Date of Last Revision: January 11th, 2019
1. WHAT TYPES OF INFORMATION DOES ZEDGE COLLECT?
User Provided Information. We obtain certain information when you provide it to us: for example, if you setup your account profile, sign in using your Facebook Connect or Google login, or report a problem, you may provide your name, email address, your date of birth, photograph, and a list of interests such as your favorite music and television shows. Some of that information can be used by Zedge to identify or contact you directly and is sometimes referred to as personally identifiable information. When you purchase virtual currency or products through our Services, we use a third-party payment processor that collects your payment information and completes the transaction. We use the personally identifiable information in the file we maintain about you, and other information we obtain from your current and past activities on the Services to: deliver the products and services that you have requested, manage your account and provide you with customer support, communicate with you about products or services that may be of interest to you, and to monitor compliance with the rules governing the Services. We don't sell your personally identifiable information to third parties.
Legal basis: We need this information to process your registration, order, payment or any other service you request from us (performance of a contract), to facilitate your use of the Websites or Mobile Apps and support Zedge's business model (balance of interests).
Information from Use of our Services. Zedge also gathers information from Users of our Services and may include: the Internet Protocol (IP) address, unique device identifiers, anonymous IDs for advertising, operating system, mobile network information, browser type, existing applications, browsing activity and non-precise device location information (e.g., city or region), as well as crash logs to improve our service. We do not write the User's IP address to disk and we discard it at the earliest possible stage we can while still being able to offer our Services.
Zedge analyzes this information gathered from users of the Services to help better understand how our Services are being used and to help tailor content and advertising across the Services. By recognizing patterns and trends in usage, Zedge is able to better design the Services to improve Users' experiences, both in terms of content and ease of use and information broadcasting through in-app notifications, push-notifications or campaigns through external services. We also may share non-personally-identifying information with third parties, including but not limited to advisors, advertisers, analytics providers, and investors, for the purpose of conducting business and improving the service.
Legal basis: We use and share this information to provide you offers and recommendations and to tailor and enhance your experience on the Websites or in the Mobile Apps when expressly agreed by you (consent) as well as to maintain the security on the Websites and in the Mobile Apps and also improve the Services on an aggregate basis (balance of interests).
Opt-Out of Marketing: You can always opt-out of our marketing via the unsubscribe button in any of our marketing.
Zedge Login. When you login directly through Zedge, we can access the information you provided during your account profile setup.
Legal basis: We need this information to process your registration, order, payment or any other service you request from us (performance of a contract).
User Generated Content. We offer our Users the opportunity to create profiles and upload images and audio. Such activities are governed by our Terms of Service. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Whenever you voluntarily disclose personally identifiable information on publicly viewable web pages or applications, that information will be publicly available and can be collected and used by others and reproduced on websites or services over which we have no control. Further information is contained in the Zedge online safety and best practices guidelines.
Legal basis: We need this information to provide you with the services you request from us (performance of a contract).
Social platform connect tools. On the Websites and/or in the Mobile Apps you can choose to use your social platform account to connect or login to Zedge. Please be aware that we may receive more information from the social platform provider than actually needed to provide our services to you. We will not use such information that we do not need. If you do not want us to receive other information than described below in the next paragraphs, please use another option to set up an account.
Facebook Connect. When you choose to connect or login to Zedge with your Facebook account, we can access certain information you've added on Facebook in order to provide a social and personalized experience while using the Service. We adhere to the Facebook Platform Policies which restrict how we may can access and use this information. If you log into our services via Facebook Connect, we collect only information needed from your Facebook account, such as your name and email address. If more information is transferred from Facebook, we will not retain this.
Google+. When you choose to connect or login to Zedge with Google+, we can access certain information you've added on Google+ in order to provide a social and personalized experience while using the Service. We adhere to the Google+ Platform Developer Policies , which restrict how we may access and use this information. If you log into our services via Google+, we collect only information needed from your Google+ account, such as your name and email address. If more information is transferred from Google+, we will not retain this.
Legal basis: We need this information to facilitate your use of the Websites or Mobile Apps (balancing of interests).
Device Information. When you access the Services on your wireless device, we may obtain information from your wireless carrier about the type of device you are using. We may use this information to notify you about what type of features and products from Zedge may be available to you on your device.
Legal basis: We use this information to enhance your mobile use of the Website and Mobile Apps (balancing of interests).
General Location. When you access the Services on your wireless device, we may obtain your general location information when you use our Services. We may use and store this information to provide enhanced location-based Services as well as to serve location-targeted advertising, which includes communication to third party Services providers who have agreed with Zedge to keep such information confidential and only use such information to the extent necessary to perform the Services as required by Zedge.
Legal basis: We need this information to provide the services that you request from us when you expressly agree to the processing (consent).
Precise Location. In the event that you utilize a portion of the Services which requires your specific GPS location, we will obtain your consent before doing so.
Legal basis: We need this information to provide the services that you request from us when you expressly agree to the processing (consent).
Zedge Beta Users. From time to time, Zedge will offer to its users the opportunity to Beta test a new Mobile App or Mobile App feature. Participation is entirely voluntary. Users who elect to sign-up to Beta test these features are "Beta Users". Beta Users may be asked to provide additional personal information as part of the Beta test, such as precise geolocation, or will be able to access certain other features, such as making in-app purchases. For each Beta test, the Beta User will be provided with a disclosure about the data collection, use, and sharing practices specific to that Beta test, and will only be permitted to become a Beta User upon acceptance of those specific terms.
Legal basis: We need this information to enable you to use the services as Beta User (performance of a contract).
Email. In the case of Zedge wanting to communicate with you through your email for other purpose than strictly tied to the service, we will ask for specific consent to do so with clear information about how to later opt-out again.
Contacting Zedge. When you contact us via the Websites or the Mobile Apps, we process personal identifiable information like name, email address, organization, phone number, country, information about your request and any other information that you provide to us. We only use your information to answer your request.
Legal basis: We need this information to answer your questions regarding your use of the services, order, payment (performance of a contract) or any other question (balance of interests, Art. 6(1)f GDPR).
2. THIRD PARTY ADVERTISERS - YOUR AD CHOICES
We use third-party advertising companies to serve ads when you visit the Websites and/or use the Mobile Apps. These companies may use information about your visits to any of the Websites and other websites and the Mobile App(s) and other mobile applications in order to provide advertisements about goods and services of interest to you. All data that third-party advertising companies collect is tied to your Android Advertising ID which can be reset under following path: Settings ->"Google (Google Settings)->Ads->Optout of interest based ads". Iphone users can opt-out of receiving targeted ads under the following path: Setting->Privacy->Advertising->Reset Advertising Identifier. We do not respond to Web browser "do not track" signals or other similar mechanisms, and do not store any personal identifiable information in web cookies.
Some of our advertisers provides personalised ad experience, this will be explicitly asked for consent for in the Android Mobile App(s). All data that third-party advertising companies collect is tied to your Android Advertising ID which can be reset under following path : “Settings ->"Google (Google Settings)->Ads->Optout of interest based ads". Iphone users can opt-out of receiving targeted ads under the following path: Setting->Privacy->Advertising->Reset Advertising Identifier.
We may offer you the ability to purchase a subscription for an ad-free Zedge experience. As part of that subscription, you may still have the option of viewing rewarded videos in exchange for additional content access, but you will otherwise not be shown ads through the Services.
3. THIRD PARTY ADVERTISERS - Ogury
One of our third party partners who collects and uses your information to serve you ads is Ogury Ltd ("Ogury"). For a full description of who Ogury is and how it uses, transfers and protects information it collects, you can take a look at its Data Usage Principles: http://www.ogury.co/privacy.html
The data that Ogury collects may include information about your device, location, email, application, and browsing usage. The data Ogury collects may be shared within its group and with select business partners, including those based outside the European Economic Area ("EEA"). If you are based in the EEA, please note that the data privacy regulations that apply in countries outside the EEA may not offer the same level of protection as provided for inside the EEA.
All data that Ogury collects is tied to your Android Advertising ID which can be reset under following path : “Settings ->"Google (Google Settings)->Ads->Optout of interest based ads".Iphone users can opt-out of receiving targeted ads under the following path: Setting->Privacy->Advertising->Reset Advertising Identifier.
4. DISCLOSURES OF INFORMATION
As reasonably necessary to provide services to you, Zedge may share non-personally identifying information or personally identifying information with its partners or affiliates, and also with third party vendors.
Print on demand. If you opt to use our Print on Demand Services, all personally identifiable information is handled directly by the third party service providers to complete your purchase. This includes in particular your name, contact details, address, payment details, your selected item to be printed. Please be aware that we cannot influence the processing of your personal identifiable information by the third party service provider and we recommend reading the third party service provider's privacy statement before using the Print on Demand Services.
Legal basis: We disclose this information to enable you to use services (performance of a contract).
Fraud and threat protection. Zedge may disclose your information to third parties like lawyers, consultants, IT forensics or competent authorities when obligated or permitted to do so by law and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person. We reserve the right to disclose to third parties non-personally identifiable information collected for any lawful purpose.
Legal basis: We use this information to protect our Websites and Mobile Apps (balance of interests), to comply with legal obligations or carry out tasks in the public interest.
Location of Service Providers. Some recipients of your information may be located in countries outside of the EEA that do not offer the same level of protection with respect to personal identifiable information as required in the EEA and where there is no adequacy decision by the European Commission. Zedge takes a variety of steps, including implementing the required data transfer tools such as standard contract clauses approved by the European Commission or by choosing recipients that are Privacy Shield or BCR certified, to help ensure your rights and protections travel with your personal identifiable information. If you have any inquiries about our handling of your personal identifiable information, or would like to obtain a copy of the respective data transfer tool, please contact us at firstname.lastname@example.org.
5. ACCESS AND CHANGES TO PERSONALLY IDENTIFIABLE INFORMATION; ACCOUNT TERMINATION
You may be entitled to access personally identifiable information held about you, subject to certain exemptions in accordance with the applicable data protection law. You may exercise the right at any time by contacting us at the address below and including "personal information request" in the subject line.
In addition, you may at any time review or change your personally identifiable information by going to your account settings. Upon your request via your account settings, we will deactivate or delete your account and contact information from our active databases in accordance with our deactivation policy and applicable law. Please note that we may be obligated to keep some or all of your information on our servers even after you've deleted your account.
We use reasonable electronic, personnel, and physical measures to protect information from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.
We do not knowingly collect or store personally identifiable information from anyone under the age of 13 unless or except as permitted by law. ANY PERSON WHO VISITS ANY OF THE WEBSITES OR USES ANY OF THE MOBILE APPS REPRESENTS TO US THAT HE OR SHE IS 16 YEARS OF AGE OR OLDER AND HAS READ AND WILL ADHERE TO OUR ONLINE SAFETY AND BEST PRACTICES GUIDELINES. If we are made aware that we have received personally identifiable information from someone under 16, Zedge will use reasonable efforts to remove that information from our records.
9. UNITED STATES OF AMERICA
10. For EU Users: YOUR STATUTORY RIGHTS
You are entitled at any time to request information about your personal identifiable information that we store, and request us to rectify, erase or restrict the processing of your personal identifiable information. You also have the right to data portability.
You have also the right to object to the processing of your personal identifiable information if the processing of your personal identifiable information is based on the balance of interests. An objection to data processing only has future effect and may require that the contractual relationship between us be terminated – because we cannot fulfill our obligations to you without processing your personal identifiable information.
You may also at any time withdraw any consent given, with future effect.
Further, you may submit a complaint to the responsible data protection supervisory authority if you believe that we cannot sufficiently help you.
If you disagree with our processing of personal identifiable information you can lodge a complaint with the data protection authorities.
22 Cortlandt Street, 14th Floor
New York, NY 10007
For EU Users:
You may also contact our EU Local Representative via e-mail email@example.com