Effective Date: March 21, 2022
1. CONTACT US
For the purposes of the General Data Protection Regulation 2016/679 (the “GDPR”) and other applicable laws globally, Zedge, Inc. is the entity responsible for your personal information (the “data controller”).
1178 Broadway, 3rd Floor, Suite #1450
New York, NY 10001
If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”), you may also contact our local representative in your jurisdiction via e-mail at email@example.com.
WHAT PERSONAL INFORMATION DO WE COLLECT?
When you use or access our Services or otherwise interact with us, we may collect a variety of information about you and others, as described below. Such information includes, but is not limited to, information about you which is in a form that permits us to identify you either on its own or in combination with other available information (your “personal information”).
A. Information you provide to us.
We obtain certain information when you provide it to us: for example, when you contact us about our Services, setup your account profile, access and use our Services, when you purchase virtual currency or products through our Services, report a problem, apply for a job with us, or communicate with us by phone, email, via third-party social media sites or otherwise. The types of information may include:
- Personal details, such as information that identiﬁes you or your personal characteristics, including your name, user ID, email address, phone number, contact details, your date of birth or photograph.
- Interests, such as your favorite music and television shows.
- Credentials, such as passwords, password hints or similar security information used for authentication and account access.
- Marketing data, such as your preferences in receiving marketing from us, or information about your use of our Services.
- Candidate data, such as employment history, qualifications, academic qualifications and education records, and any other information that you provide to us when applying for a job with us, for example in your curriculum vitae, a covering letter, on an application form or during an interview, or that we have received from a recruitment agency or background check provider.
B. User generated content.
You can use our Services 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 and Mobile Apps, or when searches are executed on the subject of your posting. Whenever you voluntarily disclose personal 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.
C. Information we collect automatically.
When you use or access our Services, we collect certain information about you, your use of our Service and your interactions with us and our advertising through automated means. This information may include (without limitation):
- Device information, such as your Internet Protocol (IP) address, unique device identifiers, bundle ID, device data (including manufacturer, make and model), anonymous IDs for advertising or created by third party social networks, operating system, carrier code (android only), carrier name, mobile carrier code, mobile network information, computer and connection information, browser type, existing applications, browsing activity, date and time, and non-precise or general device location information (e.g., city, region, country, language) or precise location (e.g. GPS coordinates or other location information). We also may collect any telephone number from which you contact us.
- Log data, including information associated with your activities on our Services, including information about the way you interact with our Services or any content or advertising thereon, statistics regarding your page views and traffic to and from our Services, and the number of bytes transferred, hyperlinks clicked, and other actions you take. Our Services may also track information such as the URL that you visited before you come to the Services and the URL to which you next go. When you download one of our Mobile Apps and/or register with Zedge, we also create identifiers which are unique to you. These identifiers are randomly generated and may be reset when you upgrade or reset your device.
D. Cookies and similar technologies.
E. Information we collect from other sources.
Third-Party Accounts. You can sign up and log in to the Services using accounts you create with third-party products and services, such as Facebook, Google, or Apple (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information (including profile picture) and preferences. This information is collected by the Third-Party Account provider and is provided to Zedge under their privacy policies. You can generally control the information that we receive from these sources using the privacy controls in your Third-Party Account.
- security service providers who provide us with information to secure our systems, prevent fraud and help us protect the security of our Services;
- online and offline data providers, from which we obtain aggregated demographic, interest based and online advertising related data; and
- publicly available sources such as publicly available databases and social media platforms.
HOW DO WE USE PERSONAL INFORMATION?
We will use your personal information for the following purposes as is necessary for the performance of our obligations under our contract with you, or to answer questions or take steps at your request prior to entering a contract with you:
- to process your registration, order, payment or to otherwise facilitate your use of the Websites or Mobile Apps;
- to provide you with the Services, manage your account and provide you with customer support;
- to send technical alerts, updates, security notifications, and administrative communications;
- to verify your identity, investigate and prevent fraudulent activities, unauthorized access to our Services, and other illegal activities;
- to manage registration, payments and your attendance to our events; and
We use your personal information for the following purposes as is necessary for certain legitimate interests, or where you have given your consent to such processing to the extent required by applicable law (such consent can be withdrawn at any time):
- to analyze how the Services are being used;
- to help tailor content and advertising across the Services;
- to recognize patterns and trends in usage, and better design the Services to improve user experience, both in terms of content and ease of use and information broadcasting through in-app notifications, push-notifications or campaigns through external services;
- to provide you offers and recommendations and to tailor and enhance your experience on the Websites or in the Mobile Apps;
- to provide enhanced location-based Services as well as to serve location-targeted advertising, which includes communication to third party service 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;
- to notify you of any new or changed Services and to communicate with you about products or services that may be of interest to you;
- to confirm, update and improve our records, and to analyze and develop our relationship with you;
- to deal with enquiries and complaints made by or about you relating to the Services;
- to seek your views or comments on the Services;
- to carry out training relating to our Services;
- for internal administrative and technical operations to maintain the security of the Services and to keep our network and information systems updated, patched and secure;
- to monitor compliance with the rules governing the Services;
- to request that you complete surveys and/or research questionnaires related to current or future services that we may offer; and
- to (i) comply with legal obligations; (ii) respond to requests from competent authorities; (iii) protect our interests; (iv) protect our rights, safety or property, and/or that of our partners, you or others; and (v) enforce or defend our legal rights.
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.
If you apply to work for Zedge, we will use your personal information in the following ways as necessary in our legitimate interests, or where you have given your consent to such processing to the extent required by applicable law (such consent can be withdrawn at any time, subject to restrictions permitted by such law) and to decide whether to enter into a contract with you:
- to assess your skills, qualifications, and suitability for the role you have applied for;
- to carry out background and reference checks, where applicable;
- to communicate with you about the recruitment process;
- to keep records related to our hiring processes; and
- to comply with legal or regulatory requirements.
4. WHEN DO WE SHARE PERSONAL INFORMATION?
- Our affiliated companies and offices.
- Our professional advisors. Including our auditors, accountants, lawyers, consultants, and IT forensic specialists.
- Trusted third-party service providers. Including those providers who perform services on our behalf in connection with our Services. The services provided by such third parties include services in the following categories: processing payments on our behalf, sending marketing communications on our behalf, authenticating identities on our behalf, helping us to create or maintain our databases, helping us to research or analyze data relating to visitors to our Services and maintaining the security of our cloud-hosting services, backend support services, data analysis and visualization support services, insurance services, and commissioned mailing house services.
- Another legal entity. On a temporary or permanent basis, as required for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution or similar event.
Fraud and threat protection. Zedge may disclose your personal information to public authorities and other third parties like lawyers, consultants, or IT forensic specialists when obligated or permitted to do so by law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, and to protect our rights, 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. Except to the extent prohibited by applicable law, we reserve the right to disclose information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate, to protect our Services, to comply with legal obligations or carry out tasks in the public interest.
We may share aggregated or anonymous information that cannot identify you with third parties, including but not limited to advisors, advertisers, analytics providers, and investors, for the purpose of conducting business and improving the Services.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
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 with respect to personal information submitted online. We cannot guarantee that only authorized persons will view your information transferred over the Internet. We are not responsible for third party circumvention of any privacy settings or security measures.
6. STORAGE OF PERSONAL INFORMATION
We will store your personal information in a form which permits your identification for no longer than is necessary for the purpose for which such personal information is processed. Please note, however, that we may retain and use your personal information as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements and rights, or if it is not technically and/or reasonably feasible to remove it. Consistent with these requirements, and to the extent required or permitted (as the case may be) by applicable law, we will try to delete your personal information quickly upon request.
We do not knowingly collect or store personal information from anyone under the age of 13, or such higher age as required by applicable law, unless or except as permitted by applicable law. ANY PERSON WHO VISITS ANY OF THE WEBSITES OR USES ANY OF THE MOBILE APPS REPRESENTS TO US THAT THEY ARE 13 YEARS OF AGE OR OLDER OR SUCH HIGHER AGE AS REQUIRED BY APPLICABLE LAW AND HAS READ AND WILL ADHERE TO OUR ONLINE SAFETY AND BEST PRACTICES GUIDELINES. If we are made aware that we have received personal information from someone under 13, or such higher age as required by applicable law, Zedge will use reasonable efforts to remove that information from our records.
9. TRANSFERS OF PERSONAL INFORMATION
The information collected by Zedge is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Services from other jurisdictions, please be advised that you are transferring your personal information to us in the U.S. where data protection and privacy laws may be less stringent than the laws of your country.
If you have any inquiries about our handling of your personal information or would like to obtain a copy of the respective data transfer tool, please contact us at firstname.lastname@example.org.
10. THIRD PARTY ADVERTISERS - YOUR AD CHOICES
All data that third-party advertising companies collect is tied to your Android Advertising ID. You can find information on how to edit your ad preferences based on your Google Account settings here.
iPhone users can find information on how to opt-out of receiving targeted ads here.
You can also manage your ad and content preferences within the settings section of our Mobile Apps.
We do not respond to web browser "do not track" signals or other similar mechanisms.
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.
11. ACCESS AND CHANGES TO PERSONAL INFORMATION; ACCOUNT TERMINATION
You can access a copy of the personal information we hold about you, subject to certain exemptions in accordance with applicable data protection law. You can exercise this right at any time by selecting “Request Zedge data” within the settings section of our Mobile Apps or by contacting us at email@example.com and including “personal information request” in the subject line.
In addition, you may at any time delete your personal information by going to your account settings. Upon your request via your account settings, we will deactivate or delete your account and personal 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 your information on our servers even after you've deleted your account.
12. EUROPEAN AND UK RESIDENTS
If you are based in the EEA or the United Kingdom, in certain circumstances you have rights under data protection laws in relation to your personal information that we hold about you—specifically:
- Request access to your personal information. You may have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.
- Request correction of your personal information. You may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you.
- Request erasure of your personal information. You may have the right to request that personal information held about you be deleted.
- Request restriction of processing your personal information. You may have the right to prevent or restrict processing of your personal information.
- Request transfer of your personal information. You may have the right to request transfer of your personal information directly to a third party where this is technically feasible.
13. CALIFORNIA RESIDENTS
Your California Privacy Rights
California residents with an established business relationship with us are permitted by California law once a year to request information about the way we shared certain categories of information with others for their marketing purposes during the prior calendar year.
We may share your personal information with others for their marketing use unless you tell us not to. To opt-out, please update your ad and content preferences within the settings section of our Mobile Apps, email us at firstname.lastname@example.org, or call us on 1 844 219 5326. We will not share your information after we have received and processed your opt-out request.
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Verified California residents have the right to:
- request and receive disclosure of our information collection practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information;
- request and receive disclosure of our information sharing practices during the prior 12 months, including a list of the categories of personal information sold with the category of third-party recipients and a list of the categories of personal information that we disclosed for a business purpose;
- request and receive a copy of the specific personal information we have collected about them during the prior 12 months;
- request that we not sell personal information about them; and
- request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.
For purposes of the CCPA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
The CCPA rights described above do not apply to information collected in the employment context about our current, former or prospective employees or contractors (who receive separate disclosures under the CCPA) or to information collected about California business contacts (employees, owners, directors, officers, or contractors of companies, sole proprietorships, and other entities collected in the context of conducting due diligence regarding, or providing or receiving a product or service to or from, such companies, sole proprietorships, or entities). California business contacts have the right to tell us not to sell their information; please see below for how to exercise this right.
Information collected, sources, and business purpose for collecting information. During the past 12 months we may have collected the following categories of personal information. This includes information that individuals provide to us directly, information we collect automatically through the website, information that we collect when individuals interact with us such as through online postings, and information that we may collect from third parties such as service providers, affiliated companies, marketing, staffing, or data partners, or other third parties. It also includes information that we collect about employees and business partners and vendors from those individuals directly or from references, referrals, or consumer reporting agencies. Not all information is collected from everyone who interacts with us. Information we collect is used for the business purposes described above in section 3 “HOW DO WE USE PERSONAL INFORMATION?”.
- Identifiers such as contact information (name, address, phone number, email or postal address), unique personal identifiers (that may include but are not limited to a legal name or preferred alias and online identifiers like user account names), and an encrypted version of your password. We may collect additional information from suppliers, vendors, or employees including business contact information, phone number, email and postal addresses and titles.
- Sensitive information such as financial and payment information like credit or debit card information, or payment information received from a third party payment provider such as Google Play or App Store (Apple).
- Commercial information such as transaction histories, billing and shipping information, and product preferences.
- Inferences we make about individuals or their interests based on analysis of other information we have collected.
- Geolocation information.
- Audio or video information such as call center recordings or monitoring records from our customer support centers and security video recordings at our facilities.
- Employment, education and professional related information, protected classification information, biometrics (collected from current and prospective employees, contractors, service providers, vendors and suppliers).
- Other types of personal information that we may disclose to you prior to the point of first collection.
Exercising your CCPA rights. To make a request for disclosure, California residents may select “Request Zedge data” within the settings section of our Mobile Apps, or contact us by calling us at 1 844 219 5326 or emailing us at email@example.com. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 business days. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
You may make a request for disclosure of our information collection practices, the specific information we collected about you, or our information sharing practices up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time.
For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.
We will not discriminate against you as a result of your exercise of any of these rights.
Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (i) the person is registered with the Secretary of State to do business in California; (ii) you provide the authorized agent with signed written permission to make a request; (iii) you verify directly with us that you have authorize the person to make the request on your behalf; (iv) you verify your own identity directly with us; and (v) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
Personal information sales opt-out and opt-in rights. We do not sell your information for monetary consideration, but we may transfer your information to a third party that provides us with services such as helping us with advertising, data analysis and security, which may fall under the definition of for “other valuable consideration” which may be considered a ‘sale’ under the CCPA. During the past 12 months we disclosed identifiers, electronic network activity, geolocation, and inferences from such collected information with third parties such as advertising and analytics providers and those third parties listed in section 9 (TRANSFERS OF PERSONAL INFORMATION) above, for a business purpose which falls within the definition of a ‘sale’. If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of individuals we know are less than 16 years of age. To exercise the right to opt-out, you (or your authorized representative) may update your ad and content preferences within the settings section of our Mobile Apps, email us at firstname.lastname@example.org, or call us on 1 844 219 5326. Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sales.
14. NEVADA RESIDENTS
We may transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future please email us at email@example.com with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.