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Zapp and certain ZAPP group companies (“Zapp”, “we”) process personal data of their users of Zapp services (“Zapp App”) and the visitors of the website zapp.world (“Website”).
In this Privacy Statement, the word “Zapp Services” refers jointly to the Website and the Zapp App. In this Privacy Statement, the word “User” or “you” refers jointly to our and our group companies’ customers, representatives and other authorized users of our customer organizations, potential customers and the users of the Zapp Services.
Our Privacy Statement explains, for example, the types of personal data we process, how we process the personal data and how you may exercise your rights as a data subject (e.g. right to object, right of access).
Some of our services might be subject to a separate privacy policy. If a separate privacy policy applies to a particular service, we will post it in connection with the service in question.
This Privacy Statement may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on the Website. We will not make substantial changes to this Privacy Statement or reduce the rights of the Users under this Privacy Statement without providing a notice thereof.
1. DATA CONTROLLER(S)
This Privacy Statement applies to processing of personal data carried out by Zapp.
In relation to the processing of personal data of Users in the below countries, Zapworld Oy and the local ZAPP group company are acting as joint data controllers. This means that Zapworld Oy and the local ZAPP group company together determine the purposes for and means by which personal data is processed. The country-specific joint controllers are listed below:
Zapworld Oy has been appointed responsible for handling all data subject requests and questions relating to the personal data processing of the ZAPP group on behalf of the local joint controllers.
In relation to the processing of personal data of Users in other countries than the ones listed above, Zapworld Oy acts as the sole data controller.
2. ZAPP’S CONTACT DETAILS
Name: Zapworld Oy
Business ID: 3134797-1
Correspondence address: Tammasaarenkatu 3, 00180 Helsinki, Finland
E-mail address: support@zapp.world
Contact person: Zapp Management
3. PERSONAL DATA PROCESSED AND SOURCES OF DATA
The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.
User Data
User Data is personal data collected directly from you or from our customer organization on behalf of which you are using the ZAPP Services (“Customer Organization”), as the case may be. We may collect User Data from our Users and Customer Organizations in a variety of ways, including, after conclusion of a service agreement with the Customer Organization or when Users register to the ZAPP Services, subscribe to a newsletter or fill out a form. Further, please note that we also collect details of any transactions and payments you carry out through the ZAPP Services.
User Data that is necessary in order to use the ZAPP Services
The following personal data collected and processed by us is necessary in order for a proper performance of the contract between you and us as well as for our legitimate interest whilst fulfilling our contractual obligations towards our Customer Organizations and for the compliance with our legal obligations.
After conclusion of the service agreement between us and the Customer Organization, the Customer Organization provides us with your full name and email address.
When you register to the ZAPP Services and create a user account, you need to provide us with the following information:
full name
telephone number
email address
information relating to your payment instrument(s) such as the number of your payment instrument(s) and the expiration date of your payment instrument(s) (required for the purposes of ordering products via the ZAPP Services)
User Data you give us voluntarily
Your user or customer experience may be enhanced by providing us with the following information:
Additional Account Information:
a picture
delivery address
location data (if you consent to the processing of your location data)
other information you provide either when creating a user account or later when modifying your account profile
Other Information. We may also process other information provided by you voluntarily such as:
information you provide when rating our services
marketing opt-ins and opt-outs
information you provide by phone or in email or chat correspondence with us, including call recordings of your calls with our customer service
In addition to User Data collected from you and the Customer Organization, we process certain personal data third party service providers provide about you.
If you connect or login to your account with Facebook, Facebook shares with us personal information about you such as your profile picture, a sample of your Facebook friends and your Facebook ID.
Analytics Data
Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may automatically collect the following Analytics Data when you visit or interact with the ZAPP Services:
Device Information. We collect the following information relating to the technical device you use when using the ZAPP Services:
device and device identification number, device IMEI
country
IP address
browser type and version
operating system
Internet service providers
advertising identifier of your device
visitor identifier
Usage Information. We collect information on your use of the ZAPP Services, such as:
time spent on the ZAPP Services
interaction with the ZAPP Services
information on your orders made through the ZAPP Services
the URL of the website you visited before and after visiting the ZAPP Services
the time and date of your visits to the ZAPP Services
the sections of the ZAPP Services you visited
the products you searched for while using the ZAPP Services
Cookies
We use various technologies to collect and store Analytics Data and other information when the Users visit the ZAPP Services, including cookies and web beacons.
Cookies are small text files sent and saved on your device that allows us to identify visitors of the ZAPP Services and facilitate the use of the ZAPP Services and to create aggregate information of our visitors. This helps us to improve the ZAPP Services and better serve our Users. The cookies will not harm your device or files. We use cookies to tailor the ZAPP Services and the information we provide in accordance with the individual interests of our Users.
The Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:
Safari
Google Chrome
Internet Explorer
Mozilla Firefox
Microsoft Edge
Please note that some parts of the ZAPP Services may not function properly if use of cookies is refused.
A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.
Web analytics services
The ZAPP Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the ZAPP Services. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
Advertising and visitor identifiers
The ZAPP Services use pseudonymized identifiers to track and predict your app and service usage and preferences.
You can opt-out of the use of these identifiers by changing your operating system settings as follows:
Advertising identifiers can be disabled on iOS mobile devices by turning on the Limit Ad Tracking tab (Settings → Privacy → Advertising → Limit Ad Tracking). For an overview and more information on the advertising identifier, please see Apple Advertising and Privacy site.
ZAPP visitor identifiers can be disabled on iOS and Android mobile devices by changing your settings (for iOS: Settings → ZAPP → ZAPP settings → Limit Tracking, and for Android: ZAPP application → Profile tab → Settings icon in the top-right corner).
4. PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA
Purposes
There are several purposes of the processing of your personal data by ZAPP:
To provide the ZAPP Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
ZAPP processes your personal data to be able to offer the ZAPP Services to you under the contract between you and ZAPP or between Customer Organization and ZAPP.
We use the data for example to handle your payments or any refunds (where applicable) and to provide our partners (the merchants and our couriers) with the information necessary for the preparation or delivery of your order. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.
For our legal obligations (legal ground: compliance with a legal obligation)
ZAPP processes data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
For claims handling and legal processes (legal ground: legitimate interest)
ZAPP may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
For customer communication and marketing (legal ground: legitimate interest)
ZAPP processes your personal data to contact you regarding the ZAPP Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the ZAPP Services to you.
For quality improvement and trend analysis (legal ground: legitimate interest)
We may also process information about your use of the ZAPP Services to improve the quality of the ZAPP Services e.g. by analyzing any trends in the use of the ZAPP Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.
Legal grounds for processing
ZAPP processes your personal data to perform our contractual obligations towards you or the Customer Organization and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.
In some parts of the ZAPP Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.
5. TRANSFER TO COUNTRIES OUTSIDE FINLAND
ZAPP stores your personal data primarily within Finland . However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside Finland or the User’s domicile.
We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of Finland through a series of agreements with our service providers based on the Standard Contractual Clauses or https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en) through other appropriate safeguards, such as the Privacy Shield Framework. https://www.privacyshield.gov/welcome)
More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.
6. RECIPIENTS
We only share your personal data within the organization of ZAPP if and as far as reasonably necessary for the purposes of this Privacy Statement.
We do not share your personal data with third parties outside of ZAPP’s organization unless one of the following circumstances applies:
For the purposes set out in this Privacy Statement and to authorized service providers
To the extent that third parties (such as the merchants which prepare your order, our courier partners who deliver your order and Customer Organization which may pay your order) need access to personal data in order for us to perform the ZAPP Services, we provide such third parties with your data. Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, sales and marketing) to process it for us and to payment service providers to process your payments to us.
When data is processed by third parties on behalf of ZAPP, ZAPP has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.
Please bear in mind that if you provide personal data directly to a third party, such as through a link in the ZAPP Services, the processing is typically based on their policies and standards.
For legal reasons and legal processes
We may share your personal data with third parties outside ZAPP if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of ZAPP, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
For other legitimate reasons
If ZAPP is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the Users concerned when the personal data are transferred or become subject to a different privacy statement.
With your explicit consent
We may share your personal data with third parties outside ZAPP when we have your explicit consent to do so. You have the right to withdraw this consent at all times free of charge by contacting us support@zapp.world.
7. STORAGE PERIOD
ZAPP does not store your personal data longer than is legally permitted and necessary for the purposes of providing the ZAPP Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.
Most personal data relating to a User’s user account with the ZAPP Services will be deleted after a period of 90 days have lapsed after the User has deleted its user account with the ZAPP Services. Thereafter, a part of the personal data relating to a User’s user account with the ZAPP Services may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes. All personal data relating to a User’s user account with the ZAPP Services will be deleted within a period of 10 years after the User has deleted its user account with the ZAPP Services, with the exception of personal data required in certain rare situations such as legal proceedings.
We will store Analytics Data of Users that do not have an account with the ZAPP Services for a period of 90 days.
8. YOUR RIGHTS
Right of access
You have the right to access and be informed about your personal data processed by us. We give you the possibility to view certain data through your user account with the ZAPP Services or request a copy of your personal data.
Right to withdraw consent
In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time free of charge. Withdrawing a consent may lead to fewer possibilities to use the ZAPP Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. You can correct or update some of your personal data through your user account in the ZAPP Services.
Right to erasure
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the ZAPP Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the ZAPP Services.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the ZAPP Services.
Right to data portability
You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.
How to use your rights
The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject or charge requests that are unreasonably repetitive, excessive or manifestly unfounded.
9. DIRECT MARKETING
The User has the right to prohibit us from using the User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the functionalities of the ZAPP Services or the unsubscribe possibility offered in connection with any direct marketing messages.
10. LODGING A COMPLAINT
In case the User considers our processing of personal data to be inconsistent with the applicable data protection laws, the User may lodge a complaint with the local supervisory authority for data protection in Finland, the Data Protection Ombudsman (https://tietosuoja.fi/etusivu). Alternatively, the User may lodge a complaint with the local supervisory authority for data protection of the User’s country of domicile.
11. INFORMATION SECURITY
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the ZAPP Services, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.
Last updated 24.9.2020
In this Privacy Statement, the word “Zapp Services” refers jointly to the Website and the Zapp App. In this Privacy Statement, the word “User” or “you” refers jointly to our and our group companies’ customers, representatives and other authorized users of our customer organizations, potential customers and the users of the Zapp Services.
Our Privacy Statement explains, for example, the types of personal data we process, how we process the personal data and how you may exercise your rights as a data subject (e.g. right to object, right of access).
Some of our services might be subject to a separate privacy policy. If a separate privacy policy applies to a particular service, we will post it in connection with the service in question.
This Privacy Statement may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on the Website. We will not make substantial changes to this Privacy Statement or reduce the rights of the Users under this Privacy Statement without providing a notice thereof.
1. DATA CONTROLLER(S)
This Privacy Statement applies to processing of personal data carried out by Zapp.
In relation to the processing of personal data of Users in the below countries, Zapworld Oy and the local ZAPP group company are acting as joint data controllers. This means that Zapworld Oy and the local ZAPP group company together determine the purposes for and means by which personal data is processed. The country-specific joint controllers are listed below:
Zapworld Oy has been appointed responsible for handling all data subject requests and questions relating to the personal data processing of the ZAPP group on behalf of the local joint controllers.
In relation to the processing of personal data of Users in other countries than the ones listed above, Zapworld Oy acts as the sole data controller.
2. ZAPP’S CONTACT DETAILS
Name: Zapworld Oy
Business ID: 3134797-1
Correspondence address: Tammasaarenkatu 3, 00180 Helsinki, Finland
E-mail address: support@zapp.world
Contact person: Zapp Management
3. PERSONAL DATA PROCESSED AND SOURCES OF DATA
The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.
User Data
User Data is personal data collected directly from you or from our customer organization on behalf of which you are using the ZAPP Services (“Customer Organization”), as the case may be. We may collect User Data from our Users and Customer Organizations in a variety of ways, including, after conclusion of a service agreement with the Customer Organization or when Users register to the ZAPP Services, subscribe to a newsletter or fill out a form. Further, please note that we also collect details of any transactions and payments you carry out through the ZAPP Services.
User Data that is necessary in order to use the ZAPP Services
The following personal data collected and processed by us is necessary in order for a proper performance of the contract between you and us as well as for our legitimate interest whilst fulfilling our contractual obligations towards our Customer Organizations and for the compliance with our legal obligations.
After conclusion of the service agreement between us and the Customer Organization, the Customer Organization provides us with your full name and email address.
When you register to the ZAPP Services and create a user account, you need to provide us with the following information:
full name
telephone number
email address
information relating to your payment instrument(s) such as the number of your payment instrument(s) and the expiration date of your payment instrument(s) (required for the purposes of ordering products via the ZAPP Services)
User Data you give us voluntarily
Your user or customer experience may be enhanced by providing us with the following information:
Additional Account Information:
a picture
delivery address
location data (if you consent to the processing of your location data)
other information you provide either when creating a user account or later when modifying your account profile
Other Information. We may also process other information provided by you voluntarily such as:
information you provide when rating our services
marketing opt-ins and opt-outs
information you provide by phone or in email or chat correspondence with us, including call recordings of your calls with our customer service
In addition to User Data collected from you and the Customer Organization, we process certain personal data third party service providers provide about you.
If you connect or login to your account with Facebook, Facebook shares with us personal information about you such as your profile picture, a sample of your Facebook friends and your Facebook ID.
Analytics Data
Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may automatically collect the following Analytics Data when you visit or interact with the ZAPP Services:
Device Information. We collect the following information relating to the technical device you use when using the ZAPP Services:
device and device identification number, device IMEI
country
IP address
browser type and version
operating system
Internet service providers
advertising identifier of your device
visitor identifier
Usage Information. We collect information on your use of the ZAPP Services, such as:
time spent on the ZAPP Services
interaction with the ZAPP Services
information on your orders made through the ZAPP Services
the URL of the website you visited before and after visiting the ZAPP Services
the time and date of your visits to the ZAPP Services
the sections of the ZAPP Services you visited
the products you searched for while using the ZAPP Services
Cookies
We use various technologies to collect and store Analytics Data and other information when the Users visit the ZAPP Services, including cookies and web beacons.
Cookies are small text files sent and saved on your device that allows us to identify visitors of the ZAPP Services and facilitate the use of the ZAPP Services and to create aggregate information of our visitors. This helps us to improve the ZAPP Services and better serve our Users. The cookies will not harm your device or files. We use cookies to tailor the ZAPP Services and the information we provide in accordance with the individual interests of our Users.
The Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:
Safari
Google Chrome
Internet Explorer
Mozilla Firefox
Microsoft Edge
Please note that some parts of the ZAPP Services may not function properly if use of cookies is refused.
A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.
Web analytics services
The ZAPP Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the ZAPP Services. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
Advertising and visitor identifiers
The ZAPP Services use pseudonymized identifiers to track and predict your app and service usage and preferences.
You can opt-out of the use of these identifiers by changing your operating system settings as follows:
Advertising identifiers can be disabled on iOS mobile devices by turning on the Limit Ad Tracking tab (Settings → Privacy → Advertising → Limit Ad Tracking). For an overview and more information on the advertising identifier, please see Apple Advertising and Privacy site.
ZAPP visitor identifiers can be disabled on iOS and Android mobile devices by changing your settings (for iOS: Settings → ZAPP → ZAPP settings → Limit Tracking, and for Android: ZAPP application → Profile tab → Settings icon in the top-right corner).
4. PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA
Purposes
There are several purposes of the processing of your personal data by ZAPP:
To provide the ZAPP Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
ZAPP processes your personal data to be able to offer the ZAPP Services to you under the contract between you and ZAPP or between Customer Organization and ZAPP.
We use the data for example to handle your payments or any refunds (where applicable) and to provide our partners (the merchants and our couriers) with the information necessary for the preparation or delivery of your order. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.
For our legal obligations (legal ground: compliance with a legal obligation)
ZAPP processes data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
For claims handling and legal processes (legal ground: legitimate interest)
ZAPP may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
For customer communication and marketing (legal ground: legitimate interest)
ZAPP processes your personal data to contact you regarding the ZAPP Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the ZAPP Services to you.
For quality improvement and trend analysis (legal ground: legitimate interest)
We may also process information about your use of the ZAPP Services to improve the quality of the ZAPP Services e.g. by analyzing any trends in the use of the ZAPP Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.
Legal grounds for processing
ZAPP processes your personal data to perform our contractual obligations towards you or the Customer Organization and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.
In some parts of the ZAPP Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.
5. TRANSFER TO COUNTRIES OUTSIDE FINLAND
ZAPP stores your personal data primarily within Finland . However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside Finland or the User’s domicile.
We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of Finland through a series of agreements with our service providers based on the Standard Contractual Clauses or https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en) through other appropriate safeguards, such as the Privacy Shield Framework. https://www.privacyshield.gov/welcome)
More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.
6. RECIPIENTS
We only share your personal data within the organization of ZAPP if and as far as reasonably necessary for the purposes of this Privacy Statement.
We do not share your personal data with third parties outside of ZAPP’s organization unless one of the following circumstances applies:
For the purposes set out in this Privacy Statement and to authorized service providers
To the extent that third parties (such as the merchants which prepare your order, our courier partners who deliver your order and Customer Organization which may pay your order) need access to personal data in order for us to perform the ZAPP Services, we provide such third parties with your data. Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, sales and marketing) to process it for us and to payment service providers to process your payments to us.
When data is processed by third parties on behalf of ZAPP, ZAPP has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.
Please bear in mind that if you provide personal data directly to a third party, such as through a link in the ZAPP Services, the processing is typically based on their policies and standards.
For legal reasons and legal processes
We may share your personal data with third parties outside ZAPP if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of ZAPP, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
For other legitimate reasons
If ZAPP is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the Users concerned when the personal data are transferred or become subject to a different privacy statement.
With your explicit consent
We may share your personal data with third parties outside ZAPP when we have your explicit consent to do so. You have the right to withdraw this consent at all times free of charge by contacting us support@zapp.world.
7. STORAGE PERIOD
ZAPP does not store your personal data longer than is legally permitted and necessary for the purposes of providing the ZAPP Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.
Most personal data relating to a User’s user account with the ZAPP Services will be deleted after a period of 90 days have lapsed after the User has deleted its user account with the ZAPP Services. Thereafter, a part of the personal data relating to a User’s user account with the ZAPP Services may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes. All personal data relating to a User’s user account with the ZAPP Services will be deleted within a period of 10 years after the User has deleted its user account with the ZAPP Services, with the exception of personal data required in certain rare situations such as legal proceedings.
We will store Analytics Data of Users that do not have an account with the ZAPP Services for a period of 90 days.
8. YOUR RIGHTS
Right of access
You have the right to access and be informed about your personal data processed by us. We give you the possibility to view certain data through your user account with the ZAPP Services or request a copy of your personal data.
Right to withdraw consent
In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time free of charge. Withdrawing a consent may lead to fewer possibilities to use the ZAPP Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. You can correct or update some of your personal data through your user account in the ZAPP Services.
Right to erasure
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the ZAPP Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the ZAPP Services.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the ZAPP Services.
Right to data portability
You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.
How to use your rights
The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject or charge requests that are unreasonably repetitive, excessive or manifestly unfounded.
9. DIRECT MARKETING
The User has the right to prohibit us from using the User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the functionalities of the ZAPP Services or the unsubscribe possibility offered in connection with any direct marketing messages.
10. LODGING A COMPLAINT
In case the User considers our processing of personal data to be inconsistent with the applicable data protection laws, the User may lodge a complaint with the local supervisory authority for data protection in Finland, the Data Protection Ombudsman (https://tietosuoja.fi/etusivu). Alternatively, the User may lodge a complaint with the local supervisory authority for data protection of the User’s country of domicile.
11. INFORMATION SECURITY
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the ZAPP Services, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.
Last updated 24.9.2020
In order for your visit to ZAPP to be attractive and to allow some features to be used, we use so-called cookies on various pages. Cookies are small text files that are stored in your browser. Some of the cookies we use are deleted after the end of your browser session, i.e. after you close the browser. Other cookies remain in your browser and allow us to recognize your browser on your next visit (permanent cookies). You can configure your browser to know how to set cookies and decide individually whether or not to accept them for specific occasions or in general. Not accepting cookies may limit the functionality of our site.
We classify the cookies we use into three categories:
● Required cookies
● Functional cookies
● Personalization cookies
Below you will find more information about your choices as well as a detailed list of cookies we use. The required cookies are necessary to navigate our site and use its features. Without the use of these cookies, the proper functioning of our site is not guaranteed (e.g. text input) when browsing the pages of the website. In addition, they are cookies that collect information about how visitors use our site, for example, which pages they visit more often and if they receive error messages. They also allow our site to remember your choices, such as language or area, to provide improved features. They are also used to store information about the consent option where required. No action is required from you to activate them.
Functional cookies allow us to continuously improve the services we offer, collecting and analyzing information about our website traffic. They can also be used to send ads and bids or to measure the effectiveness of our ad campaigns. So they give us the opportunity to suggest and help you find what you are looking for. This category also include cookies from third parties. Personalization cookies are used to create tailor-made content for you to give you the best possible ZAPP experience. Objection to the use of cookies
If you do not want us to collect and analyze information about your visit, you can opt-out at any time for the future. For the technical implementation, an exception cookie will be set in your browser. This cookie is solely intended to map your objection. Please note that for technical reasons the opt-out cookie can only be used for the specific browser from which it is set. If you delete cookies or use a different browser or device, you will need to repeat this process.
We classify the cookies we use into three categories:
● Required cookies
● Functional cookies
● Personalization cookies
Below you will find more information about your choices as well as a detailed list of cookies we use. The required cookies are necessary to navigate our site and use its features. Without the use of these cookies, the proper functioning of our site is not guaranteed (e.g. text input) when browsing the pages of the website. In addition, they are cookies that collect information about how visitors use our site, for example, which pages they visit more often and if they receive error messages. They also allow our site to remember your choices, such as language or area, to provide improved features. They are also used to store information about the consent option where required. No action is required from you to activate them.
Functional cookies allow us to continuously improve the services we offer, collecting and analyzing information about our website traffic. They can also be used to send ads and bids or to measure the effectiveness of our ad campaigns. So they give us the opportunity to suggest and help you find what you are looking for. This category also include cookies from third parties. Personalization cookies are used to create tailor-made content for you to give you the best possible ZAPP experience. Objection to the use of cookies
If you do not want us to collect and analyze information about your visit, you can opt-out at any time for the future. For the technical implementation, an exception cookie will be set in your browser. This cookie is solely intended to map your objection. Please note that for technical reasons the opt-out cookie can only be used for the specific browser from which it is set. If you delete cookies or use a different browser or device, you will need to repeat this process.