Effective as of February 22nd 2023
This Privacy Policy describes the privacy practices of ii USA Corporation (d/b/a Zoopcards), wholly owned by ii Corporation Ltd. (d/b/a influencer index), (collectively, the “Company”, "we", “us” or "our") and how we handle your personal data when you visit our websites, zoop.club, app.zoop.club, celebrity.zoop.club, and policy.zoop.club (collectively, the “Websites”), any related sites, pages, applications, services and goods or any other website operated by us that links to this Privacy Policy including our “Zoop Connect” app available on the iOS App Store and on the Google Play App Store (the “Services”). The purpose of this Privacy Policy is to provide you with a clear explanation of what personal data we collect, when, why and how we collect, use and share your personal data and it explains your statutory rights.
We strongly urge you to read this Privacy Policy and make sure you fully understand our practices in relation to personal data before you use our Services.
If you are located in the European Economic Area or the United Kingdom, please consult the EEA/UK GDPR supplemental notice below. If you are located in the State of California, please consult the notice to California residents below.
1. Personal data we collect
1.1 Information you provide to us. Personal data is data that can be used to contact or identify you, such as your name, email address, phone number, etc.
Personal data you may provide to us through our Services, or otherwise, includes:
(a) Contact data, such as your first and last name, email address, billing and mailing addresses, and phone number.
(b) Profile data, such as the username and password that you may set to establish an online account with us, photograph, biographical information, links to your profiles on social networks, non-fungible token (“NFT”) holdings, digital wallet addresses, membership communities associated with your account, and any other information that you add to or is associated with your account profile.
(c) Communications data, such as data that we exchange with you, including when you contact us with questions or feedback, through our Services, social media, or otherwise.
(d) Payment and transactional data, such as data relating to, or needed to complete, your purchases (whether primary or secondary purchases) on or through our Services (including payment card information and billing information), digital wallet information, and your purchase history.
(e) Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
(f) User-generated content, such as photos, images, comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on our Services, as well as associated metadata.
(g) Government-issued identification numbers, such as national identification number (e.g. Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card or any other data required for ‘Know Your Customer’ checks.
(h) Job application data, such as professional credentials and skills, educational and work history, LinkedIn profile page, personal website, authorization to work in the U.S., immigration status, criminal history, and other information that may be included on a resume or curriculum vitae as well as in a cover letter. This may also include diversity information that you voluntarily provide.
(i) Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
1.2 Third-party sources. We may combine personal data we receive from third party vendors and/or other commercially available sources with the personal data we collected. The third party sources from which we may receive personal data are:
(a) Public sources, such as social media platforms and other publicly available sources.
(b) Data providers, such as information services and data licensors that provide demographic and other information.
(c) Third party vendors, such as service providers providing fraud warnings or enrichment service providers to enhance and personalize your user experience.
(d) Marketing partners, such as joint marketing partners and event co-sponsors.
1.3 Automatic data collection. We may automatically collect data about you, your computer or mobile device while you access, browse, view or otherwise interact with our Services, the data we collect may include:
(a) Device data, such as your computers or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
(b) Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our Website, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.
1.4 Cookies and similar technologies. We use cookies and similar technologies (such as web beacons, pixels, tags and scripts) to improve and personalize your experience, provide our Services, analyze website performance and for marketing purposes. To learn more about how we use cookies and your control over these cookies, please see our Cookie Policy.
1.5 Data about others. Users of our Services may have the opportunity to refer friends or other contacts to us and share their contact data with us. Please do not refer someone to us, or share their contact data with us, unless you have their permission to do so.
2. How we use your personal data
We may use your personal data for the following purposes or as otherwise described at the time of collection:
2.1 Service delivery. We may use your personal data to:
(a) provide, operate and improve our Services and our business;
(b) establish and maintain your user profile for our Services;
(c) conduct Know Your Customer checks and other screens permitted by law when you set up an account;
(d) verify your identity when you place a bid on an NFT;
(e) process your payments and complete transactions with you when you purchase or trade a NFT;
(f) connect to your virtual wallet when you wish to add or withdraw funds from your virtual wallet;
(g) connect to your virtual wallet to confirm ownership of Zoop cards;
(h) [facilitate invitations to friends who you want to invite to join our Services;]
(i) [enable security features of our Services, such as (for example) by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;]
(j) communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;
(k) understand your needs and interests, and personalize your experience with our Services and our communications;
(l) enable communication with other Service users;
(m) facilitate online gaming with other Service users; and
(n) provide support for our Services, and contact you where requested or respond to your requests, questions and feedback.
2.2 Research and development. We may use your personal data for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified or anonymous data from personal data we collect. We make personal data into anonymous data by removing data that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.
2.3 Marketing and advertising. We may collect and use your personal data for marketing and advertising purposes:
(a) Direct marketing. We may send you direct marketing communications about our products, services or promotions that may be of interest to you. Our processing of your personal data for marketing purposes is based on our legitimate interest, or on your consent, or as otherwise permitted by applicable laws. You have the right to prevent direct marketing of any form at any time, this right can be exercised by following the opt-out link attached to each communication. or by sending an email to support@zoop.club
(b) Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads on other online services. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Advertising choices section below.
2.4 To manage our recruiting and process job applications. We may use personal data, such as data submitted to us in a job application, to facilitate our recruitment activities and process job applications, such as by evaluating a candidate for a job, and monitoring recruitment statistics.
2.5 Compliance and protection. We may use your personal data to:
(a) comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
(b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
(c) audit our internal processes for compliance with legal and contractual requirements or our internal policies;
(d) maintain appropriate business records;
(e) enforce the terms and conditions that govern our Services; and
(f) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
2.6 With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal data, such as when required by law.
2.7 To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal data and other individuals whose personal data we collect. We make personal data into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve our Services, promote our business or marketing purposes.
3. How we share your personal data
We may share your personal data with third parties as detailed below and as otherwise described in this Privacy Policy.
(a) Affiliates. We may share your personal data with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
(b) Service providers. We share personal data with those third parties who provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).
(c) Payment processors and fraud detection service providers. We share personal data with payment processors and fraud detection service providers for the purposes of facilitating payments done via the Services and securing the Services and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.
(d) Advertising partners. We may share your personal data with third-party advertising companies for the interest-based advertising purposes described above.
(e) Third-party platforms. If you have enabled features or functionality that connect our Services to a third-party platform (such as by linking your account to a third party’s services), we may disclose the personal data that you authorized us to share. We do not control the third party’s use of your personal data and such third party’s use will be in accordance with such party’s privacy policy.
(f) Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
(g) Government Agencies, regulators, and others. We may share personal data with law enforcement agencies, public authorities or other parties: (i) in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; (ii) when we believe it necessary or appropriate to disclose personal data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Privacy Policy; (iii) to respond to claims against us; and (iv) to protect the rights, property, or personal safety of our staff, our customers or the public.
(h) In the context of a corporate transaction. Personal data may be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of our assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If all, or substantially all, of our assets are acquired by a third party, data held by us about our users will be one of the transferred assets.
(i) Other users. Your personal data, such as your profile information and user-generated content, may be visible to other users of our Services. For example, other users may have access to your profile or content through the course of your use of our Services, such as when you purchase or trade an NFT, participate in a game, join a membership community, or publish comments. Where your personal data can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), we are not responsible for any such use of data.
4. Your choices
You have the following choices with respect to your personal data. Users who are located in the European Economic Area (“EEA”), United Kingdom or the State of California can find additional information about their rights below.
4.1 Access or update your information. If you have registered for an account with us through our Services, you may review and update certain account information by logging into the account.
4.2 Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us through the contact details set out in the ‘How to contact us’ section below. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
4.3 Advertising choices. You can limit use of your information for interest-based advertising by:
(a) Browser settings. Blocking third-party cookies in your browser settings.
(b) Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
(c) Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:
(i)Google: https://adssettings.google.com/
(ii) Facebook: https://www.facebook.com/about/ads
(d) Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
(i) Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
(ii) Digital Advertising Alliance: optout.aboutads.info.
(iii) AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
You will need to apply these opt-out settings on each device from which you wish to opt-out.
Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked to above.
4.4 Declining to provide information. We need to collect personal data to provide certain services. If you do not provide that data we identify as required or mandatory, we may not be able to provide those services.
4.5 Third-party platforms. If you choose to connect to our Services through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
5. Other sites and services
Our Services may contain links to third party websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into websites or other online services that are not associated with ours. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of each of the other third-party websites, mobile applications and online services you visit.
6. How long do we keep your personal data
We apply a general rule of keeping personal data only for so long as is required to fulfil the purpose for which it was collected. However, in some circumstances, we will retain your personal data for longer periods of time. We will retain personal data for the following purposes: (i) as long as it is necessary and relevant for our operations and to provide our Services, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and (ii) in relation to personal data from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Service terms and take other actions as permitted by law.
7. Security
We implement a number of technical and organizational safeguards designed to maintain the security of our Services in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. However, security risk is inherent in all internet and information technologies and the transmission of personal data via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted through the Service. Users who have registered for our Services agree to keep their password in strict confidence and not to disclose such password to any third party.
8. International data transfer
Some of the personal data you provide to us will be stored or processed on our behalf by third parties and may be located in other jurisdictions, such as the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in the United Kingdom and the EEA should read the important information provided in the EEA/UK supplemental notice below about transfer of personal data outside of the EEA and UK, as applicable.
9. Children
Our Services are offered and available to users who are at least 16 years of age or older and of legal age to form a binding contract. Users under 16 are only permitted to use our Services through an account owned by a parent or legal guardian with their appropriate permission. Users under 16 are not permitted to use the Website or our Services. We do not knowingly collect personal data from children under 16. Parents or guardians should at all times supervise their children’s activities. If we learn that we have collected or received personal data from a child under 16, we will delete that personal data. If you believe we might have information from or about a child under 16, please contact us at support@zoop.club.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Website. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes.
10. How to contact us
To exercise any of your rights in connection with your personal data, please contact us at support@zoop.club.
If you have any questions (or comments) concerning this Privacy Policy, please contact us at support@zoop.club.
11. EEA/UK GDPR supplemental notice
If you are located in the European Economic Area or the United Kingdom, and access our Services, this EEA/UK GDPR supplemental notice applies to you.
11.1 Who is the Controller?
ii USA Corporation (d/b/a ZoopClub) with its address at 24A Trolley Square, 2138, Wilmington DE 19806, wholly owned by ii Corporation Ltd. (d/b/a influencer index) with its address at1008 Willow House, Cricket Square, Grand Cayman, KY1-1001(collectively, the “Company”), is the controller of your personal data. The Company is represented by RJ Phillips, the Chief Executive Officer.
Pursuant to Article 27 of the UK GDPR, we have appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR via the following methods:
i) by using EDPO UK’s online request form: https://edpo.com/uk-gdpr-data-request/
ii) by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), we have appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR via the following methods:
i) by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
ii) by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
We have appointed heyData GmbH (www.heydata.eu) as our EU Data Protection Officer. You can contact heyData via the following methods:
i) by email to dataprotection@heydata.eu
ii) by writing to heyData GmbH, Schützenstr. 5, 10117 Berlin, Germany
11.2 Our legal basis for using your personal data
Where relevant under applicable laws, all processing of your personal data will be justified by a "lawful ground" for processing as set out in the table below.
We may need to process your personal data for additional purposes, such as:
11.3 Your rights
Under applicable EU and UK data protection laws, you have the following rights in respect of your personal data:
(a) to obtain information about how and on what basis your personal data is processed and to obtain a copy;
(b) to rectify inaccurate personal data;
(c) to erase your personal data in limited circumstances where (i) you believe that it is no longer necessary for us to hold your personal data; (ii) we are processing your personal data on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (ii) where you have provided your personal data to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal data; and (iv) where you believe the personal data we hold about you is being unlawfully processed by us;
(d) to restrict processing of your personal data where: (i) the accuracy of the personal data is contested; (ii) the processing is unlawful but you object to the erasure of the personal data; (iii) we no longer require the personal data for the purposes for which it was collected, but it is required for the establishment, exercise or defence of a legal claim; or (iv) you have objected to us processing your personal data based on our legitimate interests and we are considering your objection;
(e) to object to decisions which are based solely on automated processing or profiling;
(f) where you have provided your personal data to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
(g) to obtain a copy of or access to safeguards under which your personal data is transferred outside of the EEA.
Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal data by us and we may be required to no longer process your personal data. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.
When you request us to provide the personal data we collect and process about you, we will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal data for a limited period of time for record-keeping, accounting and fraud prevention purposes.
You have the right to lodge a complaint with a supervisory authority in relation to the processing of your personal data, however, we invite you to contact us first. Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.
11.4 Cross-border data transfer
Your personal data may be transferred and stored outside your place of residence, to countries which are subject to different standards of data protection. In particular, if you live in the EEA, you should be aware that your personal data may be shared with, and transferred to, our affiliates and third-party service providers who are located outside the EEA. We will take appropriate steps to ensure that transfers of personal data are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end:
(a) we will ensure that transfers within our company and its affiliates will be covered by an agreement entered into by members of the company group (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred within the company group;
(b) where we transfer your personal data outside our company group or to third parties who help provide our Services, we will obtain contractual commitments from them to protect your personal data; and
(c) where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before personal data is disclosed.
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal data when this is transferred as mentioned above.
11.5 Newsletter
We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.
Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.
Based on the consent of our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR), we also measure the opening and click-through rate of our newsletters. We have a legitimate interest to understand what is relevant for our audience and to improve our newsletters.
We send newsletters with the tool Sendinblue of the provider Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin (privacy policy: https://www.sendinblue.com/legal/privacypolicy/). The provider processes content, usage, meta/communication data and contact data in the process in the EU.
11.6 Third-party Providers
(1) Hosting providers and Content Delivery Networks
The Websites are hosted by:
It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
The legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
We use the content delivery network Cloudfront (Amazon AWS) for our website. The provider is Amazon Web Services, Inc., P.O. Box 81226 Seattle, WA 98108-1226 USA. The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider's privacy policy at https://aws.amazon.com/privacy/?nc1=f_pr.
We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
Legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
(2) Zendesk
We use Zendesk for a live chat. The provider is Zendesk, Inc., 1019 Market St., San Francisco, CA 94103, USA. The provider processes content data (e.g. entries in online forms), contact data (e.g. e-mail addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses), and master data (e.g. names, addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.zendesk.com/company/customers-partners/privacy-policy/.
(3) Auth0
We use Auth0 to manage authentications. The provider is Auth0, Inc., 10900 NE 8th Street, Suite 700, Bellevue, WA 98004, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses), and master data (e.g. names, addresses) in the EU.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://auth0.com/privacy.
(4) Google Tag Manager
We use Google Tag Manager for analytics and for advertisement. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.
(5) Segment
We use Segment for analytics. The provider is Segment.io, Inc., 100 California Street Suite 700 San Francisco, CA 94111, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://segment.com/legal/privacy/.
(6) Facebook Pixel
We use Facebook Pixel for analytics. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.facebook.com/policy.php.
(7) Google Analytics
We use Google Analytics for analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.
(8) Onfido
We use Onfido for user verification. The provider is Onfido Limited 14-18 Finsbury Square, 3rd Floor, London EC2A 1AH United Kingdom. The provider processes names, pictures, contact data and further data included in identification documents in the UK.
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in only allowing users with verified identities to use our services in order to prevent offenses such as money laundering.
The legal basis for the transfer to a country outside the EEA is an adequacy decision by the EU commission.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://onfido.com/privacy/.
12. Notice to California residents
This section describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information. For the purposes of this section, the term “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. For the avoidance of doubt, the term ‘Personal Information’ used in this section should for the purposes of the main body of this Privacy Policy be interpreted as being ‘Personal Data’. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.
12.1 Your California privacy rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. Note, however, that these rights extend only to information that is maintained or controlled by us as part of your account or through your direct interactions with us and will not apply to information that is maintained publicly or that is otherwise outside of our control, such as data maintained on public blockchains.
(a) Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
(i) The categories of Personal Information that we have collected.
(ii) The categories of sources from which we collected Personal Information.
(iii) The business or commercial purpose for collecting and/or selling Personal Information.
(iv) The categories of third parties with which we share Personal Information.
(v) The categories of Personal Information that we sold or disclosed for a business purpose.
(vi) The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
(b) Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
(c) Deletion. You can ask us to delete the Personal Information that we have collected from you.
(d) Opt-out of sales. You can opt-out of any sale of your Personal Information.
(e) Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
12.2 Exercising your right to information, access and deletion. You may submit requests to exercise your right to information via email to support@zoop.club.
12.3 Notice of right to opt-out of the “sale” of your Personal Information. Like many companies, we use services that help deliver interest-based ads to you. Our use of some of these services may be classified under California law as a “sale” of your Personal Information to the advertising partners that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you. You can request to opt-out out of this “sale” of your personal information here: Do Not Sell My Personal Information, where you will find instructions on opting-out of the use of your information for interest-based advertising.
We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require government identification, a declaration under penalty of perjury or other information.
Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.
12.4 Personal information that we collect, use and disclose. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140), and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. The terms in the chart refer to the categories of information, sources, purposes and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.
Identifiers
California Customer Records (as defined in California Civil Code §1798.80)
Commercial Information
Financial Information
None
Internet or Network Information
Profile data
Inferences
May be derived from:
N/A
Protected Classification Characteristics
We do not intentionally collect this information but it may be revealed in identity data or other information we collect
N/A
N/A
N/A
No
Sensory Information
No
12.5 Your California privacy rights. California residents may send us requests to dsar@zoop.club for identification of third parties to whom we have disclosed your personal information during the preceding calendar year for such third parties’ direct-marketing purposes. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
