Last updated 26, June 2019

Effective 26. June 2019

Our Privacy Commitment

ZETTLO as a company respects your privacy rights and recognizes the importance of protecting your personal information. Our Privacy Notice describes the kinds of personal information we collect, why we collect it, how we share it, and choices we give you.

What does this Privacy Notice cover?

What personal information is collected about you?

How is your personal information used?

How is your personal information shared?

How long do we keep your personal information?

What choices do you have about processing your personal information?

What steps do we take to safeguard your personal information?

Product-specific data processing details

Information for individuals

How to contact us about your personal information and this Privacy Notice

1. What does this Privacy Notice cover?

Our Privacy Notice applies to the collection and processing of personal information by our company ZETTLO AS and our subsidiaries and affiliated companies acting on our behalf (collectively “Zettlo” or “we”, “us”, or “our”). This Privacy Notice applies only to personal information collected about you as a user and consumer through the ZETTLO network of websites (for example, zettlo.com), as well as apps, features, services, events, and communications provided by ZETTLO where this Privacy Notice is posted (“Services”).

Our international affiliates and third-party websites or apps that our Services link to, or with whom we may have a presence, or with whom we may license use of our trademarks and copyrights, may collect and use personal information for their own purposes. Where they do so, their respective privacy notices apply. Please review the respective terms and privacy notices of these entities to learn how they process your personal information. For example, Zettlo is developed under UNITY Inc. Please visit their website (website) for information about how they processes your data.

2. What personal information is collected about you?

We don't require personal information to use many of our Services. If you choose not to disclose personal information, however, you will not be able to enjoy certain features of our Services.

Information you provide to us

The types of personal information we collect directly from you include contact information, such as your first and last name, email address, telephone number, and postal address, as well as content you share or upload, such as photos (including any metadata included in your photos and content) and payment information (for example, credit card numbers or financial account information) if you purchase a product or service from us. We may also collect demographic information tied to your personal information, such as your age and/or date of birth, gender, country of residence, hobbies, and toy and game preferences.

Information we collect automatically

We automatically collect certain information when you use our Services. For example, we may collect device information, such as your device type, operating system type, browser type, device ID, and IP address. We may also collect usage data, such as what website you were on that brought you to our website, when you used our Services and for how long, what pages and content you accessed, and features you used on our Services. We may derive other information from the information we collect, such as your general location from your IP address. In addition, with your consent, the Services may access precise geolocation data on your mobile device to enable features and deliver content based on your current location. We may combine this device and usage information with other personal information.

Cookies and Tracking

Our websites use a variety of technical methods for collecting and tracking device information and usage data, including web beacons, cookies, local storage, and device IDs.

3. How is your personal information used?

We use your personal information to the extent reasonably necessary to fulfill your requests in performing our contract with you, or based on consent where we have requested it or where required by law, and for our legitimate business objectives, including to:

Provide you with and operate, maintain, optimize, and improve our products, services, operations, and the security of our Services

Personalize content and experiences on our Services, including providing you recommendations based on your preferences

Deliver and personalize your notifications, communications, newsletters, advertisements, offers, and promotions for products and services of Zettlo and our third-party partners

Develop information to understand you based on demographics, your activity on our Services, or activity on third-party websites and applications

Conduct market research and perform statistical, demographic, and marketing analyses of users of our Services and their purchasing patterns

Perform operational tasks such as billing, accounting, communicating, and fulfilling your transactions for products and services

Send and display administrative and marketing communications about Zettlo and our partners and our respective products and services

Detect, investigate, and prevent activities that are unauthorized, may violate our terms and policies, or may be illegal, such as fraudulent activity or security violations

For the purposes listed above, we may also link or combine information about you with other personal information we receive from third parties. We also use personal information in settings and for the purposes described below.

4. How is your personal information shared?

We do not share your personal information with third parties other than as follows:

With your consent; for example, when you agree to our sharing your information with other third parties for their own purposes, subject to their separate privacy policies

With third-party vendors, consultants, and other service providers who work for us and need to access your personal information to do that work

If you've selected options available through our Services to publicly display your name and/or username and your other information

If appropriate to (a) comply with laws or to respond to lawful requests and legal processes, including, for example, to comply with a court order or subpoena; (b) protect the rights and property of Zettlo, our agents, our customers, and others, including to enforce our terms, policies, rules, and agreements; (c) protect the safety and security of any person; and/or (d) protect the safety and security of Zettlo's and our partners' Services, websites, and applications

In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets for use in accordance with applicable law

5. How long do we keep your personal information?

ZETTLO keeps your personal information for as long as appropriate to maintain your accounts, to provide Services, to fulfill your requests, for legal compliance and enforcement purposes, and for resolving disputes. Actual retention periods depend on a variety of factors, such as the type of product, the type and sensitivity of the data, business needs, customer expectations and needs, the types of available user controls, and the form in which the data is stored.

6. What choices do you have about processing your personal information?

We provide you with various controls over your personal information, for example:

You can access and update the contact information you gave us during registration by visiting the “Edit Profile” section on www.zettlo.com or the “My Account” section on the app.

You can contact us at privacy@zettlo.com with requests to delete, access, and update your personal information.

7. What steps do we take to safeguard your personal information?

We implement technical, organizational, administrative, and physical security measures designed to protect your personal information from unauthorized access and improper use. However, please understand that despite our best efforts, no security measure is perfect or impenetrable.

8. Product-specific data processing details

The following are product-specific details to supplement the information in this Privacy Notice.

Zettlo challenges!

If you participate in the ZETTLO challenges, we will use personal information about you to track your results, player ranking, rating, and player status (e.g., active, terminated, winner, etc.). Except for those jurisdictions where privacy law specifies a different age, (a) if you are 13 or older, we will post your full name or first name and last initial (as you direct us), as well as your state and country with your player ranking; and (b) if you are under 13, your parent or guardian can choose to post your username, full name, or first name and last initial in the player rankings.

Also, if you participate in ZETTLO challenge, we will share your personal information with independent third parties who created challenges through our platform with the purpose of identification. In most cases, these are independent third parties and not ZETTLO employees.

ZETTLO APP

ZETTLO will keep your personal information within the ZETLO app for as long as you keep the app on your device. If you create an account, the app sends your personal information to our servers. We keep your data for as long as you maintain an account and for 90 days after you disable the account, in case you choose to reactivate the account or in case the request to disable the account was in error. We shall give you the option to receive push notifications. You can turn push notifications on or off through settings within the app or your device. You may disable our access to your precise geolocation data through settings in your device.

ZETTLO PAYMENT

If you provide information to create an account or as part of a transaction, payment, or other account action, Zettlo may deliver marketing communications to you about similar goods or services if you have not opted out of such marketing when given the chance to do so. We may also use third parties, such as Authorize.net and PayPal, to process payment transactions and facilitate fraud protection. PayPal and other third-party entities may use your information for their own purposes, including to service accounts you have with them. Please review their respective privacy notices to understand how they use your information.

9. Information for individuals

You have the following rights:

A right to be informed of the ways in which we use your information

A right to request from ZETTLO access to and rectification or erasure of personal information, and certain rights to data portability

A right to object to the processing of your personal information or obtain a restriction of such processing under certain circumstances

A right to have your personal data transferred to another organization should it be technically feasible for ZETTLO to do so.

If the processing of personal data is based on your consent, a right to withdraw consent at any time (without affecting the lawfulness of processing before its withdrawal)

There may be exceptions to these rights in certain circumstances, and where you cannot exercise a right due to an exception, we will provide that explanation.

10. How to contact us about your personal information and this Privacy Notice

If you have questions or comments about our data practices or this Privacy Notice, you can contact us on privacy@zettlo.com

11. How will you know if we amend this Privacy Notice?

We may amend this Privacy Notice at any time by changing the last updated date. If we make material changes to how we collect, use, or share your personal information, we will describe the changes, and, if required by law, seek your consent for such changes.