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PRIVACY POLICY

This Privacy Notice is designed to help you understand how Zapshot (“we”, ”us”, “our“)  collect, use, and share your personal information and to help you understand and exercise your privacy rights. Please read our Privacy Notice carefully to get a clear understanding of how we collect, use, protect, or otherwise handle your Personally Identifiable Information in accordance with our website.

 

1. SCOPE

This Privacy Notice applies to personal information we process, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Notice easier to read, our websites, mobile applications, and other offerings are collectively called “Services.”

2. CHANGES TO THIS PRIVACY NOTICE

We may revise this Privacy Notice from time to time at our sole discretion. If there are any material changes to this Privacy Notice, we will notify you and obtain your consent before you are permitted to continue to use the site as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

 

3. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources, such as third-party services and organizations, as described below.

  A . Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

  • Registration and Account Creation. We may collect information when you register on our site and create an account, such as (a) name, username, email address, biography, social media links, phone number, and language and (b) your voice, and image of your face (if you give us permission to do so), and (c) other information to help you with your experience.

  • Your Communications with Us. We may collect personal information, such as email address, phone number when you request information about our Services, fill out a form, use live chat, register for our newsletter, request customer or technical support, or otherwise communicate with us.

  • Surveys. We may contact you to participate in surveys.  If you decide to participate, you may be asked to provide certain information which may include personal information.

  • Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein.  However, you can turn off other users’ ability to search for you on the app via your profile information.  Please see Section 6 (“Your Privacy Choices”) for more information about this.

 

  B. Information Collected Automatically 

We may collect personal information automatically when you use our Services:

  • Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during, and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.  In addition, we may collect information that other people provide about you when they use our Services.

  • Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. 

  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, and improve security or that allow you to make use of our functionality;

  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);

  • Functionality-Related. We may use technologies that allow us to offer you enhanced functionality when you access or use our services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

  • Advertising- or Targeting-Related. We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services, or on third-party websites.

See Section 6 below to understand your choices regarding these Technologies.

  • Analytics. We may use technologies and other third-party tools to process analytics information for our services. Some of our analytics partners include:

  • Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

  • Biometric Information. If you consent to our collection of biometric information, you agree that we may collect your voiceprint and an image of your face in order to enable others to identify you via your profile and view videos you post. Your biometric information may be shared with our third-party service providers Kairos, who helps us to identify you via your face, ElevenLabs, who helps us create audio based on your voice. And Cloudinary, who has access to your videos, which may contain your voice recording. Unless otherwise required by an order from a court of competent jurisdiction or applicable law, we will only retain biometric data until: (i) the initial purpose for collecting the biometric data has been satisfied, or (ii) for three years following your last interaction with us, whichever occurs first, unless legally required to keep it for a different period.

 
  C. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site like TikTok, we may collect information about you from that third-party application that you have made available via your privacy settings. 


 

4. HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including providing our services, providing administrative services, and marketing our products and services, as described below.

 

   A. Provide Our Services

We use your information to provide you with our Services, such as:

  • Managing your information and accounts;

  • Authenticating your account as part of the sign-up process via SMS;

  • Providing access to certain areas, functionalities, and features of our Services, including other users to search for you on our service via a photo of your face (if you consent to us doing so);

  • Personalizing your experience and delivering the types of content and product offerings you are most interested in;

  • Answering requests for customer or technical support; 

  • Communicating with you about your account, activities on our Services, and policy changes;

  • Administering contests, promotions, surveys, or other site features;

  • Allowing you to register for events.

 

  B. Administrative Purposes

We use your information for various administrative purposes, such as:

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

  • Measuring interest and engagement in our Services; 

  • Short-term, transient use, such as contextual customization of ads;

  • Improving, upgrading, or enhancing our Services; 

  • Developing new products and Services;

  • Ensuring internal quality control and safety;

  • Authenticating and verifying individual identities;

  • Debugging to identify and repair errors with our Services;

  • Auditing relating to interactions, transactions, and other compliance activities;

  • Enforcing our agreements and policies; and

  • Complying with our legal obligations.

 

  C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audience advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time, as set forth in section 13 below. 

 

  D. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

  • Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

  • Automated Decision Making. We may engage in automated decision-making, including profiling. Our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision-making, you may contact us as set forth below.

  • De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

  • Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend who does not have an account with us to use our Services.



 

5. HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. 

  A. Disclosures to Provide Our Services

The categories of third parties with whom we may share your information are described below. 

  • Service Providers. We may share your personal information with our third-party service providers, who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.

  • Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.

  • Affiliates. We may share your personal information with our company affiliates. 

  • Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” 

  • APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For example, if you permit us to collect a photograph of your face, that image and your phone number is sent to our third-party service provider, Kairos via API where Kairos processes it to enable us to make our service available to you.  For more information about our use of APIs and SDKs, please contact us as set forth in Section 14 below.

 

  B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

​  C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties.

 

6. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below. 

  • Global Search Settings.  You have a choice about whether users can search for you via our app.  To configure your global search settings, please click on the profile icon on the bottom row of the app.  You will be taken to your profile page.  On your profile page, you may change your icon, status, language, whether you receive notifications via the app (on/off), and whether others can search for you via the app (on/off).  

  • Adding/Removing Friends. If you choose to activate your phone book on the Friend tab, contacts registered in your mobile device contacts will automatically be added as Friends.  You can send a request to the account you wish to be friends with, and if they accept, they will be added to the Friend list. You can remove friends anytime by clicking Friends.

  • Mobile Devices. We may send you push notifications through our mobile application. You may opt out of receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information if you use our mobile application. You may opt out of this collection by changing the settings on your mobile device.

  • “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we honor DNT signals or similar mechanisms transmitted by web browsers.

  • Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for iOS.

 

Your Privacy Rights. In accordance with applicable law, you may have the right to:

  • Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);

  • Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

  • Request Deletion of your personal information; You have the right to request that we delete personal information that we have collected from you;

  • Limit the Use of My Sensitive Personal information; You have the right to direct us not to use or disclosure your sensitive personal information;

If you would like to exercise any of these rights, please contact us as set forth in Section 13 below. We will process such requests in accordance with applicable laws.

 

7. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on our Services, or by sending an email to you.


 

8. RETENTION OF PERSONAL INFORMATION 

Except as described in Section 3(B) above with respect to biometric information, we store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. SUPPLEMENTAL NOTICE FOR U.S. RESIDENTS

This U.S. Privacy Notice (this “Notice”) covers our information collection practices and describes your rights regarding your personal information for the United States of America (U.S.) residents. 

All terms defined in the privacy laws of the states of the U.S. (respectively and collectively, the “State Privacy Law(s)”) have the same meanings when used in this section. 


 

Categories of personal information we collect

 U.S. residents have the right to know what categories of personal information we collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. U.S. residents can find this information below:

“Sales” or “Share” of Personal Information under the State Privacy Laws

For the purposes of the respective State Privacy Laws, we do not sell or share your personal information, including personal information of children under the age of 16, or sensitive information, and we have not sold or shared any personal information during the 12 months preceding the effective date of this Notice.

Our Use and Disclosure of Sensitive Personal Information

Without your consent, we do not use or disclose your sensitive information for purposes other than those specified by State Privacy Laws.

Additional Privacy Rights for U.S. Residents

You may exercise the following rights by contacting us or a representative or data protection officer. If you request to exercise the following rights, please contact us as set forth in section 13 below.

Non-Discrimination. U.S. residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by respective State Privacy Law. 

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in section 13 below.

Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request,  we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

If you are a U.S. resident and would like to exercise any of your rights under respective State Privacy Laws, please contact us as set forth in Section 13 below. We will process such requests in accordance with applicable laws. 

 

California Shine the Light. We are exempted from the requirement to grant such a request because we do not disclose personal information of customers for third parties’ direct marketing purposes unless a customer directs us.

Privacy Rights for California Minors in the Digital World. If you are under the age of 18, you have the right to request permanent deletion of the reviews of products you posted on our service. Please note that, when you post the reviews they can be collected, stored, or shared by others, and we cannot delete such information held by others. If you request to exercise the above rights, please contact us as set forth in section 13 below.

 
10. SUPPLEMENTAL NOTICE FOR EU RESIDENTS

This Supplemental GDPR Privacy Notice only applies to our processing of personal data that is subject to the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) and equivalent laws of the United Kingdom of Great Britain and Northern Ireland (the “UK”)(“GDPR”). This Notice is applicable only to personal data concerning data subjects (“you” or “your”) in the member states of the European Union and three EEA/EFTA states - Iceland, Liechtenstein, Norway (collectively, the  “EU”), and the UK.

For purposes of this notice, the terms defined under the GDPR have the meanings ascribed to them under the GDPR.

 

We are responsible for your personal data as a data controller. If you have any questions or would like to uphold your rights, please contact us at;

Email: info@ph7.ltd


 

Transfers to third countries outside the EU

Your personal data may be transferred to third countries outside the EU with or without an adequate decision by the European Commission. In the case of any transfer of personal data to a country that does not have an adequate level of data protection in light of the standards under the GDPR, we will ensure such transfer will be made through the Standard Contractual Clauses adopted in accordance with the GDPR. 

 

No obligation to provide your personal data

You have no obligation to provide your personal data to us either under applicable law or a contract. Once you make an order for our services, we may require your personal data based on the contract with you, in which case your failure to provide the personal data we require may prevent us from providing you with the services. 

 

Profiling

We will not make decisions based solely on automated processing, including profiling on collected personal data, which produces legal effects concerning the User or similarly significantly affects the User.

 

Additional Privacy Rights for EU Residents

You may exercise the following rights by contacting us or a representative or data protection officer. If you request to exercise the following rights, please contact us as set forth in section 13 below.

Right to erasure. You may obtain the erasure of your personal data, subject to certain exceptions under the GDPR, where: (i) such personal data is no longer necessary in relation to the purposes for which we collected and processed it; (ii) you withdraw your consent to our processing solely based upon your consent; (iii) you object to our processing and there are no overriding legitimate grounds for such processing; (iv) our processing is unlawful; (v) your personal data has to be erased in compliance with a legal obligation. 

 

Right to restriction of processing. You may obtain restriction of processing of your personal data, subject to certain exceptions under the GDPR, where: (i) you contest the accuracy of your personal data: (ii) our processing is unlawful, and you select to restrict our processing instead of requesting erasure of your personal data: (iii)  you request us to establish, exercise or defense legal claims that need your personal data no longer necessary for the purposes of our processing; or (iv) you exercise the right to object to our processing and wait for verification on where we have overriding legitimate grounds.

 

Right to data portability. You may receive your personal data or direct us to transmit your personal data to a third party you designate, provided that we process such personal data based upon your consent or as the performance of a contract with you.

 

Right to object. You may object to the processing of your personal data where our processing is based upon the exercise of our official authority or our legitimate interests, including “profiling” or for direct marketing purposes.

 

Right to the withdrawal of your consent. You may withdraw your consent at any time to the processing of your personal data that we have collected about you. The legality of processing based on consent prior to withdrawal will not be affected by withdrawal of consent.

 

Right to complain. You may lodge a complaint with the supervisory authority, in particular, in the member state of the EU or the UK where you have a habitual residence or place of work or where the alleged infringement of GDPR took place.

 

11. CHILDREN’S INFORMATION

The Services are not directed to children under 13 in the United States and under the applicable age of consent in other countries ("Child" or "Children"). We do not knowingly collect or store personal information from Children. However, we do collect information, including personal information, from all users of the Services. If you believe we may have unintentionally collected personal information from your Child, please contact us as set forth in section 13 below.

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12. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications, and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk. 

 

13. CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:

PH7, Ltd.
10940 Wilshire Blvd. Los Angeles​, CA​, 90024

https://www.zapshot.me/contact

info@ph7.ltd


 

Additionally, if you reside in the EEA, you can contact our Data Protection Officer, European representative, UK representative, or file a complaint with the supervisory authorities in Europe, the UK.

  • Representative

Our representative in the EU/UK is Classmethod (Europe) GmbH. You can contact our representative at;

 

Mail: Krausenstr.9 -10, 10117 Berlin, Germany 

Email: gdpr@ph7.ltd

 

  • Data Protection Officer

You can contact our Data Protection Officer at;

Email: dpo@ph7.ltd

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