Privacy at Zogo

We are committed to protecting the security of your personal information and employ a comprehensive security program designed to safeguard your data. This includes encrypting all user data both at rest and in transit. Our systems reside within a secure, enterprise-grade cloud infrastructure with multiple layers of security controls. We regularly conduct security assessments and vulnerability testing to identify and mitigate potential weaknesses, and we undergo annual independent third-party assessments.

We continuously monitor our systems for security events and proactively review and update our security practices to address emerging threats. These measures include appropriate physical, technical, and administrative safeguards. While no security system is impenetrable, we are dedicated to maintaining the confidentiality, integrity, and availability of your personal information and continually strive to enhance our security program.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (in this Privacy Policy we refer to this as “personal information”). In particular, we have collected the following categories of personal information:

• Identifiers

  Examples: Name, username, email address, phone number, IP address

  Source(s): Directly from the user

  Purpose of Collection (including business purposes): Maintaining and servicing your account, providing customer service, processing rewards

• Demographic information

  Examples: Zip code, year of birth, survey responses

  Source(s): Directly from the user

  Purpose of Collection (including business purposes): Maintaining and servicing your account, providing customer service, processing rewards

• Protected classifications

  Examples: Age

  Source(s): Directly from the user

  Purpose of Collection (including business purposes): Maintaining and servicing your account, providing customer service, processing rewards

• Internet or network activity

  Examples: IP address, MAC address, operating system, IP address

  Source(s): Directly from App and analytics providers

  Purpose of Collection (including business purposes): Providing advertising or marketing services, for analytical purposes, calculating usage levels, diagnosing server problems

• Inferences

  Examples: User profiles to determine preferences, behaviors, characteristics, etc.

  Source(s): Directly from the user

  Purpose of Collection (including business purposes): Providing advertising or marketing services, for analytical purposes

We collect the following categories of sensitive personal information about you:

• Sensitive Personal Information

  Examples: Driver’s license, passport, non-driver ID card

  Source(s): Third party identity verification service

  Purpose of Collection (including business purposes): Verifying account belongs to a real person, for preventing rewards fraud

  Retention: 3 years (data is stored by third-party identify verification service)

We may share your personal information with third-party service providers who assist us with various aspects of our business, including: cloud infrastructure, marketing and customer relationship management, communications, analytics, internal operations, customer support, rewards programs, and identity verification.

We may also share your data with a partner sponsor institution, when directed by you for purposes of providing you with rewards for using our services.

Please reference the information listed in the “Information We Collect” section above for a list of personal information that we may share with third parties.

We may also disclose personal information for the following purposes:

• Fraud Prevention: We may disclose your personal information when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.
• Law enforcement or legal requests: We may disclose your personal information with government authorities, such as law enforcement authorities, courts, or regulators to comply with the law.
• Corporate Restructuring: We may transfer your information to a third party if we or any of our affiliates are involved in a corporate restructuring, including a sale, merger, or other transfer of some or all of our assets.

We, our service providers, and certain third parties use cookies, pixels, tags, or similar tracking technologies (“Collection Technologies”) to gather certain information when you use, access, or otherwise interact with our Services. Below we have described how we use Collection Technologies.

Our use of Collection Technologies generally falls into the following categories:

• Necessary/Essential Cookies

  Type: Session Cookies

  Administered by: Us

  Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Functionality Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

• Tracking and Performance Cookies

  Type: Persistent Cookies

  Administered by: Third-Parties

  Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

We keep your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, as may be required by law (e.g., for tax and accounting purposes), or as otherwise communicated to you. This is based on the nature of the data, why the data was collected and processed, and additional applicable legal retention requirements.

Depending on where you are located, you may have certain data privacy rights under law, which may be subject to limitations and/or restrictions. We believe in the inherent right to privacy and will endeavor to fulfill privacy rights requests even if you don’t have them available to you under law. The privacy rights that may be available to you are the following:

• The Right to Know and Access: You have the right to request that we disclose to you the categories of personal information we have collected, used, disclosed about you. You may also request a copy of the personal information we have collected about you.
• The Right to Deletion: 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.
• The Right to Correct: You have the right to request that we correct any inaccurate personal information that we have collected from you and maintain.
• The Right to Opt-Out: You have the right to opt out of targeted advertising. If you would like to opt out, please see the “Managing Your Cookie Preferences” section above.

Please see the “Exercising Your Privacy Rights” section below for details on how to submit a Right to Know and Access, Right to Deletion, and Right to Correct request.

We will not discriminate against you for exercising any of your privacy rights listed above.

Depending on where you are located and the applicable privacy laws, you may have the right to appeal our decision if we deny one of your requests listed above. Please see the “Exercising Your Privacy Rights” section listed below for details on how to submit this request.

We may revise or supplement this Privacy Policy from time to time on our website. If we make changes that materially affect our use of your personal information or your privacy rights, we will announce the changes by providing a notice to you through our website, application or via an email distribution.

This Privacy Policy provisions supersedes all previous notices or statements regarding our privacy practices and the terms and conditions that govern them in respect of privacy.

If you have questions regarding our Privacy Policy or your privacy rights as described above, please contact us at support@zogofinance.com