Our Commitment To You
At Zap (the “Company”, “we”, “us”, “our”), the privacy of its users, consumers, clients, service providers, distributors, retailers, suppliers and other individuals (“you”, “your”) is a top priority. Your privacy is at the core of the way we design and build the services and products we provide to you. We appreciate that you put your trust in us when you provide us with your personal information and we do not take this lightly.
We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We strive to be transparent in the way we process your data. We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your personal information.
Collection of Your Personal Information
We are the controller and the responsible party for your personal information. We may collect personal information in connection with your use of the Platform or with your use or purchase of the Company’s products and services, which may include personal information provided in connection with your use of the Platform.
When you use our Platform, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our Platform. The personal information that we may collect may include:
(a) Information you provide to us when you are:
(i) Registering for an account and creating a profile, you provide us with your name, email addresses, your age, date of birth, gender, residential address, your telephone number, government identification numbers and other relevant information, photo, signature and certain background information. You may also provide us with your government issued identification (or copies thereof). By choosing to provide this information, you consent to our processing of that information;
(ii) Participating in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials;
(iii) Registering or filling in forms on the Platform;
(iv) Purchasing any product or service from the Company and/or when you subscribe to a paid service or make a purchase directly from us (rather than through a third-party platform), you provide us or our payment service provider with information, such as your credit card and debit card numbers (with expiration dates and CVV) or other financial information. We use Transport Layer Security (TLS) encryption technology to encrypt sensitive personal information (such as your payment information) before it travels over the internet. Credit card numbers are never stored on our database or servers; however, we use third-party providers to process any payments made by you and such third-party providers may store your personal information on their databases and/or servers;
(v) Reviewing any product or service from the Company;
(vi) Participating in our promotions, events or contests and in such instances, we collect the information that you use to register or enter;
(viii) Requesting information or assistance from the Company. This includes information you may provide when you request additional information about the Company’s products and services or sign up to receive the Company’s e-mail newsletters or coupons. The Company may also keep a copy of any communications or correspondence you may send to it, including any e-mail communications; and
(ix) Using other features, including Interactive Functions (as such term is defined in the Platform’s Terms and Conditions of Use (the “Terms and Conditions”)) of the Platform that may be offered from time to time, and may require such information in order to utilize the feature (including but not limited to making a User Submission as defined in the Terms and Conditions);
(i) Other users may provide information about you as they use our products and services. We may also collect information about you from other users if they contact us about you;
(ii) Instead of registering for an account with our Platform directly, you may log in to the Platform using sign-in services such as Facebook. Such sign-in features eliminate the need for you to create a username and password for our Platform and allow you to authenticate your account using your existing social media identity and pre-verified user account. These services will also provide you with the option to share certain personal information with us such as your name and email address. Prior to using any such sign-in services, please review the privacy policies of these social media providers as they may have different policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the operators of these social media platforms; and
(iii) We may receive personal information about you from our affiliates or service providers. We may supplement the information we collect about you through the Platform with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, websites on which we have placed advertisements, such as Google Ad Network and Facebook Ad Network may tell us which ads about the Company you clicked on.
(c) Information collected when you use the Platform. When you use our Platform, we collect information about which features you’ve used, how you’ve used them and the devices you used to access our Platform, for instance, we collect information:
(i) About your activity on our Platform (for example, date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on, etc.);
(ii) About the device(s) you use to access our Platform including:
- hardware and software information such as manufacturer, model, IP address, device identification and type, operating system and identifiers associated with cookies or other technologies that may uniquely identify your device or browser (such as, IMEI/UDID and MAC address);
- information on your wireless and mobile network connection such as, your service provider and signal strength and information on device sensors (such as accelerometers, gyroscopes and compasses);
(iii) From the device(s) you use to access our Platform including your:
- address book and contacts saved to your device; and
- device-specific and application settings and characteristics, application crashes, advertising IDs (such as Google LLC’s AAID and Apple Inc.’s IDFA), browser type, version and language, time zones, etc.; and
(iv) Other information with your consent such as:
- your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, magnetic field sensors, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the Platform if the permission you gave us expressly permits such collection;
- your photos, images and videos (for instance, if you want to publish a photo, video or streaming on the Platform); and
- any other personal information that you choose to include in your profile, your User Submissions (as defined in the Terms and Conditions) or in other communications to the Company.
We may collect personal information even when you are not using the Platform. We may combine personal and non-personal information about you collected by us or by our affiliates, retailers, distributors and other third parties with whom we have a relationship, and we may combine this information with information from external sources.
In obtaining your consent to collect, use, maintain, retain, transfer and disclose your personal information we will use reasonable efforts to inform you of the purpose for which personal information will be collected, used, maintained, retained, transferred or disclosed. The form of consent may vary depending on the circumstances and type of information disclosed. We will take into account the sensitivity of the personal information and your reasonable expectations when determining the appropriate form of consent.
You may voluntarily submit personal information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, registering for an account, purchasing a product or service, creating an account, reviewing a product or service provided by the Company, subscribing to a newsletter or a mail or e-mail list and participating in contests and surveys. If you are a registered user on the Platform, we may combine and store personal information about your use of the Platform and information you have provided to us with certain other online and offline information we may have collected.
We may send you marketing or promotional e-mail communications. In this process, we may collect certain information such as the date and time you first opened our e-mail communications, the number of times you open our e-mail communications, the number of instances you click through our articles and your total click-through activity on the contents of our e-mail communications. We may also combine and store any such information to manage and improve our e-mail communications. If you no longer wish to receive any future marketing or promotional material from us, our promotional e-mail communications will include instructions on how to unsubscribe and inform us of your preferences.
There are different types of cookies including:
(a) First-party cookies which are cookies placed on your device directly by us;
(b) Third-party cookies which are cookies placed on your device by our affiliates and service providers;
(c) Session cookies which only last until you close your browser or exit the Platform. We use session cookies for various reasons, including to learn more about your use of our Platform during one single session and to help you to use our Platform more efficiently; and
(d) Persistent cookies which have a longer lifespan and are not automatically deleted when you close your browser or exit the Platform. These types of cookies are primarily used to help you quickly sign-in to our Platform again and for analytical purposes.
When you use our Platform, some or all of the following types of cookies may be set on your device:
(a) Essential website cookies: we use such cookies to provide you with the products and services available on our Platform and to use the features of our Platform;
(b) Analytics cookies: we use such cookies to understand how you use our Platform and how effective our marketing campaigns are and help us customize and improve our Platform for you;
(c) Advertising cookies: we use such cookies to make our advertising messages more relevant to you for instance by preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on your interests and measuring the number of ads displayed and their performance; and
Unless you specifically inform us (for instance, by sending us correspondence from the Platform), we will not know who you are. You can reset your browser either to notify you when you receive a cookie or refuse to accept cookies. If you refuse to accept cookies, you may not be able to use some of the features available on the Platform.
We would like to provide you with some information about controlling your cookie settings. Some web browsers allow you to control or reject cookies or to alert you when a cookie is placed on your computer. Please review the specific steps involved for such settings in your particular browser help menu as each browser uses different procedures. You also may be able to reset device identifiers by activating the appropriate setting on your device. The procedure for managing device identifiers is slightly different for each device so please review the specific steps in the help or settings menu of your particular device. With respect to interest-based advertising tools, you may opt out of seeing online interest-based advertising from participating companies by using the following applications: (a) the Digital Advertising Alliance; (b) the Interactive Digital Advertising Alliance; or (c) App-choices. Please note that opting out does not mean you will not see any advertisements; it only means that you won’t see personalized advertisements from the companies that participate in the opt-out programs. Lastly, if you delete cookies on your device after you opted out, you will need to opt-out again.
Third Party Websites
We may also include links to other websites on the Platform or in our e-mail communications. These third-party websites may collect your personal information and they may have different privacy policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the third parties operating these third-party websites. We strongly encourage you to read the privacy policies of these websites to enable you to make an informed decision whether or not to provide your personal information to these websites’ operators.
Protection of Your Personal Information
To: (a) prevent unauthorized access to, or disclosure of, personal information; (b) maintain data accuracy; and (c) facilitate the appropriate use of your personal information; we use physical, technological and administrative procedures to protect your personal information that we collect from loss, unauthorized access, modification, unauthorized disclosure or other misuse. Nevertheless, internet or wireless transmissions are never completely private or secure. You understand that any messages, content or information you send or submit through the Platform may be read or intercepted by others. If you have any questions about the security of your personal information collected by us, please contact the Company’s Privacy Officer at the address below.
Use of Your Personal Information
Once we collect your personal information, we may use such personal information internally, separately or in combination with any pre-existing information for the following purposes:
(a) To provide our products and services to you, including:
(i) To administer your account;
(ii) To assist with billing and the collection of accounts;
(iii) To provide you with transaction receipts;
(iv) To process and fulfill your order, including to send you emails to confirm your order status, and other related emails;
(v) To develop, enhance, market, sell or otherwise provide information, products or services;
(vi) To contact you and to respond to any communications that you may have had with us;
(vii) To conduct or administer contests, sweepstakes or other promotions in which you have participated; and
(viii) To distribute our newsletters and other informational e-mail communications and other material to individuals on our mail and e-mail lists;
(b) To ensure consistent experience with our Platform across all of your devices, including:
(i) To troubleshoot problems with the Platform;
(ii) To customize your experience or homepage on the Platform;
(iii) To obtain your feedback on the Platform, our products and services; and
(iv) To establish and conduct commercial relationships, including to process transactions and to conduct or administer other transactions that you may engage in with us;
(c) To improve our products and services and to develop new products and services, including:
(i) To evaluate our service providers and their qualifications;
(ii) To help us learn more about your preferences; and
(iii) To conduct surveys, research, evaluations and measurement activities;
(d) To prevent, detect and fight fraud or other illegal or unauthorized activities, including:
(i) To detect, and to protect the Company and other third parties against, error, negligence, breach of contract, fraud, theft and other illegal activity; and
(ii) To audit compliance with our policies and contractual obligations;
(e) To ensure legal compliance, including:
(ii) As permitted by, and to comply with, any legal or regulatory requirements or provisions; and
(iii) To use, maintain, retain, transfer and disclose your personal information if the Company is required to do so by law or legal process or if the Company determines, in its sole discretion, that such action is necessary to protect the rights of the Company, third parties and other users of the Platform or to respond to your request for customer service; and
(f) For our business purposes, including:
(i) To engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving the Company;
(ii) To market, sell or otherwise provide products and services of third parties with whom we have a commercial relationship;
(iii) To develop and manage our business and operations; and
(iv) For any other purpose to which you consent.
To process your information as described above, we rely on the following legal bases:
(a) The primary reason we process your personal information is to perform the contract that you have with us for instance to maintain your account and to offer our products and services to you;
(b) We may use your personal information where we have legitimate interests to do so for example to improve our products and services by analyzing users’ behavior on our Platform and for administrative, fraud detection and other legal purposes; and
Disclosure of Your Personal Information
Occasionally, we may disclose your personal information to:
(a) Third party service providers or vendors: for instance, third party service providers or vendors with whom we have a contractual relationship, an organization or individual retained by us to collect outstanding debts, our financial institution and our distributors and retailers;
(b) A person who, in our reasonable judgment, is providing or seeking the information as your agent;
(c) Our personnel or contractors;
(d) Government authorities, regulatory agencies, insurers, benefits providers, consultants or agents; and
(e) Any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.
In certain situations, we may use, maintain, retain, transfer or disclose your personal information without your knowledge or consent (as permitted or required by law). Such situations may be:
(a) Where your personal information is publicly available;
(b) Where collection or use of the personal information is unmistakably in your interests and consent cannot be obtained in a timely manner;
(c) To investigate a breach of an agreement or a contravention of law;
(d) In the event of a corporate change in control of the Company resulting from, for example, a merger, a reorganization, a sale of assets or bankruptcy;
(e) To comply with a subpoena, warrant, court order or as required or otherwise permitted by law; and
(f) When information is being collected for the detection and prevention of fraud or for law enforcement.
Retention of Your Personal Information
After we have collected your personal information, we may retain a record of your personal information (including correspondence or comments). We will continue to use, maintain, transfer, disclose or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and as required or permitted by law. However, we will take reasonable steps to destroy or permanently de-identify personal information we hold if it is no longer needed for our business purposes.
Cross-border Data Transfers
Sharing your personal information sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. To increase our efficiency, we use password-protected electronic file storage on cloud servers based outside of Canada, in countries where laws regarding collection, use, maintenance, transfer and disclosure of personal information may be less stringent than the laws in Canada. We do not assume any responsibility for the privacy practices, policies or actions of such cloud server providers or of any governmental authority of the country in which such cloud servers are based.
Control of, Access to, and Correction of, Your Personal Information
You may request a copy of the personal information which you have provided to us by advising our Company’s Privacy Officer at the address provided below. If you have any questions or enquiries relating to our privacy practices or procedures, or if you believe that the personal information that the Company holds about you is not accurate, complete or up-to-date, you may write to the Company’s Privacy Officer at the address provided below. If you are able to establish that the information is not accurate, complete or up to date, we will take reasonable steps to correct the information so that it is accurate, complete and up-to-date. We may ask you to provide proof of identity before we can answer the above requests.
Questions or Comments