Privacy Policy

Last updated: Nov 7, 2023

At Zapp Inc., we take your privacy seriously. This privacy notice explains how we collect, use, and share your Personal Data when you use our products and services. By using our products and services, you agree to the collection, use, and sharing of your Personal Data as described in this privacy notice. We may make changes to this privacy notice from time to time. Please check this privacy notice periodically for updates.

Data Controller

Zapp Inc., a company domiciled in the State of Texas, United States, is the data controller responsible for your personal data.

Personal Information

“Personal Information” or “Personal Data,” as it may be referred to in certain privacy laws, means any information that’s about you. This information can be your name, your email address, your contact information, and anything else that tells someone something about you.

Information We Collect

Through our interactions, we may collect different kinds of Personal Information about you which we have grouped together as follows:

Information You Provide Us:

● Personal Identification Data includes your first name and last name, email address, phone number, billing address, phone number, home country, Internet Protocol (IP) address, age, gender, and interests, or similar identifiers.

● Transaction Data includes your payment and transaction information, such as your banking information, your credit/debit card number, your first and last name, and your billing address.

● Communication Data includes your discussions with our customer support, other communications you send us, and your feedback that you send to us via email or social media.

● Marketing Data includes your first and last name, your mailing address, and your email address.


Information Automatically Collected by Technology:

In addition to the information you provide us, we may automatically collect certain information about your equipment, software, and browser to provide you with an efficient and personalized experience.

This information includes:

● Device Data such as your device’s hardware information, operating system, platform information, browser type, language information, and browser plugin types.

● Web Usage Data which includes information about how you use our website and our products and services.


Information Collected from Third Parties:

We may collect personal or anonymized information about you from third party companies that provide products and services that are used in together with our website or our services. For example, we may collect information from social networking sites, such as Facebook, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect with our accounts on such social networks.


Aggregated Data:

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Information, but Aggregated Data is not considered Personal Information, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of

users accessing our website and services. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

How We Collect Your Information

We collect Personal Data about you from various sources. For example, we collect and obtain information:

● Directly from you.

● Using cookies and other automatic data collection technologies.

● From third parties or publicly available sources.

The Purpose for Collecting and Processing Your Information

Your Personal Information is processed to provide you with our products and services, to communicate with you, and to improve our products and services. Specifically, we may ask you to provide your Personal Information to:

● Provide our services to you and fulfill your requests.

● Process transactions, including payments and refunds.

● Personalize your experience on our website or application.

● Subscribe you to our services.

● Send you newsletters or special offers you sign up for.

● Inform you of new features, functionality, services, products, and other promotions, if you

agree to such notifications.

● Communicate with you for marketing and promotional purposes.

● Respond to your customer service inquiries.

● Communicate with you about our products and services.

● Detect, prevent, and address technical issues.

● Gather analysis or valuable information enabling us to monitor the usage of our websites.

● Improve our products and services.

● Address legal issues, including (i) complying with our obligations to retain certain business records; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal processes; (iv) detecting and preventing fraud or

intellectual property infringement claims, violations of our contracts or agreements, violations of law, or other misuses of our websites or services; and (v) protecting our rights or property, or yours or others’ health, safety, welfare, rights, or property.

● Allow you to exercise your data privacy rights.

Sharing your Information

We may disclose your Personal Data to other entities under specific circumstances, including:

● Corporate affiliates that process Personal Data on our behalf to provide services or in other circumstances consistent with this Privacy Policy and applicable data privacy laws.

● Service providers that support business functions and internal operations.

● Third-party partners that we have partnered with to jointly create and offer a product, service, or joint promotion.

● Third-party analytics providers who help us analyze how our products and services are used.

● Government authorities or law enforcement officials when required by law.

● Users may be asked if they would like their information shared with other third parties not described in this policy.

● Social media platforms and networks have features or tools made that, when used, may result in information being collected or shared between us and the third-party, and their use of your information is not governed by this privacy policy.


We do not sell your Personal Data to third parties. We may share anonymized or Aggregated Data internally and with third parties for any purpose. Such information will not identify you individually.

Cookies and Automatic Data Collection Technologies

Our website may use automatic data collection technologies to distinguish you from other website users. This helps us deliver a better and more personalized experience when you browse our website. It also allows us to improve our website by enabling us to:

● Estimate our audience size and usage patterns.

● Store your preferences, so we may customize our website according to your individual interests.

● Recognize you when you return to our website.


The technologies we use for this automatic data collection may include:

● Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. For information about managing browser settings to refuse cookies, see Your Rights and Choices.

● Flash Cookies. Certain features of our website may use Flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on the website. For information about managing Flash cookies, see Your Rights and Choices.

● Web Beacons, Pixel Tags, Clear Gifs. Our website pages and emails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page

visitors or email readers, or to compile other similar statistics such as recording website content popularity or verifying system and server integrity. For information about managing web beacons, see Your Rights and Choices.

Third Party Links

Our websites include links to other websites whose privacy policies may differ from this Privacy Policy. If you submit Personal Information to any of those sites, such information is subject to third-party privacy statements. We strongly encourage you to carefully read the privacy statement of any website you visit.

Children

Our website and services are not intended for children under 13 years of age. We will not knowingly solicit or collect Personal Information from children under 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law. If we learn that we have received information directly from a child under 13 without his or her parent’s or legal guardian’s consent, we will make commercially reasonable efforts to delete such information.

Your Rights and Choices

You have certain choices about how we use and share your Personal Data. Specifically, you can:

● Opt out of receiving marketing communications from us by clicking the “unsubscribe” link in our emails.

● Set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies, please note that some parts of these websites may become inaccessible or not function properly.

● Access, rectification, and delete/cancellation your information. You can contact us as set forth in the Contact Us section below to request access to, correction of, or deletion of Personal Information that you have provided to us. We may also ask you to verify your identity before we respond to your request. Depending on your request, we may not accommodate your request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.

● Object to the collection and processing of your information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts

on your fundamental privacy rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

● Request to limit the use or disclosure of your personal information. To limit the use or disclosure of your data please contact us at privacy@zapp.global.

● If you are a US resident and your state has passed a data privacy law, contact us regarding additional personal rights and choices related to your Personal Information as provided by your state’s laws. If you would like to make a request related to such rights and choices,

please submit your request to us in writing using the information in the Contact Us section.

● Right to limit the use of sensitive personal information. Sensitive personal information means, except where the information is publicly available, information that reveals your:


Social security number, driver’s license number, state identification card, or passport number;

○ Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;

○ Precise geolocation;

○ Racial or ethnic origin, religious or philosophical beliefs, or union members;

○ Mail, email, and text message contents, unless APH is the intended recipient of the communication;

○ Genetic data;

○ Unique identity via the processing of biometric information;

○ Health information; and

○ Sex life or sexual orientation information.

In the past 12 months, we have used and disclosed sensitive personal information to fulfill the specified business purposes in this privacy policy. You can request that we limit this use by reaching out to us via the contact information in the Contact Us section.


● California Residents. If you are a California resident, you may have additional personal rights and choices with regard to your Personal Information. Please see Your California Privacy Rights in the California Consumer Protection Act Notice for more information. California’s

“Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information in the Contact Us section.


● Colorado Residents. This section concerning the CPA applies solely to individuals who are residents of the State of Colorado. Colorado residents have the following consumer rights:

o Right to opt-out of targeted advertising, sale of Personal Information or profiling for

automated decision purposes

o Right to know about Personal Information collected or disclosed

o Right to request deletion of your Personal Information

o Right to request correction

o Right to limit the use of your sensitive personal data


We note that we do not sell your Personal Information.


For the specific details of the rights and the process for submitting consumer rights requests, please submit your consumer request to us at privacy@zapp.global and write “Request for Colorado Privacy Data” as the subject of the message or call us at (832) 497-0976. We will

not discriminate against consumers who exercise their consumer rights.


● Connecticut Residents. This section concerning the CTDPA applies solely to individuals who are residents of the State of Connecticut. Connecticut residents have the following consumer rights:

o Right to opt-out of targeted advertising, sale of Personal Information or profiling for automated decision purposes

o Right to know about Personal Information collected or disclosed

o Right to request deletion of your Personal Information

o Right to request correction

o Right to limit the use of your sensitive personal data


We note that we do not sell your Personal Information.


For the specific details of the rights and the process for submitting consumer rights requests, please submit your consumer request to us at privacy@zapp.global and write “Request for Connecticut Privacy Data” as the subject of the message. We will not discriminate against

consumers who exercise their consumer rights.


If we deny your consumer request, consumer shall have the right to appeal the denial of the request. Consumers may appeal their consumer requests by emailing us at privacy@zapp.global explaining why the denial of the request should be reconsidered. We will provide a response no later than sixty days after receipt of the appeal informing the consumer in writing if any action was taken or was not taken in response to the appeal and the reasons for the decisions.


● Nevada Residents. Nevada residents have the right to opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we do not have plans to sell this information.


● Utah Residents. This section concerning the UCPA applies solely to individuals who are residents of the State of Utah. Utah residents have the following consumer rights:

o Right to opt-out of targeted advertising, sale of Personal Information or profiling for

automated decision purposes

o Right to know about Personal Information collected or disclosed

o Right to request deletion of your Personal Information


We note that we do not sell your Personal Information.


For the specific details of the rights and the process for submitting consumer rights requests, please submit your consumer request to us at privacy@zapp.global and write “Request for Utah Privacy Data” as the subject of the message. We will not discriminate against consumers who exercise their consumer rights.


● Virginia Residents. This section concerning the VCDPA applies solely to individuals who are residents of the State of Virginia. Virginia residents have the following consumer rights:

o Right to opt-out of targeted advertising, sale of Personal Information or profiling for automated decision purposes

o Right to know about Personal Information collected or disclosed

o Right to request deletion of your Personal Information

o Right to request correction

o Right to limit the use of your sensitive personal data


We note that we do not sell your Personal Information.


For the specific details of the rights and the process for submitting consumer rights requests, please submit your consumer request to us at privacy@zapp.global and write “Request for Virginia Privacy Data” as the subject of the message. We will not discriminate against consumers who exercise their consumer rights.


Exercising Your US State Privacy Rights.

To exercise your right to know, right to obtain a copy, or right to delete your Personal Information as described above, please submit your consumer rights request to us by contacting us at: privacy@zapp.global


Before fulfilling your request, we take steps to verify that you are who you say you are or you have the authority to act on someone else’s behalf. Therefore, upon receipt of your request, we may request additional information that we need to verify you and, if you are submitting a request on behalf of someone else, to verify that you are permitted to act on that person’s behalf.


When we contact you to request verification information, please respond and provide the information that we have requested. Depending on the nature of your request, we will verify your identity to either a reasonable or high degree of certainty. This may mean that we need to match two or three pieces of information that we hold about you with information that you provide to us.


In addition to providing the information we need to verify you or your authority, you must provide us with enough information so that we can understand, evaluate, and respond to your request. We cannot respond to your request or provide you with Personal Information if we cannot confirm the Personal Information relates to you.


We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request and to locate relevant information. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and to understand, evaluate, and respond to your request.


We cannot delete Personal Information in those situations where our retention is required for our own internal business purposes or otherwise permitted by applicable laws (such as fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.


We will attempt to respond to your privacy request within forty-five (45) days of receipt. If we require an additional forty-five (45) days to respond to your request. We will inform you of the reason and extension period in writing.


If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.


Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. When you request a copy of your Personal Information, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity easily.


We do not charge a fee to process or respond to your privacy request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide a cost estimate before completing your request.


If we deny your privacy request, you have the right to appeal the denial of the request. You may appeal your request by emailing us at privacy@zapp.global explaining why the denial of the request should be reconsidered. We will provide a response no later than sixty (60) days after receipt of the appeal informing the consumer in writing if any action was taken or was not taken in response to the appeal and the reasons for the decisions.

International Transfers

We are a company located in the United States, and our services are provided to individuals residing in the United States. Our services allow residents of the United States to send funds and associated Personal Information to individuals located in other countries. If you are using our website from outside the United States, you should be aware that the information collected on this website and through our services may be stored and processed in the United States or any other country in which we, our affiliates, or our service providers maintain facilities, including hosting services or servers. By providing your information to our website or services, you are consenting to the transfer of your information (including placing cookies) outside of your country in accordance with this Privacy Policy. You are also consenting to the application of United States law in all matters concerning our website and services.


The processing of personal information will be performed as described in this Privacy Policy.

Data Security

We take data security seriously and have implemented reasonable measures to protect your Personal Data from unauthorized access, disclosure, or use. We also require our service providers and business partners to whom we disclose information to do the same. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security and any transmission of Personal Information is at your own risk.

How Long Do We Retain Your Information

Your Personal Data will only be kept for as long as necessary to fulfill the purposes it was collected for, and to satisfy any legal or reporting requirements. The retention period will be determined based on applicable laws and regulations, the nature and sensitivity of the data, the risk of unauthorized use or disclosure, and the purposes for which the data was collected.

Changes to this Privacy Notice

We may update this privacy notice from time to time. We will notify you of any significant changes by posting a notice on our website or application. We encourage you to review this notice periodically for any updates.

Complaints

If you have a complaint regarding our handling of your Personal Information please contact our Customer Service team.

Contact Us

If you have any questions, comments or requests about this privacy notice, please contact us at:

Zapp Inc.

Attn: Privacy Department

2001 Timberloch Place, Suite 500, The Woodlands, TX 77380

(281) 899 0553 , or hola@zapp.global

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2001 Timberloch Place, Suite 500, 

The Woodlands, TX 77380

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