Privacy Policy

This is the Privacy Policy for any application or web service (collectively the “App”) owned by growth lbs ltd. (“our”, “we”, or “Zeal”).Company registration number: 12836993Registered office address: 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQZeal is the controller of your personal data collected through the App.We are committed to protecting and respecting your privacy.

1. Introduction

This Privacy Policy explains why and how we process personal data collected through your use of the App and the rights you have with regard to your personal data.When you give any personal data to us we must collect the information fairly and explain to you how we will use it.It is important that you read this Privacy Policy so that you are fully aware of how and why we are using that data.This Privacy Policy supplements other notices and legal documents including the Zeal Terms of Use and is not intended to override or replace them.By downloading our App, you agree to this Privacy Policy. If, for any reason, you do not agree to the terms of this Privacy Policy, please stop using the App.We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. It is your responsibility to check this Privacy Policy before each use of the App.The App is not intended for anyone under the age of 18 and we do not knowingly collect data relating to children. If you believe we have collected personal information about your child, you may contact us at legal@zeal.app and request that we remove information about them.

2. What information we collect

What is personal data?

Where this Privacy Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth and even your IP address.

How and what types of data we collect from you when you use the App

When you use the App or report a problem with the App, we may collect, store and use certain personal information that you share with us.The information we collect from you may include (but is not limited to): your IP address, written feedback and log-in information.We shall also collect information about you when you visit and interact with the App through the use of technologies such as cookies. The following are examples of information we may collect:

  • information about your device, browser or operating system;

  • time zone setting;

  • your IP address;

  • information about interactions you have with the App (such as scrolling and clicks);

  • information about the way you use and the actions you take within the App;

  • length of time on the App and time spent within certain sections;

  • response times; and

  • errors or issues with the app.

We may also partner with third parties who may collect anonymous usage or statistical data through your use of the App (including, for example, sub-contractors in technical, payment and/or delivery services, business partners, advertising networks, analytics providers).Updating your informationIf you want to update the information you have previously given to us, you can contact us at legal@zeal.app.

3. How and why we use/share your information

Lawful basis for processing your information

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:

  • Where you have asked us to do so, or consented to us doing so;

  • Where we need to do so in order to perform a contract we have entered into with you;

  • Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and

  • Where we need to comply with the law or regulation

Marketing

You may receive marketing messages from us if you have given us your consent to do so or if you have provided feedback on our App and have not opted out of receiving marketing messages.To unsubscribe from marketing emails, please click on the unsubscribe link at the bottom of any marketing email at any time.

Sharing your information

Depending on how and why you provide us with your personal data, we may share it in the following ways:

  • with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; or

  • with analytics that assist us in the improvement and optimisation of the App.

We may also disclose your personal information to third parties in the following events:

  • if we were to sell or buy any business or assets, in which case we might disclose your personal information to the prospective seller or buyer of such business or assets;

  • if Zeal or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets; or

  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply the EULA; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will try not to share personal data with our service providers and if they need it to fulfil their services only the minimum amount of needed data will be shared.At present Amazon Web Services, Amplitude, and Sentry are trusted third party service providers of ours.

App Store Provider use of Data

During your use of the App, your app store provider may also collect personal information about you regarding your use of the App such as your identity, your usage and location.These third parties shall act as separate and independent controllers of that personal data and shall process it in accordance with their own privacy policy.

Links to third party sites

The App may contain links to and from the websites of our partner networks, advertisers and affiliates. We may also provide links to third party websites that are not affiliated with the App. All third party websites are out of our control and are not covered by this Privacy Policy, but rather their own privacy policies. If you access third party sites using the links provided, the operators of these sites may collect information from you that could be used by them, in accordance with their own privacy policies.

4. How long we keep your information

We will hold your personal information on our systems only for as long as required to provide you with the products and services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.In some circumstances you can ask us to delete your data.In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

5. Security

The security of your personal data is very important to us. We have put in place appropriate physical, electronic and managerial security measures to prevent your personal data from being lost, used or accessed in an unauthorised way, altered or disclosed. including use of secure servers, passwords and industry standard encryption for data both in transit and at rest.In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

6. International Data Transfers

Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your request for information, products and services, the processing of your payment details and the provision of support services.Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. Transfers of personal data are either made:

  • to a country recognised by the European Commission as providing an adequate level of protection; or

  • to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

By submitting your personal information, you agree to this transfer, storing or processing. If you would like more information about the mechanism by which your personal data is transferred please contact legal@zeal.app

7. Your Rights

Below, we have described the various rights that you have as well as how you can exercise them.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to yo to check that it is correct and to ensure that we are processing that personal data lawfully.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate.You may also ask us to erase personal data that we control if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”). There may be legal requirements to keep certain personal data or technical limitations to the data we can delete. For example, we are not able to erase records on the blockchain like your transaction history and your account balance.There may also be legitimate interests in keeping certain data including, amongst others, if the data is required for the App to function. If this is the case we will continue to process this data.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

Your Right to Portability

You may write to us and ask us to provide to you personal data we hold about you in a commonly used machine-readable format.

Your Right to object to processing

You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

Your Right to stop receiving communications

You may ask us to stop sending you various kinds of communications.

Your Right to object to automated decision making and profiling

You can ask us about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the effects that such processing has on you.

Withdrawal of consent

Where we are relying on consent to process your personal data you may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

8. Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at legal@zeal.appYou also have the right to lodge a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).We would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

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