
Some of your User Generated Content may contain or depict personal data about You or other persons, e.g. audio, photos or videos featuring You or Your friends. We therefore advise You to be selective about what personal information You provide in User Generated Content. We advise You not to include any of the following types of information in any submission to any publicly available area: telephone numbers, addresses, full name. Be aware that if You upload information about or depicting other individuals (e.g. a photo of a friend), You are advised to request their consent first.
If You remove information that You posted to the Zappar Services, copies may remain viewed in cached and archived pages of the Zappar Services.
Information about Your device and Your use of the ZAPPAR App:
When You use the ZAPPAR App, Our servers will automatically record information that Your mobile device sends or transmits, including the following:
- a random ID (see below),
- Your Internet Protocol (“IP Address”),
- the time,
- the make and model of Your device (including operating system version),
- the version of the App being used,
- user settings, and
- information about Your use of the App.
We may use this information to optimise Your use of the Zappar Services, develop new products and offer products or services which may be of use to You.
The random ID referred to above is a unique identifier generated by the ZAPPAR App when it is first run. The ID is random, seeded from the time and does not identify You personally. The ID is used to anonymously track a person’s use of the App in the following ways:
- when the user opens the App;
- when the user taps “Zap”;
- when the user performs certain actions during a zap e.g. completing a game;
- how long a user spends interacting with a zap;
- to confirm that the user is allowed to use an age-restricted feature of the ZAPPAR App.
Our servers will record information that Your web browser sends when you use the Zappar Services (“Log Data”). This may include information such as Your IP Address, the pages that You visit, time spent on pages and other statistics. We use this information to better tailor the Zappar Services to Our users’ needs. We do not use Log Data in association with other elements of Your Data, though We may aggregate it to provide a better user experience.
GPS Location Data:
Use of Your Data
We may use Your Data for all or any of the following purposes:
- to enable Us to provide You with access to all parts of the Zappar Services and to enable You to have access to the Content;
- to provide You with service related updates;
- to provide You with personalised content and promotional communications that You have consented to receive from the Zappar Services;
- to provide customer service in relation to Your use of the Zappar Services;
- to enable You to create and share User Generated Content; and
- to administer, support, improve and develop the Zappar Services, including automatically updating the ZAPPAR App on Your device.
We may use Your Data to send You notifications and information about the Zappar Services and other Zappar products and Zappar Services We think may be of interest to You, but only if You have given your consent. If at any time You no longer wish to be contacted for this purpose, please let Us know and We will remove You from Our mailing list. Please note that You may not opt out of service related emails.
All processing of Your Data by Us or on Our behalf is carried out within the European Economic Area, except that We may use certain service providers for infrastructure services whose servers are based in the United States. We do not transfer or process Your Data outside the European Economic Area except where necessary to provide the Zappar Services in which case We shall take all steps reasonably necessary to ensure that Your Data is adequately protected.
We may appoint third parties to carry out certain data processing on Our behalf. For example, We may appoint a third party (1) as a payment provider, (2) to host the Zappar Services or (3) to administer electronic marketing on Our behalf. We will continue to be the data controller in respect of the data transferred to such third parties and shall remain responsible for the processing undertaken by them.
Disclosure of Your Data
We may disclose Your Data to or share it with:
- other users where You allow information to be made public;
- social media services You choose to share information with;
- any third party to whom disclosure is necessary to enable Us to provide You with the Zappar Services;
- Our business partners, which may include advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of interest to You;
- any prospective purchaser of Zappar Limited, its parent company, or the Zappar Services or any part thereof;
- outside parties (e.g. judicial or regulatory authorities) to comply with the law and legal obligations.
Third Party Sites and Contributors
Security and data retention
We employ commercially reasonable security measures to protect Your Data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. However, We cannot ensure the security of Your Data or guarantee that Your Data may not be accessed, disclosed, altered or destroyed by an unauthorised person.
We will retain Your Data for the duration of Your use of the Zappar Services and for a reasonable period thereafter for backup, archival and/or audit purposes or for as long as the law otherwise requires or permits.
You are entitled to see the information that We hold about You and You may ask Us to make any necessary changes to ensure that it is accurate and kept up to date. If You wish to do this, please contact Us using the contact information provided below. We are entitled by law to charge a fee of £10 to meet Our costs in providing You with details of the information We hold about You and We reserve Our right to require You to submit reasonable proof of Your identity before We disclose any information to You.
Data Protection Officer
The Barley Mow Centre
10 Barley Mow Passage
London W4 4PH
You may withdraw Your consent for Us to process Your Data at any time by notifying Us in writing, but if You withdraw Your consent to certain types of processing described above We may be unable to maintain Your registration for certain features of the Zappar Services or in some instances permit Your continued use of certain features of the Zappar Services.
Children’s privacy and the Children’s Online Privacy Protection Act (COPPA)
This section applies if You are accessing any Zappar Services from within the USA and any other country which requires parental consent for the collection of personal information from an individual under the age of 13.
We do not knowingly collect or solicit personal information from children under the age of 13. The Zappar Services and their content are not intentionally directed at children under the age of 13 and We do not target children under 13 as Our primary audience. In the event We learn that We have inadvertently collected personal information from a child under the age of 13, and that child lives in a country which does not permit such collection without parental consent, We will delete that information as quickly as possible.
If a parent or legal guardian becomes aware that their child under the age of 13 has provided Us with personal information without parental consent, please contact Us at the address above and We will delete such information from Our files.
So as to comply with international privacy laws, We use age screens for certain features of the ZAPPAR App. We do not store any individual’s date of birth on Our servers and this information is held within the user’s device.
LAST UPDATED: 1ST MARCH 2013