Privacy Policy

1. INTRODUCTION

 1.1 Welcome to the Zapz platform, administered by ZAPZ CONSULTORIA EM MARKETING LTDA ("Zapz"), registered with the CNPJ under No. 41.490.823/0001-20 and its affiliates (individually and collectively, "Zapz", "we", "us" or "our"). Zapz takes seriously its responsibilities under applicable privacy laws and regulations ("Privacy Laws") and is committed to respecting the privacy rights and concerns of all Users of our Zapz platform (the "Platform") (we refer to the Platform and the services we provide as described on our Platform collectively as the "Services"). We recognize the importance of the personal data you have entrusted to us and believe it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy ("Privacy Policy" or "Policy") is designed to help you understand how we collect, use, disclose and/or process the personal data you have provided to us and/or we hold about you, now or in the future, and to help you make an informed decision before providing us with your personal data.

 

1.2 Personal data" or "personal data" means data, whether true or not, about an individual who can be identified from that data or that data and other information to which an organization has or is likely to have access. Common examples of personal data may include name, identification number and contact information.

 

1.3 By using the Services, registering an account with us, visiting our Platform or accessing the Services, you acknowledge and agree that you accept the practices, requirements and/or policies described in this Privacy Policy and hereby consent to our collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will post those changes or the changed Privacy Policy on our Platform. We reserve the right to change this Privacy Policy at any time.

 

1.4 This Privacy Policy shall apply in conjunction with other regulations, notices, contractual clauses, consent clauses applicable to the collection, storage and/or processing of your personal data by Zapz and does not supersede any such notices, regulations or clauses unless expressly provided by Zapz to that effect.

 

1.5 This Privacy Policy applies to all users of the Platform and services provided by Zapz, including buyers and sellers, except as otherwise expressly provided by Zapz.

  

2. when will zapz collect personal data?

 

2.1 We will / may collect personal data about you:

  • when you register and/or use our Services or Platform, or open an account with us;

  • when you submit any form, including, but not limited to, registration forms or other forms related to any of our products and services, whether online or via a physical form;

  • when you enter into any contract or provide any other documentation or information regarding your interactions with us or when you use our products and services;

  • when you interact with us, such as in phone calls (which may be recorded), letters, faxes, face-to-face meetings, social media platforms, and e-mails, including when you actively interact with our customer service and support services;

  • when you use our electronic services, or interact with us through our application or use services on our Platform. This includes, without limitation, through cookies that we may deploy when you interact with our application or website;

  • when you grant permission on your device to share information with our applications or Platform;

  • when you perform transactions through our Services;

  • when you provide us with feedback or complaints;

  • when you sign up for a contest; or

  • when you submit your personal data to us for any reason.

The above is not intended to be exhaustive and sets out some common examples of when personal data about you may be collected.

 

3. WHAT PERSONAL DATA WILL Zapz COLLECT?

 

3.1 The personal data Zapz may collect includes, but is not limited to:

  • name;

  • email address;

  • date of birth;

  • billing address;

  • bank account and payment information;

  • phone number;

  • sex;

  • information submitted or associated with the device(s) used to access our Services or Platform;

  • Information about your internet network, as well as personal and accounts that you have interacted with; 

  • Recordings and files of photos, audios or videos you have shared with Zapz

  • Identification documents issued by the competent public authorities and/or other information required due to our audits, know-your-customer process, verification and validation of user identity, as well as for fraud prevention and anti-money laundering processes; 

  • any other information about you when you sign up to use our Services or Platform and when you use the Services or Platform, as well as information related to how you use our Services or Platform; and

  • aggregate data about the content with which the User engages.

3.2 You agree not to submit any inaccurate or misleading information to us, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right, at our sole discretion, to require additional documentation to verify the information provided by you.

 

3.3 If you sign up as a user of our Platform using your social media account ("Social Media Account"), link your Zapz account to your Social Media Account, or use any of Zapz's social media features, we may access information about you that you have voluntarily provided to the provider of your Social Media Account in accordance with that provider's policies, and we will manage and use that personal data in accordance with this Policy at all times. 

 

3.4 If you do not wish us to collect the above mentioned information / personal data, you may opt-out at any time by notifying our Data Protection Officer in writing. More information about opting out can be found in the section below entitled "How can you withdraw consent, remove, request access to, or modify information you have provided to us?" Please note, however, that deleting or withdrawing your consent to collect, use or process your personal data may affect your use of the Services and the Platform.  For example, disabling the collection of location information will cause your location-based features to be disabled.

 

4. GATHERING OTHER DATA

 

 

4.1 As with most websites and mobile applications, your device sends information that may include data about you that is recorded by a web server when you browse our Platform. This typically includes, without limitation, the IP address of your device, your computer/mobile device's operating system and browser type, mobile device type, the characteristics of your mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) of your mobile device, the address of a referring website (if any), the pages you visit on our website and mobile applications and the times of your visit, and sometimes a "cookie" (which can be disabled using browser preferences) to help the website remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in the anonymous statistics to allow us to understand how visitors use our site.

 

4.2 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more purposes, including, without limitation, the location-based services you request or to provide you with relevant content based on your location or to allow you to share your location with other Users as part of the services in our mobile applications. For most mobile devices, you can withdraw your permission for us to obtain this information about your location through your device settings. If you have questions about how to disable location services for your mobile device, please contact your mobile device service provider or device manufacturer.

 

4.3 When you view pages on our website or mobile application, as well as when you view content and advertisements, advertisements, and access any software on our Platform or through the use of our Services, most of the same information listed above is sent to Zapz (including, without limitation, IP address, operating system, etc.); however, instead of page views, your device will send us information about the content, advertisement viewed and/or software installed by the Services and the Platform and the time they were accessed. 

 

 

5. COOKIES

 

5.1 From time to time, Zapz or its authorized service providers and partners, may use "cookies" or other functionality to allow third parties to collect or share information regarding your use of the Services or the Platform. It is precisely such functionality that will help us improve our Platform and the Services we offer, or help us offer new services and features. "Cookies" are identifiers that we store on your computer or mobile device record data about your computer or device, how and when the Services or Platform are used or visited, by how many people, and other activities on our Platform. We may link information from cookies to personal data. Cookies also link information about the items you have selected for purchase and the web pages you have viewed. This information is used to track your shopping cart and to provide content specific to your interests and monitor your use of the Services.

 

 

5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do so, you may not be able to use the full functionality of our Platform or the Services.

  

6. HOW DO WE USE THE INFORMATION YOU PROVIDE US?

 

 

6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

 

  • consider and/or process your application/transaction with us or your transactions or communications with third parties through the Services;

  • manage, operate, provide and/or administer your use of and/or access to our Services and our Platform (including, without limitation, remembering your preferences), as well as your relationship and user account with us;

  • respond, process, handle or complete a transaction and/or fulfill your requests for certain products and services and notify you of service problems and unusual account actions;

  • enforce our Terms of Service or any applicable end user license agreements;

  • protect personal safety and the rights, property or safety of others;

  • for identification, verification, audits, "know your customer" processes, fraud and money laundering prevention and combat;

  • maintain and administer any software updates and/or other upgrades and support that may be required from time to time to ensure the proper functioning of our Services;

  • to handle or facilitate customer service, carry out your instructions, handle or respond to any inquiries made by (or supposed to be made by) you or on your behalf;

  • contact or communicate with you by voice call, text message and/or fax, email and/or postal mail or otherwise for the purpose of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating to you administrative information related to our Services. You acknowledge and agree that such communication by us may be by means of correspondence, documents or notices to you, which may involve the disclosure of certain personal data about you in order to provide for their delivery, as well as on the outside cover of envelopes / mail packages;

  • to allow other Users to interact, connect with you or view some of your activities on the Platform, including to inform you when another User sends you a private message or posts a comment to you on the Platform or in connection with your use of social interaction features on the Platform;

  • conduct research, analysis and development activities (including but not limited to data analysis, surveys, product and service development and/or profiling), analyze how you use our Services, improve our Services or products and/or enhance your customer experience;

  • allow audits and surveys to, among other things, validate the size and composition of our target audience and understand their experience with Zapz Services;

  • for marketing and advertising, in that sense, send you by various modes of marketing communication, information and promotional and related materials about products and/or services (including, without limitation, products and/or services of third parties with which Zapz may collaborate or partner) that Zapz (and/or its affiliates or related companies) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function on electronic marketing materials. We may use your contact information to send you newsletters from us and our related companies;

  • to respond to legal process or comply as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or when Shope, in good faith, believes that the provision of such information is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on Zapz or its related representatives or affiliates (including, where applicable, providing your name, contact and business details and the relevant legal entity)

  • prepare statistics and research for internal and statutory reporting and/or record keeping requirements;

  • perform due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that have been implemented by us;

  • audit our services or Zapz's business;

  • to prevent or investigate any suspected or actual violation of our Terms of Service, fraud, illegal activity, omission or misconduct, whether related to your use of our Services or any other matter arising from your relationship with us;

  • to respond to any threats and/or claims made against Zapz or other claims where any Content violates the rights of third parties;

  • to store, host, backup (whether for disaster recovery or otherwise) your personal data within or outside your jurisdiction;

  • to handle and/or facilitate a business transaction or a potential business transaction, where such transaction involves Purchaser as a participant or involves only one corporation or affiliate related to Purchaser as a participant or involves Purchaser and/or any one or more Corporations or affiliates related to Purchaser as participant(s), and there may be other third party organizations participating in such transaction. A "business transaction" means the purchase, sale, lease, leaseback, merger, or any other acquisition, disposition or financing of an organization or part of an organization or of any business or asset of an organization; and/or

  • any other purposes of which we notify you at the time of obtaining your consent. 

(collectively, the "Goals").

 

6.2 You acknowledge, consent and agree that Zapz may access, preserve and disclose your account information and Content if required by law or court order or by any competent governmental or regulatory authority with jurisdiction over Zapz or in a good faith belief that the preservation or disclosure of access is reasonably necessary to: (a) comply with due process and/or legal obligations; (b) comply with a request from any competent governmental or regulatory authority with jurisdiction over Zapz; (c) enforce Zapz's Terms of Service, this Privacy Policy and other Zapz Policies and Regulations; (d) respond to any threat or actual claim made against Zapz or claim that any Content violates the rights of a third party; (e) respond to your customer service requests; or (f) protect the rights, property or personal safety of Zapz, its users and/or the public. 

 

6.3 As the purposes for which we will collect, use, disclose or process your personal data depend on the circumstances at hand, this purpose may not appear above. However, we will notify you of this other purpose at the time of obtaining your consent, unless processing the applicable data without your consent is permitted under Privacy Laws.

 

7. HOW DOES Zapz PROTECT AND RETAIN CUSTOMER INFORMATION?

 

 

7.1 We have implemented a variety of efforts and security measures to ensure the security of your personal data on our systems. Your personal data is contained in secured networks and is only accessible by a limited number of employees who have special access rights to these systems. However, inevitably there is no way to grant absolute security guarantees.

 

7.2 We will retain your personal information in accordance with Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which such personal data was collected is no longer being served by retaining such personal data; (ii) retention is no longer necessary for legal or business purposes; and (iii) no other legitimate interest justifies the retention of such personal data. If you stop using the Platform, or if your permission to use the Platform and/or the Services is terminated or withdrawn, we may continue to store, use and/or disclose your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your Personal Data without prior notice.

 

 

8. Does Zapz DISCLOSES INFORMATION COLLECTED FROM ITS VISITORS TO EXTERNAL ENTITIES?

 

8.1 In conducting our business, we will need/may disclose your personal data to our service providers, agents and/or our affiliates or related companies and/or other third parties located in Singapore or outside Singapore for one or more of the Purposes mentioned above. These service providers, agents and/or our affiliates or related companies and/or other third parties would be processing your personal data on our behalf or otherwise for one or more of the above Purposes. Such third parties include, without limitation:

  • our subsidiaries, affiliates and related companies;

  • buyers or sellers with whom you have interacted or transacted through the Platform or in connection with your use of the Services in connection with such purpose;

  • other users of our Platform for one or more of the purposes mentioned above;

  • contractors, agents, service providers and other third parties that we use to support our business. This includes, but is not limited to, those parties that provide us with administrative or other services, such as postal distribution, logistics, general financial and payment processing services, telecommunications companies, information technology companies and data centers;

  • governmental authorities and competent regulatory bodies that have jurisdiction and control over Zapz's activities, as permitted in item 6.2 above

  • a purchaser or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of Zapz, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where personal data held by Zapz about our Service Users is among the transferred assets; or to a counterparty in a business asset transaction in which Zapz or any of its affiliates or related companies is involved; and

  • third parties to whom disclosure by us is for one or more Purposes, and these third parties would in turn collect and process your personal data for one or more Purposes

8.2 This may require, among other things, Zapz to share statistical and demographic information about our Users and information about your use of Services with advertising and programming providers. This would not include anything that could be used to specifically identify you or to discover individual information about you.

 

8.3 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organization such as us to collect, use or disclose your personal data without your consent, that permission granted by the laws will continue to apply.

 

8.4 Third parties may unlawfully intercept or access personal data transmitted or contained on the Website, technologies may malfunction or not work as expected, or someone may access, abuse or misuse the information through no fault of our own. We will, however, implement reasonable security measures to protect your personal data as required by Privacy Laws; inevitably, however, there is no guarantee of absolute security, such as, without limitation, unauthorized disclosure by malicious and sophisticated hackers through no fault of ours.

 

8.5 If available in your territory, Zapz may allow you to share YouTube videos on the Zapz Livestream feature ("YouTube Content"). To facilitate this, Zapz uses the YouTube API (systems integration) services made available by YouTube. By using YouTube Content sharing, you agree to abide by the Google Privacy Policy (http://www.google.com/policies/privacy).

 

9. INFORMATION ON CHILDREN

 

 

9.1 The Services are not intended for children under the age of 13. We do not knowingly collect or maintain personal data or non-personally identifiable information from children under the age of 13 nor is part of our Platform or other Services directed to children under the age of 13. Parents or legal guardians should not allow children under their responsibility to submit personal data to Zapz. In the event personal data of children under the age of 13 under your responsibility is shared with Zapz, you, as the legal guardian, hereby consent to the processing of such child's personal data and accept and agree to the provisions of this Policy on behalf of such child.  We will terminate all accounts used solely by such children and remove and/or delete personal data that we believe has been submitted, without parental and/or legal guardian consent, by children under the age of 13.

 

10. INFORMATION COLLECTED BY THIRD PARTIES

 

 

10.1 Our Platform uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyze how Users use the Platform. The information generated by the cookies about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Platform, producing reports on website activity for operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law or where Google has delegated third parties to process such information. Google will not associate your IP address with any other data held by Google.

 

10.2 We and third parties may from time to time make available software application downloads for your use through the Platform or through the Services. These applications may separately access and allow third parties to view your identifiable information, such as your name, your user ID, the IP address of your device, or other information such as cookies that you may have previously installed or that were installed for you by a third party software application or website. In addition, these applications may ask you to provide additional information directly to the third party. Third party products or services provided through these applications are not owned or controlled by Zapz. You are encouraged to read the terms and other policies posted by third parties on their websites or otherwise.

 

11. DISCLAIMER RELATING TO SECURITY AND THIRD PARTY SITES

 

 

11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY WEBSITES. We implement a variety of security measures to maintain the safety of your personal data in our possession or under our control. Your personal data is contained on secured networks and is accessible only by a limited number of persons who have special access rights to these systems and are required to keep personal data confidential. When you order or access your personal data, we offer the use of a secure server. Any personal data or confidential information that you provide is encrypted in our databases to be accessed only as indicated above.

 

11.2 In an attempt to provide greater value to you, we may choose various third party websites to link to and frame within the Platform. We may also participate in co-branding and other relationships to provide e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies and security agreements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-branded partners or third party websites (even if offered on or through our Platform) may not be received by us.

 

11.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are for your convenience only and you therefore access them at your own risk. However, we seek to protect the integrity of our Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

 

12. will zapz transfer your information overseas?

 

 

12.1 Your personal data and/or information may be transferred to, stored or processed outside of your country. In most cases, your personal data will be processed in Singapore where our servers are located and our central database is operated. In order to enable Zapz to provide its services effectively and safely, your personal data and information may be transferred internationally to other countries and/or territories, especially in the case where third party services are used to enable Zapz to perform its activities. In any case, Zapz will only transfer your information abroad in accordance with applicable Privacy Laws and to countries, jurisdictions and/or data centers that provide an adequate level of protection for personal data.

 

 

13. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS OR CORRECT THE INFORMATION YOU HAVE PROVIDED TO THE U.S.?

 

13.1 Withdrawal of Consent

 

13.1.1 You may withdraw your consent to the collection, use and/or disclosure of your personal data held by us or under our control by sending an e-mail to our Personal Data Protection Officer at [email protected], and we will process the request in accordance with this Privacy Policy as well as our obligations under privacy and other applicable laws.

 

13.2 Requesting Access to or Correction of Personal Data

 

13.2.1 If you have an account with us, you may personally access and/or correct your personal data currently held or controlled by us through the Account Settings page on the Platform. If you do not have an account with us, you may request access and/or correction of your personal data currently held or controlled by us by submitting a written request to us. We will need sufficient information about you to verify your identity and the nature of your request in order to be able to fulfill your request. Therefore, please submit your request in writing by sending an e-mail to our Personal Data Protection Officer at [email protected]

 

14.2.2 We reserve the right to only fulfill requests from Users with regard to their personal data in accordance with the provisions set forth in the applicable privacy and data protection legislation, including where the legislation may permit the controller and/or operator of the personal data to refuse to comply with requests from personal data subjects in certain circumstances and/or upon fulfillment of specific requirements by the data subjects.

 

14. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US

14.1 If you have any questions or concerns about our privacy practices, please contact us at [email protected]