Privacy Policy

If you are a ZAPXY, Inc. (“ZAP”) customer, app holder or user, this privacy notice applies to you. It explains what data we collect about you, what we do with it, when and why we share it with others, how long we keep it, how we secure it, what cookies are and what they (and similar technologies) do, what data is collected about you by third-party service providers, and what choices you have to control your data. By using ZAP, you consent to these data practices.

This privacy notice describes how ZAP, our affiliates and white label partners (“we” and “us”) collect, use, disclose, transfer, store, retain or otherwise process your information when you (‘you,” “your”) download ZAP through a relevant App Store and sign up for a ZAP account and other services through the app or online at zapxy.com (collectively “Services”).

This Privacy Notice applies to your use of the Services and covers only information collected in connection with your access to and use of our Services.  Please read this Privacy Notice carefully. By continuing to interact with our Services, you are consenting to the practice is described in this Privacy Notice.

Our Privacy Notice explains:

  • Information we collect about you

  • Sources of information we collect about you

  • How and when we use your information

  • When and with whom we share your information

  • Cookies or other similar automated technologies

  • How long we keep your information

  • Your choices

  • Rights of California residents

  • Security

  • Storage and processing

  • Changes to this Privacy Notice

  • How to contact us

Information We Collect About You

We use your data to make ZAP work better for you and others.  This describes what data we get about you (which can vary depending on where you live).

It is necessary to collect information about you to provide you with the Services or the support you request. Specifically, we collect (and/or have collected during at least the 12-month period preceding the effective date of this Privacy Notice) the categories of personal information below. Additionally, you can voluntarily provide information to us.

Information you provide to access the Services

We use data you put into our systems when you use ZAP like financial information, information that identifies who you are, transaction information, and any other information you give us.

We collect the information you provide when you apply or sign up for a ZAP account, go through our identity or account verification process, authenticate into your account, communicate with us, answer our surveys, participate in contests or promotions offered by us or our partners, or otherwise use our Services.

We collect the following categories of information about you when you use our Services, including:

  • Identification Information. such as: Your name, email address, mobile phone number, ZIP Code, signature and authentication credentials (for example, information you use to log into your ZAP account) including Internet Protocol (“IP”) address.

  • Additional Identification Information for Verified Users.  such as: Your Full mailing address; date of birth; government-issued identification, including Social Security number, passport or driver’s license; and photograph and voiceprint.

  • Financial Information. such as: Bank account and PIN you add to your ZAP account.

  • Contacts Information. In order to provide you with the Service, we will also need to collect information from you about the intended recipient of the payment you request us to make. We will therefore ask you to provide contact details of your intended recipient. You can do this by: (a) scanning a QR code, (b) manually entering a phone number or email address into the ZAP app, or (c) as described below (under Information You Provide to Enhance Your Experience), you can choose to give us access to your phone contacts to facilitate the entry of recipient information. We may also ask you to provide limited access to your phone contacts for account verification purposes. You can update your settings to stop sharing your phone contacts with us at any time, although we will always need a recipient’s phone number or email address to send money to them as requested by you.

  • Transaction Information. When you use our Services to make, request or accept payments, we collect information such as: when and where are the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer of such amounts, and the devices and payment method used to complete the transactions.

Information You Provide to Enhance Your User Experience

We also use data you give us to make your experience with ZAP better, like contacts you upload to make it easier to exchange money with them.

You can choose to provide us with additional information to improve your user experience when using our Services:

  • Contacts Information. If you choose to give us access to your phone contacts, we collect all the telephone numbers of all your phone contacts to facilitate the entry of payment recipient information. You can update your settings to share your phone contacts with us at any time, although we will always need a recipient’s telephone number or email address to send money to them as requested by you.

  • Other Information You Provide. We collect information that you voluntarily provide to us, including your photograph if you choose to upload a photo to the Services; survey responses; participation in contests or other prospective marketing forms or devices; suggestions for improvements; referrals; photo and/or voiceprint for security purposes; referrals; or any other actions you perform on the Services.

Information We Collect from Your Use of our Services

We also get information from the devices you use when you interact with our systems, like your location and information about the device you’re using. We need this data to do things like help protect your account from hackers, combat fraud, check to see if payments are made or received legally and by you, and making our products and services better for you and others.

We collect information about you in the devices you use to access the Services, such as your computer, mobile phone, or tablet. The information that we collect includes:

  • Geolocation Information. The location of your device, including your IP address, device language, and the location of your network provider. For more information and to learn how to disable collection of location information from your mobile device, please see below.

  • Geolocation Information. The location of your device, including your IP address, device language, and the location of your network provider. For more information and to learn how to disable collection of location information from your mobile device, please see below.

  • Internet or Other Electronic Network Activity Information. Information about how you use an interact with our Services, including your access time, your “log-in” and “log-out” information, country and language setting on your device, IP address, mobile device and operating system, features you use, and the date and time of your use of the Services.

  • Inferences drawn from any of the information we collect to create a profile about you that may reflect, for example, your preferences, characteristics, and behavior, including for account security purposes or to enhance our Services to you.

Sources of Information We Collect About You

We also have to check to make sure you are using our Services legally, that you are eligible for the Services you want to use, and we protect your data and our Services from fraudsters who may put you and your money at risk.  To do this we collect data about you from companies that help us verify your identity, do a credit check, prevent fraud, or assess risk.

We collect (and/or have collected during at least the last 12-months period preceding the date of this Privacy Notice) information about you from the following categories of sources:

  • You directly, when you submit information to us or allow us to access information

  • Your devices and how you interact with the Services

  • Our partners or affiliates

  • Identity Verification. Information from third-party verification agencies (e.g. Identification verification agencies and through companies that provide third-party analytics), and publicly available sources. In some circumstances, where lawful, this information can include your government-issued identification number.

  • Compliance, and Fraud. Information about you from third parties from any identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law.

How We Use Your Information

We use your data to do things like make sure the products you are using work, help you log into your account, verify who you are, secure your data, fight fraud, follow the law, enforce our agreements, figure out what new products we can build, and market and tailor our products to you.

We may collect, use, and share (or have collected, used, and shared during at least the 12-month period preceding the effective date of this Privacy Notice), information about you for the following reasons:

Providing, Improving, and Developing Our Services

  • Determining whether the Services are available in your country;

  • Processing or recording purchases from Approved Merchants;

  • Processing or recording payment transactions or money transfers;

  • Providing you with the ZAP product and features you choose to use;

  • Displaying your historical transaction information;

  • Connecting you with Merchants you already know so you can receive notifications;

  • Receiving your Merchant referrals and suggestions;

  • Connecting you with people you already know;

  • Developing new products and services;

  • Delivering the information and support you request through the use of our Services;

  • Improving, personalizing, and facilitating your use of our Services, content and applications;

  • Measuring, tracking, and analyzing trends and usage in connection with your use or the performance of our Services; and

  • Otherwise providing you with the products and features you choose to use.

Communicating with You About Our Services

  • Sending you surveys and getting your feedback about our Services; and

  • Sending you information we think might be useful or which you have requested from us about our products and services.

Protecting Our Services and Maintaining a Trusted Environment

  • Conducting, complying with and enforcing any applicable laws, regulations, legal requirements, and industry standards, and responding to lawful requests from the government or to valid legal process;

  • Contacting you to resolve disputes, collect fees and help you with our Services;

  • Debugging to identify and fix errors that impair our Services function;

  • Making sure you follow our General Terms of Service or other applicable agreements or policies;

  • Investigating, detecting, preventing, recovering from, or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious or illegal activities, or otherwise help protect your account, including to dispute chargebacks on your behalf;

  • Protecting your, our, or our other customers’ rights or property, or the security or integrity of our Services;

  • Verifying or maintaining the quality and safety of our Services; and

  • Verifying your identity (e.g. through your government-issued identification numbers)

Advertising and Marketing

  • Marketing our Services to you;

  • Communication and notifications from Approved Merchants;

  • Communicating with you about products, opportunities, services, promotions, contests discounts, incentives, surveys and rewards offered by us and select partners.

Other Uses

  • For any other reason we may tell you about from time to time.

When and With Whom We Share Information

We share your information with others in the circumstances described in this section. For example, with other people with whom you interact when you use the Services; with service providers who help us run our services; or if we need to share information to comply with the law.

We may share the information described in the “Information We Collect About You” section with the following categories of service providers in third parties:

With Other Users of Our Service with Whom You Interact

  • Approved Merchants

  • With other users of our Services with whom you interact through the use of our Services.  For example, we may share information with the person(s) with whom you transact when you make or accept a payment or money transfer using our Services.  This helps them know they are getting money from you (or that you requested a payment from them).

With Our Service Providers

  • With service providers that help us provide maintain and improve our Services (e.g., vendors who help us with fraud prevention, identity verification and fee collection services) as well as financial institutions, payment networks, and other entities in connection with your payment, money transfer process, or otherwise to help us provide the Services; and

  • With service providers that help us run our advertising campaigns, promotions, contests, special offers, or other events and activities.

Business Transfers and Corporate Changes

  • To a subsequent owner, co-owner, or operator of one or more of the Services; or

  • If we do or try to do a corporate merger, consolidation or restructuring (including during due diligence and negotiating of these); sale of all or substantially or of our stock and/or assets; the financing, acquisition, divestiture or dissolution of all or a portion of the business; or other corporate change

Safety and Compliance with the Law

  • If we believe that a disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or government request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.); (ii) to establish, defend or exercise legal rights; (iii) to enforce or comply with our General Terms of Service or other agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; (vi) or to protect us, users of our Services or the public from harm, fraud or potentially prohibited or illegal activities.

With Your Consent

  • With your consent, for example at your direction or as described at the time you agree to share.

With Others

  • With other companies who deliver services on our behalf and third-party analytics.

Aggregated and Anonymized Information

  • We also may share with affiliates, service providers or third parties aggregated and anonymized information that does not specifically identify you or any individual user of our Services.

How Long We Keep Your Information

We keep your information as long as you continue to use our products and services.  After that we keep it as long as we need it to do things like fight fraud, collect fees you owe, resolve disputes with (or involving) you, follow the law, enforce our agreements, and defend ourselves in court.

We generally keep your information as long as reasonably necessary to provide you the Services or to comply with applicable law. However, even after you deactivate your account, we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations, or as we believe reasonably necessary to comply with applicable law, regulation, legal process or government request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our General Terms of Service or other agreements or policies, or to take any other actions consistent with applicable law.

Your Choices

You can see, fix or change information you gave us, ask us to deactivate your account, control your location information, or tell us to stop marketing to you by opting out.

If you live in California, you have additional rights which we discuss below

Personal Information

You can access, change, or correct information that you have provided by logging into your ZAP app anytime or by making a request to us at the contact details below.  We will need to verify your identity before granting access or otherwise changing or correcting your information.

Deactivating Your Account

If you want to deactivate your account, you can do so at any time by deleting your account from your phone and by emailing us at deactivate@zapxy.com from the email you signed up with. Please include your mobile number in the header and be aware that we may contact you via phone to make sure you made the deactivation request.

Location Information

In order to provide certain Services, we may require access to location information, including precise geolocation information collected from your device. If you do not consent to collection of this information, certain Services Will not function properly and you will not be able to use those Services. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, some of our mobile applications will no longer function. You may also stop our collection of location information via mobile application by following the standard uninstall process to remove the ZAP mobile application from your device.

Promotional Communication

After Beta Testing is complete, you will be able to opt out of receiving in-app push notifications containing promotional messages from any or all Approved Merchants, or us, by adjusting the settings on your mobile device or by following the instructions in those messages. If you decide to opt out, we may still send you non-promotional communications in-app, by text, or email such as transaction receipts and Messages about your account, or processing of information in accordance with provision of the Services.

Rights of California Residents

If you live in California, the following rights apply to you.

Right to Know

You may have the right to request, up to twice in a 12-month period, to see the following information about the personal information we have collected about you during the past 12 months:

  • The categories in specific pieces of personal information we have collected about you:

  • The categories of sources from which we collected the personal information;

  • The business or commercial purpose for which we collected the personal information;

  • The categories of third-parties with whom we shared the personal information; and

  • The categories of personal information about you that we disclosed for a business purpose, and the categories of third-parties to whom we disclose that information for a business purpose.

To request the specific pieces of personal information we have collected about you, see “How to Exercise Your Rights” below. You may find all of the other information listed above in this Privacy Notice.

California law gives you the right to ask if we disclose your personal information to third-parties for their direct marketing purposes (we do not disclose your personal information for others’ direct marketing purposes). It also gives you the right to ask if we sell your personal information to third-parties (we do not sell your personal information, and have not done so in the past), and if we did (which we don’t), you would have the opportunity to opt out of such sales.

Right of Deletion

You have the right to ask us to delete the personal information we have collected from you (subject to the limitations that the law provides). Please note that you may no longer be able to use the Services if you delete your personal information.

Right of Non-Discrimination

You have the right not to be discriminated against if you exercise these privacy rights. We will not discriminate against you, deny, charge different prices for, or provide a different quality of goods and services if you choose to exercise these rights.

How to Exercise Your Rights

If you live in California and would like to send us a request to exercise one of your rights, you may do so online at http://www.zapxy.com or by contacting us as indicated in the “How to Contact Us” section below.

To help protect your privacy and maintain security, we take steps to verify your identity and will require you to be logged in to the ZAP account before granting you access to your personal information or complying with your request.

You may designate an authorized agent to make a request on your behalf as permitted under law, though before we process the request, we will require you to provide the authorized agent written permission to do so and verify your identity directly with us. To the extent permitted by law, we may charge a reasonable fee to comply with your request.

Children’s Personal Information

If you are under age 13, immediately delete our app and our services. If we collect your data and later find out you under 13, we will delete it.

Our Services are general audience service is not directed at anyone under age 13. If we learn that any information we collect has been provided by a child under the age of 13, we will promptly delete that information.

How We Secure Information

We do a lot to keep your data safe. While we think we have strong defenses in place, no one can ever guarantee that hackers won’t be able to gain access to our platform or steal your data while it is stored or flowing from you to us or vice versa.

We take reasonable measures, including administrative, technical and physical safeguards, to protect your information from loss, theft and misuse, and unauthorized access, disclosure, alteration and destruction. Nevertheless, the Internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information of you both at our own premises and with the assistance of third-party service Providers.

Storage and Processing

We operate in many countries, and we (or our service providers) may move your data and process it outside the country where you live.

We may, and we may use third-party service providers, to process and store your information in the United States, Canada, England, Japan, the European Union, and other countries.

Changes to This Privacy Notice

We can change this Privacy Notice. When changes impact your rights or how we use your information in important ways, we will tell you first by email (if you’ve given us your email information).

We may amend this Privacy Notice from time to time by posting a revised edition and updating the “Effective Date” above. The revised date will become effective on the “Effective Date” listed. We will provide you a reasonable prior notice of material changes in how we use your information, including by email, if you have provided one. If you disagree with these changes, you may cancel your account at any time. If you keep using our Services, you consent to any amendment of this Privacy Notice.

How to Contact Us

You can contact our privacy team with any questions or concerns at the address below.

Please contact our privacy team with any questions or concerns regarding this Privacy Notice at ZAP, Inc., 101 Jefferson, Menlo Park, California 94025, USA. privacy@zapxy.com

If you have any questions or concerns regarding our privacy notice, or if you believe our privacy notice or applicable laws relating to the protection of your personal information have not been respected, you can file a complaint with our privacy team listed above. We will respond to let you know when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may, but are not required to, keep records of your request and any resolution