Effective as of September 7, 2022
Personal Information We Collect
Information You Give Us. It is our policy to only collect and use data from you that is required to use the Application. Personal information you may provide through the Application or otherwise communicate to us includes, but is not limited to:
Registration, Enrollment and Account Signup Information. In order to use the core functionality of the App, you will need to register for an account and enroll (register). In this process we will collect certain personal information including your first and last name, a username, phone number, email, gender, date of birth, and location. In addition, you will be asked to provide us with a digital scan of your government-issued ID (including name, issue date, expiration date, and address), a face scan and access to other authenticators available on your phone (e.g., fingerprint, face ID) to further authenticate your identity to ensure you are of legal age to purchase and consume products available from retailers on the App. We will ask for your consent prior to using any such authentication methods on the App.
Communications and Contact. We collect information about you when you provide contact and identity confirmation information to us via email, mail, or through the Application, including as a result of creating an account, signing up for communications, responding to surveys, requesting support or any other communications. This information may include your first and last name, email, phone number, photos, gender, date of birth, location and information related to the reason for contact.
Payment information. We collect information, provided by you, related to payment methods that could be used for purchases. This information may include your first and last name, credit card information (card number, expiration, CVV number) and zip code.
Information We Get from Others. We do not obtain additional information about you from third party sources.
We may use this information to gain a better understanding of the users of our Application, to improve our Application, and to improve our services. We may combine automatically collected information with your Personal Information. If we do so, we will treat the combined information as Personal Information under this Privacy Notice.
How We Use Your Personal Information
To Authenticate your Identification, Identity or Age
We collect a scan of your identification documentation and biometric data such as an image of your face and other information to authenticate your identity and age for the purpose of making purchases using the App.
Your face scan is compared to the image on your identification documentation to create a face template. This template is used at time of purchase to compare your face at that time to the template, thus authenticating your identify before each purchase.
Other information from your identification documentation (e.g., birthdate, expiration date, etc.) is collected and saved to use in the ongoing authentication process when making purchases through the App.
The App may use additional authenticators available on your phone for additional multi-factor authentication in conjunction with the face scan mentioned above. Your consent will be obtained prior using any such additional authenticators.
To Provide the Application and Communicate with You. We use your personal information (not including biometric data):
to provide, maintain and improve the Application, including its the content, layout and interface, and any related services provided to you or others;
to create and maintain your account;
to better understand your needs and interests, and personalize your experience with the Application;
to tailor and deliver targeted marketing information to you;
to respond to your requests, questions, comments, and feedback;
to perform analytics and database management services;
to compile personal information and other information collected through the App on an aggregated basis;
to develop new products and services; and
for other purposes as requested or communicated.
For Compliance, Fraud Prevention and Safety. We may use your personal information as we believe appropriate to:
investigate or prevent violation of the law or government regulations;
to comply with retailer rules and requirements;
protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims);
protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity;
comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and
where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our Application for illegal reasons.
With Your Consent. In some cases, we may ask for your consent to collect, use or share your personal information.
We reserve the right to license or sell aggregate, de-identified information collected from or about the users of our Application.
How We Share Your Personal Information
Biometric information such as face data will not be shared with retailers or third parties except during the authentication process.
We do not share your personal information with third parties without your consent, except in the following circumstances:
Service Providers. We may share your personal information with third-party companies and individuals as needed for them to provide us with services that help us with our business activities and to provide and promote our services to you. A list of our current service providers is available upon request.
Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy.
Other Important Privacy Information
Security. The security of your personal information is important to us. We take a number of organizational, administrative, technical and physical measures that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your personal information.
Retention. Personal information needed to ensure ongoing authentication capability or details related to purchases may be retained on a secure AWS server to provide the services on the App and in accordance with our retention policies. All biometric data, including face scan images and any related face templates, will be deleted from the platform if the App is not used within the previous 365 days. Any user will be required to re-enroll to use the App if they have not used the App within the previous 365 days.
Verifying, Changing, and Deleting Your Information. If you have registered and/or enrolled for an account through our Application, you may update your profile information and change your communication preferences by contacting us directly at email@example.com or through the re-enrollment or support functions of the App. You also have the right to be forgotten. Specifically, you can request that we deactivate and delete any account you have with us. A “Delete My Account” option is available in the menu of the App. Requesting this option will delete your account profile (including all of your personal and biometric information) and trigger the removal of all data that can be used to identify you from partner servers.
The Application is not intended for use by anyone under the age of 18 (and only those over 21 can use the App to buy items that require a minimum age of 21). We do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, you should not attempt to use the Application or send any information about yourself to us. If you are under 21, you should not attempt to use the Application to buy alcoholic beverages or any other products for which the legal age of purchase and/or consumption is 21. You should not attempt to use the Application to purchase products not permitted under applicable law.
Notification of Data Breach.
In the event of a data breach in which the user data collected from the App is compromised, we will notify you in accordance with applicable law.
How to Contact Us
Re: Zigit App Privacy
3145 E Chandler Blvd, Suite 110, PMB 335
Phoenix, AZ 85048-8702
United States of America
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date / Last Updated: September 7, 2022
'Personal Information' means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include information that is not subject to the CCPA, including de-identified data or aggregate consumer information.
Information We Collect
Our App collects, or anticipates collecting, information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). This could include items from the examples provided in the categories listed below.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A real name, address, telephone number, passport number, driver's license or state identification card number, credit card number, debit card number, or any other financial information,. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age, citizenship, gender expression, veteran or military status.
D. Commercial information.
Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Identifiers or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, or other physical patterns.
F. Internet or other similar network activity.
Browsing history, search history, information on a your interaction with our website, App, or advertisements.
G. Geolocation data.
Precise geolocation of your device when you grant us access to it.
H. Inferences drawn from other personal information.
Information generated from your use of the Platform (App and associated websites) reflecting your preferences
Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from information you provide, identification that you share or products you purchase.
Indirectly from you. For example, from observing your actions on our App.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
Account creation for access to the App;
To authenticate identification, identity or age
Storage of purchase information and App activity;
Responding to questions and feedback;
In-App communications via push notifications;
Providing the products you purchase on the App from our partners;
Reporting certain information to our partners;
Providing, maintaining, administering or expanding the App, performing business analyses, or for other internal purposes to support, improve or enhance our business, the App, and the products offered by our partners;
Notifying you about certain resources or services we think you may be interested in learning more about;
Aggregating information collected through the App on an aggregate basis; and
For such other purposes as you may authorize at the time you submit the information.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
Disclosure of Personal Information
We may disclose your personal information for a business purpose to our partners and third party technology service providers who provide hosting, database, network, and related services to support App operations. We may also disclose your personal information to:
Partner Portal Providers
Sales of Personal Information
Your Rights and Choices (Your California Privacy Rights)
As a California resident, you may be able to exercise the following rights (collectively, the 'California Privacy Rights') in relation to the Personal Information about you that we have collected (subject to certain legal limitations):
Note About Right to Access and Right to Delete Requests
We will need to verify your identity before processing any access or deletion requests, which may require us to request additional Personal Information from you or require you to log into your account. We will only use Personal Information that you provide in connection with a California Privacy Rights request to review and comply with your request.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
To exercise these rights, you may submit a request to us by submitting a “Data Rights Request” via our support screen in the App or to firstname.lastname@example.org.
Do Not Sell My Information / Right to Opt-Out
You have the right to opt out of sale of your personal information to a third party as defined by the CCPA. Please note that this does not stop us from distributing this information within our organization across business units. Additionally, your right to opt out does not stop all transfers to third parties as we can continue to provide your personal information to our service providers pursuant to a written contract that meets requirements within the CCPA. Furthermore, we can continue to provide data that does not meet the definition of personal information.
This right to opt out applies to all California consumers ages 16 or older and may be exercised at any time. We will honor all such requests unless you subsequently decide to opt in to the sale of your personal information.
The sale of personal information does not include if you direct us to interact with a third party, any third party alerts that you have opted out of, the sharing of information is necessary to perform a business purpose and meets the other conditions specified, or the information is transferred as part of an asset in a merger, acquisition, bankruptcy or other change of control event.
To exercise your right to opt-out, you may submit a request to us through the support section in the App or by sending a “Do Not Sell” request to email@example.com. Please note that the third parties to whom we sell Personal Information may use such information for their own purposes in accordance with their own privacy notices.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Your right to delete is subject to certain exceptions under the CCPA, including but not limited to exceptions for information necessary for us or our service provider(s) to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 etc.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided.
Regardless of exceptions that may require us to retain some personal information, if you request to “Delete your Account”, any stored biometric data will be immediately removed and any data related to purchases or transactions will be anonymized so that no trace to any individual can be made.
To exercise your right to delete your data, you may submit a request to us by selecting “Delete My Account” in the App menu or sending the request to firstname.lastname@example.org
Exercising Access, Data Portability, and Deletion Rights
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal 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 confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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 consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, 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 without hindrance.
We do not charge a fee to process or respond to your verifiable consumer 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 you with a cost estimate before completing your request.
The response for “Delete My Account” is completed as soon as it is sent and is fully complete through partners servers no later than 72 hours from the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your information described in this policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us:
By E-Mail (attn: Privacy Officer): email@example.com