Effective Date: July 27, 2021
Last Updated: July 27, 2021
Apps That Pay, LLC doing business as Zap Surveys (“Zap Surveys”, “we”, “us” or “our”) is committed to protecting your (“you” or “your”) privacy and empowering you with this privacy policy (this “Privacy Policy”). This Privacy Policy explains how we collect, use, disclose, and apply the information collected when you use our website (https://www.zapsurveys.com) or use any of the other services that we may make available to you (collectively, “Services”). As applicable to you, our Survey Creator Terms of Services, our Publisher Terms of Service, and our Survey Taker Terms of Service (collectively, the “Terms”) are expressly incorporated herein by reference and are an integral part hereof. The Terms can be found here: https://www.zapsurveys.com/terms-of-service.html.
By using the Services, or interacting with us, you are agreeing to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, do not access or use the Services. Please read the following carefully to understand how we collect, use, and maintain your personal information. In addition, it describes your choices for use, access, and correction of your personal information.
1. Changes to this Privacy Policy. We may change this Privacy Policy, in our sole discretion in accordance with applicable law, from time to time. In the event we make changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy. If there are significant changes to this Privacy Policy, we will attempt to notify you directly by email or provide information via our home page prior to any such changes becoming effective. We encourage you to review our Privacy Policy whenever you use the Services to stay informed of ways you can protect your privacy.
2. Information We Collect and Receive. We collect information to deliver the Services you request, to help improve your experience, and to support our business functions. We collect information from you in a variety of ways when you interact with the Services. More information about the categories and sources of information is provided below.
2.1 Information You Provided to Us. We collect information that you decide to share with us. At times, we may require you to provide certain information in order to use certain parts of our Site, fulfill your requests, or provide you with certain Services.
2.1.1 Registering for an Account. If you establish an account with us, we may require you to provide your name, email address, gender, zip code, relationship status, employment status, income, race and ethnicity, birthday, and a password to create your account. We may also ask if you are registered to vote, the number of people who live with you, the approximate revenue of your organizations, industries those in your household work in, who in your household makes certain decisions, and the highest level of education you have complete.
2.1.2 Survey Information. When you participate in a survey, we may collect the information that you submit in a survey and in connection with the receipt and redemption of rewards and incentives.
2.1.3 Content Information. You also may choose to send us personal information in an email containing inquiries about the Services and we use this information in order to help us respond to your inquiry. You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, or (iv) in connection with an actual or potential business relationship with us.
2.2 Information We Obtain from Others. We may obtain information about you from third parties who help us provide our Services, publicly available information systems, and commercial information services. We may also obtain some information from our marketing partners in order to inform you about products, new surveys, or Services that we think you might be interested in. Finally, we may obtain information that does not identify you directly, but which is later used in a way that may later directly identify you. We may combine that general information with your information to provide related services to you.
2.3 Information We Automatically Collect. We automatically collect certain information from you when you use the Services, including internet or other network activity information (as described below), unique device identifiers, browsing and search history (including content you have viewed in the Services), and cookies and other technologies (as defined in Section 3). Information collected automatically includes:
2.3.1 Device information. We collect technical information when you visit our Services. This includes information such as the type of device or browser you use, your device’s operating system, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id. When you visit and interact with the Services, we may collect certain information automatically through cookies or other technologies, including, but not limited to, the type of computer or mobile device you use, your mobile device’s unique device ID, the IP address of your computer or mobile device, your operating system, the type(s) of internet browser(s) you use, and information about the way you use the Services.
2.3.2 Usage Information. We collect information regarding your use of the Services including data about features you use, pages you visit, emails and advertisements you view, portions of the Services that you view and interact with, the time of day you browse, and your referring and exiting pages.
2.3.3 Crash and Error Information. If any of the Services crash or return an error, we may collect data to determine the cause of the error. The crash or error information collected may include the following: IP address, device name, operating system version, application configurations(s), the time and date, and other statistics.
2.3.4 Location Information. We offer location based rewards. If you grant us access to your location, Zap Surveys may collect information about your location when you use our Services. Your location can be determined by: IP address, and information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. The specificity of the location data collected may depend on a number of factors, including the device you are using (e.g. laptop, smartphone or tablet) and how you are connected to the Internet (e.g., via cable broadband connection, Wi-Fi).
3. Cookies and Other Technologies. Like many other websites, our Services may use “Cookies” or “Other Technologies” (such as “pixel tags”, “web beacons”, “clear GIFs”, links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies) to collect information and support certain features of our Services. Cookies and Other Technologies allow us and third parties to obtain information about your visits to our Services, including analyzing your visiting patterns. Although you are not required to accept Cookies when you visit our Services, you may be unable to use all of the functionality of our Services if your browser restricts our Cookies. We use this information to process your requests and to deliver online and mobile advertisements, messages and content for us and others that are specific to your interests. The information we collect from your web browser and from Cookies and Other Technologies does not identify you personally but in some cases, we may link it to personally identifiable information.
3.1 Cookies. Below, we explain the different types of Cookies that may be used on the Services.
3.1.1 Necessary Cookies. Necessary Cookies are essential to enable your use of the Services and to identify and prevent security risks, such as storing your session information to prevent others from changing your password without your username and password.
3.1.2 Preference Cookies. We use these Cookies to remember your settings and preferences and to improve your experience on our Services. For example, we may use these Cookies to remember your language preferences.
3.1.3 Session Cookies. These types of Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser. We use session Cookies to support the functionality of the Services and to understand your use of the Services—that is, which pages you visit, which links you use, and how long you stay on each page.
3.1.4 Statistics Cookies. Statistics Cookies help collect information about your use of the Services and enable us to improve the way it works. These Cookies give us aggregated information that we use to monitor the Services’s performance, count page visits, spot technical errors, see how users reach the Services, and measure the effectiveness of marketing (including emails).
3.1.5 Marketing Cookies. Marketing Cookies are used to show users display advertisements across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. We do not display ads for any services besides our own.
3.1.6 Unclassified Cookies. Unclassified Cookies are Cookies that we are in the process of classifying, together with the providers of individual Cookies.
3.2 Other Technologies. In addition to Cookies, we may use Other Technologies, like pixel tags (also known as web beacons and clear GIFs), to, among other things, track the actions of users of the Services (about usage including email recipients), measure the success of our marketing campaigns, and compile statistics of the Services and response rates.
4. How We Use Your Information.
(a) We may use the information collected for the limited purpose of providing the Services and related functionality and services, as described in the Terms and in this Privacy Policy, and as permitted by applicable laws. These limited purposes include circumstances where it is necessary to provide or fulfill the Services requested by or for you or where you have given us your express consent. We may use the information we obtain about you to:
(i) Provide the information, products, and Services you request;
(ii) Service your account and provide you, if you are a registered user, with effective customer service;
(iii) Better understand your needs and interests, and provide you with a personalized experience when you use our Services;
(iv) Contact you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
(v) Contact you with information and notices related to your use of our Services, including our Services;
(vi) Invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);
(vii) Improve our products and Services and develop new products and Services, improve our marketing and promotional efforts, and improve the content, functionality, and usability of the Services;
(viii) Enforce our Terms;
(ix) Promote security and protect against and prevent fraud, claims, and other liabilities;
(x) Verify the information you provide to us as well as the representations and warranties you make to us in the Terms or on the Services;
(xi) Meet our internal and external audit obligations;
(xii) Tailor survey opportunities to you and notify you of these opportunities;
(xiii) Administer and manage our reward and incentive programs and fulfill your requests for rewards and incentives; and
(xiv) Use for any other purpose for which we provide notice at the time of collection.
(b) We may aggregate and/or de-identify information collected through the Services and from other sources so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including, without limitation, for research and marketing purposes
5. How We Share and Disclose Information.
5.1 We Do Not Sell Personal Information. We do not sell or otherwise disclose personal information we collect about you, except as described herein or otherwise disclosed to you at the time the data is collected. We share information to perform activities that you request.
5.2 Sharing Information with Third Parties.. We disclose your Personal Information to the following categories of third parties:
· Our affiliates
· Service providers and other third parties, with whom we have a contractual, to support our business including without limitation those providing data append services, data validation services, fraud detection and/or prevention services, database-matching services, coding services, data segmentation services, and reward, and incentive related services, as well as market research partners that provide surveys;
· Commercial providers;
· Enterprise accounts, such as your employer;
· Third parties to whom you or your agents authorize us to disclose your Personal Data in connection with the services we provide to you
5.3 Your Consent. We may share information for other purposes pursuant to your consent or with your further direction.
5.4 Aggregate/De-Identified Data. We may share Aggregate/De-Identified Information with any third parties, including advertisers, promotional partners, business and channel partners, sponsors, and/or others.
5.5 Legal Reasons. We may also disclose information about you when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose information about you to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Services; to enforce or apply our Terms or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others. We will attempt to notify our users about legal demands for their personal information when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority.
5.6 Sale, Merger, or Other Business Transfer. We also reserve the right to transfer information about you to a successor organization if we transfer the ownership or operation of one of our websites to another organization or if we merge with another organization. If such a transfer occurs, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
6. Your Choices.
(a) You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you choose to visit our website and use our Services, we aim to provide you with choices about how we use your Personal Information. If we have collected your Personal Information because you visited our website or contacted us, then we will facilitate your rights directly because we are the controller of your Personal Information. If we have collected your Personal Information on behalf of a customer when you have been employed by that customer, your rights are facilitated by the customer because they are the controller of your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.
You can manage Cookies through your web browser. Most browsers will tell you how to stop accepting new Cookies, how to be notified when you receive a new Cookie, and how to disable existing Cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org. Please note, however, that without Cookies you may not be able to take full advantage of all our website features. In addition to the browser-based controls, you can manage third party Cookies by visiting www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice. Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
(b) If you have registered for an account, you may access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities.
(c) You have a choice at any time to stop us from sending you emails for marketing purposes by adjusting your settings in your account settings. You also have the option to opt out of receiving certain other emails from us by adjusting your settings in your account settings. You can also opt out of commercial email messages by following the “unsubscribe” link included in these messages. Please note that despite any indicated email marketing preferences, we may continue to send you administrative emails regarding inBrain, including, for example, notices of updates to our Terms or this Privacy Policy, notifications of new survey opportunities, if we choose to provide such notices to you in this manner.
(d) Some browsers offer a “do not track” (“DNT”) option. Since no common industry or legal standard for DNT has been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
7. European Residents. If you are a resident of the European Economic Area, you have certain rights regarding the personal information we maintain about you. We offer you certain choices about what personal information we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the “Contact Us” section below:
7.1 Information and Access. You can request to see which personal information we process from you. We can inform you on how and why we process this data unless restricted by law, or if we are unable to verify your identify.
7.2 Submitting information. You may refrain from submitting information directly to us, although doing so may impact our ability to provide the services, and information you request and/or affect your ability to use the Services.
7.3 Rectification. You may request to update or correct the personal information we maintain for you.
7.4 Right to be forgotten/request deletion. You may request deletion of your personal information. We may ask you for additional information to verify your identity and will process your request subject to and in accordance with the law.
7.5 Restriction. You may request the limitation on the processing of your personal information.
7.6 Restricting cookies. You may elect not to have a unique cookie identification number assigned to your computer to avoid aggregation and analysis of data collected on our websites. Generally, if you do not wish to receive cookies, you may set your browser to deny cookies or to alert you when a cookie is placed on your computer.
7.7 Objection. You may remove your consent for the processing of your personal information.
7.8 Transferability. You may request to transfer your personal information.
7.9 The right to refuse to be subjected to automated decision making, including profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
7.10 The right to lodge a complaint with a supervisory authority.
8. California Residents.
(a) If you are a resident of the State of California, you have certain rights afforded to you under the California Consumer Privacy Act or the “CCPA”. When we say “Personal Information” in this section, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you.
(b) During the last twelve (12) months, we have collected the following categories of personal information from California consumers.
|
Category |
Type of Identifiers We Collect |
Collected |
|
A. Identifiers. |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
YES |
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories. |
YES |
|
C. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
YES |
|
D. Internet or other similar network activity. |
Browsing history, search history, information on a consumer’s interaction with a website, application logs, device data and registration, social media account information or advertisement. |
YES |
|
E. Geolocation Data |
Physical location or movements |
YES |
|
F. Professional or employment-related information. |
Current or past job history, professional memberships, employee reference checks, and trade union membership |
YES |
|
G. Inferences drawn from other personal information. |
Profile reflecting a person’s preferences, behavior, and attitudes. |
YES |
We obtain the categories of Personal Information listed above from the following categories of sources:
· Directly from our customers or their agents.
· Indirectly from our customers or their agents. For example, through information we collect from our clients in the course of providing Services to them.
· Directly and indirectly from activity on our website (www.inbrain.ai). For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
· From third parties that assist us in providing certain transactions and services, even though it appears that you may not have left our Site.
We do not sell (as such term is defined in the CCPA) the Personal Information we collect (and will not sell it without providing a right to opt out).
(c) Subject to certain limitations, the CCPA provides California residents the following rights:
(i) You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;
(ii) You have the right to request that we delete your Personal Information that we have collected from you;
(iii) You have the right to request that we no longer sell your Personal Information to third parties;
(iv) We will not discriminate against you for exercising any of these rights.
(d) California residents may make a request pursuant to their “right to know”, “right to request deletion”, and/or “right to opt-out” under the CCPA by contacting us in accordance with the “Contact Us” section below. In order to verify your request to know or delete information, we may require you to provide us with certain information to be used solely for the purpose of verifying your identity.
(e) Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
9. Information Retention. We may retain your Personal Information for a period of time consistent with the original purpose for collection. For example, we keep your Personal Information for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
10. Data Processing and Data Transfers. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have different privacy laws from your country of residence. Whenever we share information of European Union users outside the European Union, we make sure an adequate transfer mechanism is in place.
11. Security. We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction, or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process, and store and the current state of technology. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.
12. Links to Third-Party Websites. The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website, or the privacy practices of the operator of the website.
One of the third parties that we work with to provide you with location based opportunities is inMarket and you can find their Privacy Policy here and can opt out here.
13. Children’s Privacy. The Services are directed to individuals over the age of thirteen (16). We do not knowingly collect personal information from individuals under the age of thirteen (16) (“Children”). If we become aware of any Children who have provided us with personal information, we will take steps to deactivate their account and delete the personal information. If you become aware of information from Children, which has been provided to us, please contact us in accordance with the “Contact Us” section below.
14. Contact Us. If you have any questions or concerns about our Privacy Policy, please contact us via email at support@zapsurveys.com.
