GDPR Privacy Policy
Zapme LLC - FZ
1. Overview
Thank you for using our platform!
Zapme LLC – FZ (Zapme, we, us, our) is committed to protecting your privacy. We have prepared this GDPR Privacy Policy to describe to you our practices regarding Personal Data (as defined below) we collect from users of our services, including our website at www.zapme.co and our platform which allows users to streamline their messaging services into one platform, and make local and international calls and video calls using global data (Services).
Our Privacy Policy, available on our website www.zapme.co, sets out how we comply with these obligations.
Sometimes, we also handle the information of European Union (EU) and United Kingdom (UK) residents or share data with other organisations which do so or provide services to individuals located in the EU and UK. To the extent that we do so, for individuals:
- based in the EU or who are citizens of the EU, this GDPR Privacy Notice for the EU General Data Protection Regulation applies (EU GDPR); or
- based in the UK or who are citizens of the UK, this GDPR Privacy Notice for the UK General Data Protection Regulation applies (UK GDPR).
The processing of Personal Data will always be in line with the EU GDPR and UK GDPR, and in accordance with country-specific data protection regulations and other applicable regulations to Zapme.
We have implemented a number of technical and organisational measures to ensure the most complete protection of Personal Data processed through the Services.
2. Your rights
The EU GDPR and UK GDPR provide you with eight key rights, being the right to:
- Be informed: anyone processing your Personal Data must make clear what they are processing, why and who else the data may be passed to.
- Access: the right to access what Personal Data is held about you.
- Rectification: the right to have your Personal Data corrected or amended if what is held is incorrect.
- Erasure: the right to ask for your Personal Data to be deleted, also known as the right to be forgotten, if permitted under applicable laws.
- Restrict processing: the right to require a temporary halt to the processing of Personal Data.
- Data portability: the right to request for any Personal Data supplied by you to us to be provided in a structured, commonly used and machine-readable format.
- Object: the right to object to further processing of your Personal Data which is inconsistent with the primary purpose for which it was collected.
- Consider automated decision making and profiling: the right not to be subject to a decision based solely on automated processing.
This Privacy Policy sets out, among other things, how you can exercise these rights when dealing with Zapme.
3. Consent
Where we rely on your consent as the lawful basis to process your data under the GDPR regime applicable to you we will always ask for you to positively affirm your acceptance. By clicking to accept this Privacy Policy, you acknowledge and agree to be bound by this Privacy Policy.
We note that all contact or other data forms where consent is required to be given by you include no pre-checked checkboxes so that you are able to freely and affirmatively opt-in. We will also provide you with notice on the Services specifically detailing what it is that you are consenting to in clear and plain language as well ensuring that each matter that requires consent is clearly distinguishable.
For all areas of the Services where consent is given it is just as easily able to be withdrawn through the appropriate account settings on the Services or by contacting us at the details provided below.
If you believe that consent has not been given freely or in breach of the terms of this Privacy Policy, please contact us.
4. Personal data we collect
We will only collect Personal Data from you if it is reasonably necessary for one or more of our functions or activities.
Personal Data means any information that allows someone to identify you, for example, your name, telephone number, e-mail address, date of birth, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
4.1 Information you provide to us
(a) Account
You need to create an account with us to use our Services (Account).
During your Account registration and use of the Services, you may enter your details on different forms or provide us with additional content.
We may collect Personal Data from you, such as:
- your name, date of birth, address, email address and phone number; and
- your profile photo and “about” information.
This data is used to enable us to identify and verify you and provide you with support, services, mailings, sales and marketing actions. Certain functionalities of the Services require your Personal Data to function properly.
The legal basis for this processing is based on:
- your consent through your voluntary creation of your Account, or through your consent to integrating other messaging platforms into our Services, and agreeing to this Privacy Policy;
- the Personal Data being necessary for the performance of a contract to which you are a party;
for carrying out pre-contractual measures; and/or
our legitimate interests or any applicable regulatory obligations in providing our Services to our users.
(b) Contact and Messaging Data
When you use the Services to send messages, images and other content you share in the Services (User Content), we will collect, but not store, this User Content in order to provide our Services to you. Your User Content will remain on your device, unless you save it separately.
If you contact us through electronic communications, we will collect your name and e-mail address, as well as any other content included in the e-mail or conversation, in order to send you a reply. We will store and process your communications and information as needed. We may also collect contact information if you choose to upload, sync or import it from a device.
The legal basis for this processing is based on:
- your consent through your voluntary submission of the User Content through our Services or through your submission of a message or communication to us;
- the Personal Data being necessary for the performance of a contract to which you are a party;
- for carrying out pre-contractual measures; and/or
- our legitimate interests or any applicable regulatory obligations in providing our Services to our users.
By sending User Content through our Services, such Personal Data is transmitted on a voluntary basis and you consent to its collection.
(c) Subscription Data
When you use the Services, you may have the ability to subscribe to our marketing, offerings and promotions and other updates about our Services. We may collect the data when you input your details for subscription purposes.
The Personal Data is processed for the purpose of informing you regularly by means of a newsletter or other electronic communication. The Personal Data collected during the subscription will only be used for the purposes of marketing to you.
The legal basis for this processing is based on:
- your consent through your voluntary submission of our contact form and agreeing to these terms; and/or
- our legitimate interests in providing our Services to our users.
By submitting the form and voluntarily providing us with your data, you are providing consent to the use of such data by us for the purpose of providing subscription based materials. For the purpose of revocation of consent there is a corresponding unsubscribe link found in each subscription email. You can also contact us at support@zapme.co to revoke your consent. Please review the consent section above in this Privacy Policy for how we deal with consent. Where we use your data for direct marketing, we will ensure that it is in compliance with relevant laws. Where you are a customer of ours, we may be required to send you emails for legitimate reasons including but not limited to billing, reminders and Account verification.
We retain information on your behalf, such as domain names, URLs, time zone preferences, transactional history for your subscription payments and any other information that you store using your Account.
We may also collect Personal Data at other points on our Services. These points state that Personal Data is being collected.
In some circumstances, Personal Data may be provided to us by third parties such as our related entities, service providers, or other messaging platforms that you choose to integrate into our Services, such as those operated by the Meta Companies. With your express consent, your Personal Data may be used and disclosed to us this way. The purposes as outlined above may include the processing of such Personal Data to the extent necessary for us to comply with a law, regulation or legal request or to protect the safety of any person or to prevent fraud.
4.2 Information we collect as you use our services
(a) Metadata including Location Data
Our Services may allow you to add or may have metadata added to your content including hashtags (to mark keywords), geotags (to mark your location), comments or other data. This helps our Services and your content to be more searchable.
We use location data to help target and tailor the Services to your particular location and jurisdiction. With your consent, we will also collect information about your precise location using methods including GPS, wireless networks, cell towers, Wi-Fi access points and other sensors.
(b) Log Data
To make our Services more useful to you, our servers (which are hosted by a third-party service provider, Amazon Web Services) gather information automatically and store it in log files. This information includes, but is not limited to, Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), your call logs (sender and receiver) referring and exit websites and applications, operating system, mobile phone operating system, date/time stamp, clickstream data, which telecommunications tower you are near, MAC address, and sender and receiver information.
We use this information to understand and analyse trends, to administer the Services, to learn about user behaviour regarding the Services, to improve our services, to comply with any applicable laws and to gather demographic information about our user base as a whole. Zapme may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on our Services. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
(c) Analytics
4.3 Information we collect from others
(a) Data and content other people upload
We may also collect information and communications that other people provide when they use our Services. This can include information about you such as when others send User Content to you, or submit user reports about you, such as where another user has reported your use of your Services to us. We may also collect your information if you are invited to participate in our Services. This may include information such as your name, date of birth, phone number and email address relevant to the Services and is used for the purpose of enabling us to provide our Services to you.
We will only collect information about you directly from you, except where it is unreasonable or impracticable to do so.
(b) Contacts
We may also collect contact (but not store) details that other people provide when they use our Services, such as if they consent to uploading to the Services the phone numbers in their address book if the applicable laws permit. This can include information about you such as your name and telephone number, and is used for the purposes of providing our Services to you and our users.
We will only collect information about you directly from you, except where it is unreasonable or impracticable to do so.
5. How we use your Personal Data
5.1 Use of Personal Data
- enable you to access and use our Services;
- maintain internal records and administrative purposes;
- comply with our legal obligations and resolve any disputes that we may have;
- maintain your Account and contact details;
- remember information so you don’t have to re-enter it during your visit to our website or our app;
- provide personalised content and information to you and others;
- send marketing communications to you;
- conduct our business, generate content and provide customer support and payment options (including updates and improvements);
- administer contracts including to negotiate, execute and/or manage a contract with you;
- communicate with you;
- provide you with access to protected areas of the Services;
- conduct surveys to determine use and satisfaction;
- detect, investigate and prevent potentially unlawful acts or omissions or acts or omissions with the potential to breach our Terms and Conditions, this Privacy Policy or any other policy;
- enforce our Terms and Conditions, this Privacy Policy or any other policy;
- verify information for accuracy or completeness;
- comply with our legal obligations;
- monitor metrics;
- combine or aggregate your Personal Data with information we collect from third parties and use it for the purposes set out in this Privacy Policy;
- protect a person’s rights, property or safety;
- process transactions to which you are a party;
- resolve disputes and to identify, test and resolve problems;
- improve our Services; and
- any other purpose made known in this Privacy Policy or other policy.
We agree to not use or disclose this information for a secondary purpose unless you consent to us doing so, or another exception applies under applicable laws.
We do not ask for special category data from you. However, if you put special category data in User Content or enter any special category data in our Services, then we will only disclose or use that information in accordance with the relevant GDPR regime with your consent or if another exception applies under applicable laws.
We will also use or disclose your Personal Data or special category data if we are required to do so by law or a court / tribunal order, or if we reasonably believe that the use or disclosure of the information is reasonably necessary for an enforcement related activity or on behalf of an enforcement body, in which case we will make a written note of the use or disclosure or another exception applies under relevant laws.
5.2 Creation of anonymous data
We also collect data in a form that does not, on its own, permit direct association with any specific individual (Anonymous Data). We may collect, use, transfer, and disclose non-Personal Data for any purpose.
We may collect information regarding customer activities on our Services including the website. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and Services are of most interest. Aggregated data is considered non-Personal Data for the purposes of this Privacy Policy.
6. Disclosure of your Personal Data
We may disclose your Personal Data to third parties for the purposes contained in this Privacy Policy, including without limitation to:
(a) Service Providers
We may share your Personal Data with service providers to:
- provide you with the Services that we offer you;
- to conduct quality assurance testing;
- to facilitate creation of Accounts;
- to provide technical support;
- and/or to provide other services to Zapme.
The service providers (and if necessary, data processors) include:
- information technology service providers such as web host providers and analytical providers;
- advertising partners;
- market research organisations to enable them to measure the effectiveness of our advertising; and
- specialist consultants.
These third party service providers are prohibited from using your Personal Data other than to provide the services requested by Zapme. If you would like details of our service providers, being: Amazon Web Services, ID Analyzer and Upgoo (Sub-processor List).
As part of the sign up process for our Services, you may be required to verify your identity. Your identity will be verified by our third party service provider. We will not collect any identification documentation from you.
(b) Affiliates and Acquisitions
We may share some or all of your Personal Data with any of our parent companies’ subsidiaries, joint ventures, or other companies under a common control (Affiliates), in which case we will require our Affiliates to honour this Privacy Policy. In the event we are involved in a merger, acquisition or sale of assets we may disclose Personal Data collected by us to such entities that we propose to merge with or be acquired by and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
(c) Third parties including those you choose to share your data with
We may disclose your Personal Data to third parties to whom you expressly ask to us to send the Personal Data to or to third parties you choose to send your Personal Data to. This includes other messaging platforms that you choose to integrate into our Services.
We may also, with your consent or at your direction, disclose your Personal Data to your authorised representatives.
(d) Other disclosures
Regardless of any choices you make regarding your Personal Data (as described below), Zapme may disclose Personal Data if it believes in good faith that such disclosure is necessary:
- in connection with any legal investigation;
- to comply with relevant laws, regulations, enforceable governmental requests or to respond to subpoenas or warrants served on Zapme;
- to protect or defend the rights or property of Zapme or users of the Services;
- to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms and Conditions;
- to protect the safety of any person or to protect the safety or integrity of our platform including for security reasons; or
- detect, prevent or otherwise address fraud, security or technical issues.
We may share your Personal Data with such third parties subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your Personal Data only on our behalf and pursuant to our instructions.
We will take reasonable steps to ensure that anyone to whom we disclose your Personal Data respects the confidentiality of the information and abides by the GDPR or equivalent privacy laws.
We will not share, sell, rent or disclose your Personal Data in ways different from what is disclosed in this Privacy Policy.
7. If we can’t collect your data
If you do not provide us with the Personal Data described above, some or all of the following may happen:
- we may not be able to provide our Services to you, either to the same standard or at all;
- we may not be able to run any competitions and promotions in a way that benefits you;
- we may not be able to provide you with information about products and services that you may want; and/or
- we may be unable to tailor the content of our Services to your preferences and your experience of our Services may not be as enjoyable or useful.
8. Cookies Policy
8.1 What are cookies?
A cookie is a small piece of text sent to your browser by a website that you visit. It helps the website to remember information about your visit, like your preferred language and other settings. That can make your next visit easier and the site more useful to you. Cookies play an important role. Without them, using the web would be a much more frustrating experience.
8.2 Use of cookies
Zapme’s Services, including websites, online services, interactive applications, email messages, and advertisements, may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behaviour, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.
We treat information collected by cookies and other technologies as non-Personal Data. However, to the extent that Internet Protocol addresses or similar identifiers are considered Personal Data by local law, we also treat these identifiers as Personal Data. Similarly, to the extent that non-Personal Data is combined with Personal Data, we treat the combined information as Personal Data for the purposes of this Privacy Policy.
Zapme and our partners also use cookies and other technologies to remember Personal Data when you use our Services. Our goal in these cases is to make your experience with Zapme more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit the Zapme platform. Knowing someone using your computer or device has shopped for a certain product or used a particular service helps us make our advertising and email communications more relevant to your interests. And knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize your operating system and provide you with better customer service.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
8.3 How to manage cookies
Some people prefer not to allow cookies, which is why most browsers give you the ability to manage cookies to suit you. If you want to disable you may do so using the function in your web browser. Please note that certain features of the Zapme Services may not be available once cookies are disabled.
9. Third party websites
When you click on a link to any other website or location, you will leave our website and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.
10. Managing your Personal Data
Subject to the EU GDPR or UK GDPR you may request to access the Personal Data we hold about you by contacting us or through the function in your Account. All requests for access will be processed within a reasonable time.
(a) Accessing or rectifying your Personal Data
We provide you with tools and Account settings to access, correct, delete, or modify the Personal Data you provided to us. You can find out more about how to do this by contacting us. In the event that you are unable to access your Account to access or rectify your Personal Data, you may submit a request to us to correct, delete or modify your Personal Data and download the data for you.
(b) Deletion
We keep data for as long as it is needed for our operations. If you deactivate and delete your Account, your data will no longer be visible on your Account, including any undelivered messages and any information that we do not need to operate our Services. We will retain some information about your Account as required under the applicable laws.
Deleting your Account will not result in any User Content that you have shared with others to be deleted.
If you wish to have us delete your data, please contact us.
(c) Object, restrict or withdraw consent
If you have an Account on the Services, you will be able to view and manage your privacy settings. Alternatively, if you do not have an Account, you may submit a request to us if you object to any Personal Data being stored, or if you wish to restrict or withdraw any consent given for the collection of your Personal Data.
You may withdraw your consent to the processing of all your Personal Data at any time. If you wish to exercise this right, you may do so by contacting us.
You may withdraw your consent or manage your opt-ins by either viewing your Account on the Services or clicking the unsubscribe link at the bottom of any marketing materials we send you.
(d) Portability
We may, if required and possible, provide you with the means to download the information you have shared through our Services. Please contact us for further information on how this can be arranged.
In certain instances, we may not be required or able to provide you with access to your Personal Data. If this occurs, we will give you reasons for our decision not to provide you with such access to your Personal Data in accordance with the requirements of the EU GDPR or UK GDPR.
There is no application fee for making a request to access your Personal Data. However, we may charge an administrative fee for the provision of information in certain circumstances, such as if you make repeated requests for information or where the information is held by a third-party provider.
11. Storage and Security of Your Personal Data
Zapme stores Personal Data through a number of different layers including:
- encrypted browsing through HTTPS;
- storing authentication details, such as passwords and user access tokens, in hashed or non reversible formats;
- using multi-factor authentication for account verification;
- actively monitoring errors; and
- logs using industry level tooling.
Our servers are hosted with Amazon Web Services and are rebuilt with each deployment to prevent persistent access to rogue services, Server access and deployment are limited to revokable access keys that can only be regenerated on a master account. Access to servers can only be gained by using industry standard encryption keys that are generated and regularly updated, including when employees leave Zapme.
User logs redact certain types of information, such as passwords, before they are logged to prevent user information leaking to third parties.
Servers and databases are limited to internal access only to prevent database access to the public, unless it relates to certain whitelisted services or for monitoring and troubleshooting.
Zapme takes the security of your Personal Data very seriously. We will take all steps reasonable under the circumstances to protect your Personal Data from misuse, interference, loss, and unauthorised access, modification or disclosure. We will process Personal Data securely and apply and maintain appropriate technical and organisational measures to protect Personal Data.
The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that Personal Data that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
12. International Transfer and Disclosure of Personal Data
Where we transfer Personal Data from within to outside of the EU, EFTA States, or UK, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws.
We may disclose Personal Data to our related bodies corporate and third-party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your Personal Data do not breach the privacy obligations relating to your Personal Data.
We may disclose your Personal Data to entities located outside of United Arab Emirates, including the following:
- our related bodies corporate;
- our data hosting and other IT service providers, located in various countries as set out in our Sub-processor List; and
- other third parties located in various foreign countries.
We may disclose your Personal Data to entities within United Arab Emirates who may store or process your data overseas.
13. Notifiable Data Breaches
We take data breaches very seriously. We will endeavour to meet the 72-hour deadline as imposed by the EU GDPR and UK GDPR, to report any data breach to the relevant supervisory authority or to the Information Commissioner’s Office where a data breach occurs that will likely be a risk to you. Further, where there is likely to be a high risk to your rights, we will endeavour to contact you without undue delay. We will review every incident and take action to prevent future breaches.
14. Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision is not necessary for entering into, or the performance of, a contract between us, or is not authorised by EU Member State law or UK law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or is not based on your explicit consent. If you wish to exercise your rights, please contact us.
15. Integrity and Retention of Data
We take all reasonable steps to ensure that the Personal Data we collect about you is accurate, up to date and complete. Where we collect that information from you directly, we rely on you to supply accurate information. Zapme makes it easy for you to keep your Personal Data accurate, complete, and up to date. Where we use or disclose your Personal Data, we will also ensure that your Personal Data is relevant.
We will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
We may retain your information for fraud prevention or similar purposes.
16. Contact Information
Zapme welcomes your comments or questions regarding this Privacy Policy.
If you have a question regarding this Privacy Policy or you would like to make a complaint, please contact us by email by using the details below.
If you reside in the EU, EFTA States or the UK, the data controller that is responsible for your Personal Data is:
Zapme LLC – FZ
Email: support@zapme.co
Address: Zapme LLC – FZ, Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E
For individuals based in the EU, we have appointed Prighter as our Article 27 representative under the EU GDPR. If you want to exercise your rights under the EU GDPR, please visit Prighter.
To contact our EU Article 27 representative, please use the details below:
Prighter
c/o Zapme LLC – FZ
Email: info@prighter.com
Address: 20 Mortlake Mortlake High Street, London, SW14 8JN, UNITED KINGDOM
Please add the following subject to all correspondence: Zapme UK/EU Privacy
For individuals based in the UK, we have appointed Prighter as our Article 27 representative under the UK GDPR. If you want to exercise your rights under the UK GDPR, please visit Prighter.
To contact our UK Article 27 representative, please use the details below:
Prighter
c/o Zapme LLC – FZ
Email: info@prighter.com
Address: 20 Mortlake Mortlake High Street, London, SW14 8JN, UNITED KINGDOM
Please add the following subject to all correspondence: Zapme UK/EU Privacy
If you wish to raise a concern about our use of your information you have the right to do so with your local supervisory authority for individuals based in the EU or with the Information Commissioner’s Office for individuals based in the UK.
17. Changes to this Privacy Policy
This Privacy Policy is subject to occasional revision and Zapme reserves the right, at its sole discretion, to modify or replace any part of this Agreement. It is your responsibility to check this Agreement periodically for changes. Continued use of our Services including the website shall indicate your acknowledgement that it is your responsibility to review the Privacy Policy periodically and become aware of any modifications. We may amend this policy from time to time. Not all changes to our Privacy Policy will require your consent, for example where office security procedures are changed. We will notify you of any change to our information handling policy that requires your consent before being implemented.
