Zagger, Inc. (“we”, “us” or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose personal information that we obtain about visitors to our website at www.zaggerapp.com (the “Site”) and users of the services available through our Site, including any mobile applications (collectively, the “Services”), and how we use and disclose that personal information.
By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and the Terms of Use, including its applicable limitations on damages and provisions on the resolution of disputes.
The Information We Collect About You
We collect personal information about you directly from you and from third parties, as well as automatically through your use of our Site or Services.
Information We Collect Directly From You You may browse certain areas of the Site without registering with us or providing us personal information. If you register for our Services, then you must provide your name, Zagger type, nationality, email address, phone number, birthdate, gender, user location, and activity on the platform. In addition, we collect your personal information in the following other ways:
In addition, if you are providing personal information for third parties in connection with using our Services, you are responsible for ensuring that you have all required permissions and consents to provide such personal information to us for use in connection with the Services and that our use of such personal information to provide the Services does not violate any applicable law, rule, regulation, or order.
Information We Collect Automatically We may automatically collect the following information about your use of our Site or Services through cookies and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site or use our Services; and the referring URL, or the webpage that led you to our Site. We may combine this information with personal information that we have collected about you, including, where applicable, your username, name, and other personal information. Please see the “Our Use of Cookies and Other Tracking Mechanisms” section below for more information.
Geolocation If you have provided permission through your mobile device to allow us to collect location information through the App, we may obtain your physical location information in terms of latitude and longitude from technologies like GPS, Wi-Fi, or cell tower proximity. You are able to withdraw your permission for us to acquire such physical location information from your mobile device through your mobile device settings, although we do not control this process. If you have questions about how to disable your mobile device's location services, we recommend you contact your mobile device service provider or the mobile device manufacturer.
How We Use Your Information
We use your information, including personal information, for the following purposes:
How We Share Your Information
We may share your information, including personal information, as follows:
Please note that any third party with whom we share your personal information will provide the same or equal protection of personal information as provided in this Policy.
Our Use of Cookies and Other Tracking Mechanisms
We service providers use cookies and other tracking mechanisms, such as web beacons, to track information about your use of our Site and Services. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf).
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies), but such disabling will impair use of the Site and Services.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Services. There are two types of cookies: session and persistent cookies.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will not be able to browse certain areas of the Site or use the Services.
Third Party Analytics
We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and our Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties. To opt-out of Google Analytics and find out more about their privacy practices, see https://tools.google.com/dlpage/gaoptout
Third-Party Links
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
Security of My Personal Information
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
What Rights Do I Have Regarding My Personal Information
You may request access, a copy, modification or deletion of personal information that you have submitted to us by contacting us at dataprotection@zaggerapp.com We will use reasonable efforts to accommodate such requests to the extent required by law, provided that we may be required to retain personal information to comply with legal obligations, accounting requirements, or for other business purposes. We may request additional information to verify the identity of the requesting party before responding to a request. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.
What Choices Do I Have Regarding Use of My Personal Information for Marketing?
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us.
Location of Personal Information
Our Site and Services are offered from the United States. We store any personal information we collect in the United States. If you access the Services or Site from outside the United States, you agree to the transfer of your information to the United States, which may have less protections for your personal information than your jurisdiction of residence.
Children Under 13
Our Site and Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Contact Us
If you have questions about the privacy aspects of our Site or Services or would like to make a complaint, please contact us at dataprotection@zaggerapp.com
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on the Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site or if you have an account with us, providing notice to the email address in your account (for this reason you should make sure to update your account information promptly if it changes).
UNITED STATES REGIONAL PRIVACY NOTICE
This United States Regional Privacy Notice supplements the Policy and contains the disclosures required under the California Consumer Privacy Act, the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “U.S. Privacy Laws”). While we may not be subject to these U.S. Privacy Laws, we will endeavor to comply with them. The U.S. Privacy Laws require certain disclosures about the categories of personal information we collect and how we use it, the categories of sources from whom we collect personal information, and the third parties with whom we share it.
In order to submit a request, we will need to verify your identity. If you have an account with us that is password-protected, we may verify your identity through our existing authentication practices for your account. If you do not have an account with us, and your request concerns “categories” of personal information collected, we can request from you two data points of personal information to verify your identity. If you do not have an account with us, and your request concerns specific personal information, we can request from you at least three data points of personal information as well as a signed declaration with penalty of perjury to verify your identity.
To submit a request to exercise your rights, and as applicable, to appeal a consumer rights action, please send us an email to the following email address: dataprotection@zaggerapp.com .
Please note that following your verified request, we will send you your personal information from the following email address: dataprotection@zaggerapp.com . Any response to your request, including any personal information may be sent as an encrypted file.
Please note that once you have submitted a request, we will send you a receipt, acknowledging your request, within 10 days. If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please send us an email to dataprotection@zaggerapp.com , as an error may have occurred.
We will process and respond to your request within 45 days after it is received (in some cases, as is allowed under U.S. Privacy Laws, this process may be extended by an additional 45 days).
Please note, that regarding requests under subsections (a), (b), and (c) above, you may only make two requests in a 12-month period, and the information provided need only cover the 12-month period prior to your request.
Under certain U.S. Privacy Laws, you may also have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us at dataprotection@zaggerapp.com for more information if you wish to submit a request through an authorized agent.
If you have additional questions about this United States Regional Privacy Notice or how to exercise your rights under applicable U.S. Privacy Laws, please contact us at dataprotection@zaggerapp.com .
Notice of Financial Incentive
We may offer programs, benefits, and other offerings to consumers related to the collection, retention, or sale of personal information that may be deemed a “financial incentive” or “price or service difference” under the California Consumer Privacy Act (“CCPA”). For example, consumers may receive premium services if they allow us to collect, retain, or sell their personal information. You may opt-in to these premium services as directed by us. These offerings may involve collecting the following categories of personal information from customers who participate: identifiers; customer records; protected class and demographic information; commercial information and preferences; internet or other electronic network activity information and device information; audio, electronic, visual, or other sensory information; and inferences. We are providing you with this information so that you may make an informed decision on whether to participate in our programs.
Based on our reasonable and good faith estimate, we receive value from promotional programs, but we do not assign an independent monetary value to the personal information we collect in connection with our promotional programs. By participating in any of the above promotional programs, you agree that the benefits are reasonably related to the value of the personal information collected and retained.
Participation in our promotional programs is voluntary, and you may withdraw at any time.
Notice of Information We Plan to Collect
This serves as notice of the categories of personal information that we plan to collect through the Site and Services and the commercial purposes for which the information will be collected. Please note that all of the categories of personal information we plan to collect about you (as detailed below) come from the following categories of sources:
In particular, we plan to collect the following categories of personal information:
| Category | Collected | Business or Commercial Purpose |
| A. Identifiers. | YES | Please see the “How We Use Your Information” section above. |
|
B. Personal
information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
YES | Please see the “How We Use Your Information” section above. |
| C. Protected classification characteristics under California or federal law. | YES | Please see the “How We Use Your Information” section above. |
| D.Commercial information. | YES | Please see the “How We Use Your Information” section above. |
| E.Biometric information. | YES | N/A |
| F. Internet or other similar network activity. | YES | Please see the “How We Use Your Information” section above. |
| G. Geolocation data. | YES | Please see the “How We Use Your Information” section above. |
| H. Sensory data. | YES | Please see the “How We Use Your Information” section above. |
| I. Professional or employment-related information. | YES | Please see the “How We Use Your Information” section above. |
|
J. Non-public education information (per the Family
Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
YES | Please see the “How We Use Your Information” section above. |
| K. Inferences drawn from other Personal Information. | YES | Please see the “How We Use Your Information” section above. |
| L. Sensitive Personal Information | YES | Please see the “How We Use Your Information” section above. |
Notice of Sale or Sharing of Personal Information
Except as noted, we may sell or share certain data from all of the above categories of personal information listed above for purposes of targeted advertising. We will not sell or share or share: (i) personal information if we have actual knowledge that the consumer is less than 16 years of age; or (ii) Sensitive Personal Information.
We may sell or share personal information with the following categories of third parties:
Notice of Disclosures of Personal Information for a Business Purpose
We may also disclose certain data from the foregoing categories of personal information to the categories of recipients listed in “How We Share Your Information” Section of our Privacy Policy, such as our service providers, for one or more of the following business purposes:
Please note that when we disclose personal information for a business purpose to a third party, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Retention
We will generally store and use your personal information only for as long as is necessary for the uses we collected the information for as described in this Policy. Unless we are actively using your personal information or have a legal basis for retaining such information, in accordance with this Policy and applicable law, we will delete your personal information after 2 years of inactivity with respect to such information.
Other California Laws
California Shine the Light Law : In addition, under California Civil Code § 1798.83, California residents who have provided personal information to Zagger may obtain information regarding Zagger’s disclosures, if any, of personal information to third parties for third-party direct marketing purposes. Requests must be submitted to the following email address: dataprotection@zaggerapp.com . Within 30 days of receiving such a request, we will provide a California Privacy Disclosure, which will include a list of certain categories of personal information disclosed during the preceding calendar year to third parties for their direct marketing purposes, along with the names and addresses of the third parties. This request may be made no more than once per calendar year.
California Eraser Law : Any California residents under the age of eighteen (18) who have posted content or information on our Services can request removal by emailing use at dataprotection@zaggerapp.com detailing where the content or information is posted and attesting that you posted it. We will make reasonable, good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content that we do not control.