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.

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.

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.

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.

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.

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.