Privacy & Cookie Policy

Important information and who we are

• Purpose of this Privacy Policy

  • This privacy policy aims to give you information on how Zappi collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletters or mailing list, purchase or indicate interest our products or services.

  • This website is not intended for children and we do not knowingly collect data relating to children.

  • It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.

• Controller

  • ZappiStore Limited, ZappiStore Inc. and affiliated companies are the controllers and responsible for your personal data (collectively referred to as "Zappi", "we", "us" or "our" in this privacy policy).

  • We have appointed a Head of Information Security and Data Compliance who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data privacy team using the details set out below.

• Processor

  • Please note that in some cases Zappi may carry out the activities referred to in this Policy in our capacity as a data processor acting on behalf of our clients.

• Contact Details

  • Our full details are:

    1. Full name of legal entity: ZappiStore Limited

    2. Email address: data-privacy@zappistore.com

    3. Postal address: Theatre House, 97 – 99 Camden High Street, London, NW1 7JN, United Kingdom

  • You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

• Changes to the Privacy Policy and your duty to inform us of changes

  • This version was last updated in April 2023 and historic versions can be obtained by contacting us.

  • It is important that the personal data we hold about you is accurate and current. If applicable, please keep us informed if your personal data changes during your relationship with us.

• Third-party links

  • This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

• Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

• We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier, employment data, title, date of birth and gender.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

  • Usage Data includes information about how you use our website, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, information about how you use a feature may be collected and combined with information about how others use the same feature, without personal information included in the resulting data. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

• We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

• If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

• We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;

  • create an account on our website;

  • subscribe to our service or publications;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey; or

  • give us some feedback.

• Automated technologies or interactions.

  • As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

  1. Technical Data from the following parties:

     • analytics providers such as Google based outside the EU;

     • user behaviour analytics systems such as FullStory, or Drift based outside of the EU/UK.

  2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services;

  3. Identity and Contact Data from data brokers or aggregators such as Drift or LinkedIn based outside of the EU/UK;

  4. Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU/UK.

How we use your personal data

• 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 we need to perform the contract, we are about to enter into or have entered into with you.

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

  • Where we need to comply with a legal or regulatory obligation.

• Please note that where Zappi undertakes processing on behalf of our clients as a data processor we do not require the legal basis mentioned above for such processing.

• Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at data-privacy@zappistore.com.

• Purposes for which We Use Your Personal Data

  • We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please note that where Zappi undertakes this processing on behalf of our clients as a data processor we do not require a legal basis for such processing.

  • Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at data-privacy@zappistore.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

    1. To register you as a new customer

       • Type of data: (a) Identity (b) Contract

       • Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you

    2. To process and deliver your order including: · Manage payments, fees and charges · Collect and recover money owed to us

       • Type of data: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications

       • Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)

    3. To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey

       • Type of data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications

       • Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

    4. To enable you to partake in a prize draw, competition or complete a survey

       • Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications

       • Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

    5. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

       • Type of data: (a) Identity (b) Contact (c) Technical

       • Lawful basis for processing including basis of legitimate interest: a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

    6. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

       • Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical

       • Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

    7. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

       • Type of data: (a) Technical (b) Usage

       • Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    8. To make suggestions and recommendations to you about goods or services that may be of interest to you

       • Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile

       • Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)

• Marketing

  • We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. To view or make decisions about your personal data, please contact us at data-privacy@zappistore.com.

• Promotional offers from us

  • We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

  • You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

• Third-party marketing

  • We will get your express opt-in consent before we share your personal data with any company outside the Zappi group of companies for marketing purposes.

• Opting out

  • You can ask us or third parties to stop sending you marketing messages at any time by unsubscribing at any time.

  • Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.

• Cookies

  • You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

• Change of Purpose

  • We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at data-privacy@zappistore.com.

  • If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

  • Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your personal data

• We may have to share your personal data with the parties set out below for the purposes set out above.

  • Internal Third Parties as set out in the Glossary.

  • External Third Parties as set out in the Glossary.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

• Transfers outside of the EEA and the UK:

  • We share your personal data within the Zappi Group. This will involve transferring your data outside of the European Economic Area (EEA) and the United Kingdom (UK).

• We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.

• Many of our external third parties are based outside of the EEA and the UK so their processing of your personal data will involve a transfer of data outside of the EEA and the UK.

• Whenever we transfer your personal data out of the EEA or the UK, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented.

  • Where we use certain service providers, we may use Standard Contractual Clauses approved by the European Commission and/or the Information Commissioner’s Office (ICO), which give personal data the same protection it has in Europe, and/or the UK (where applicable). For further details, see (i) European Commission: Standard Contractual Clauses for data transfers between the EU and non-EU countries; and (ii) ICO: International Data Transfer Agreement and guidance.

• Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA and the UK.

Data Security

• We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

• We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

• How long will you use my personal data for?

  • We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

  • To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  • By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for legal or tax purposes.

  • In some circumstances you can ask us to delete your data: see Request erasure below for further information.

  • 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.

Your legal rights

• Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

• If you wish to exercise any of the rights set out above, please complete the form at the end of this section.

• No fee is usually required

  • You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

• What we may need from you

  • We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

• Time limit to respond

  • We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

• California Privacy Notice

  • We collect information referred to as "personal data" in this privacy policy that may also be considered "personal information" pursuant to the California Consumer Privacy Act ("CCPA"). If you are a resident of California ("California Consumer"), the CCPA provides you with specific rights regarding your personal information. This section describes the rights that California Consumers have and explains how to exercise those rights.

    • During the prior 12 months, we have collected the following personal information (and plan to do so in the future):

      • Categories of Personal Information – Described above in the section entitled " THE DATA WE COLLECT ABOUT YOU"

      • Sources of Personal Information - Described above in the section entitled " HOW IS YOUR PERSONAL DATA COLLECTED?"

      • Business Purpose for such Personal Information - Described above in the section entitled " Purposes for which We Use Your Personal Data"

      • Categories of Third Parties with whom Personal Information is Shared - Described above in the section entitled " DISCLOSURE OF YOUR PERSONAL DATA"

    • Request to Know : As a California Consumer, you have the right to request that we disclose certain information to you about our collection, use or disclosure of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:

      • The categories of personal information we collected about you.

      • The categories of sources from which the personal information is collected.

      • Our business or commercial purpose for collecting 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.

    • Request to Delete : 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. However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.

    • We do not "sell" personal information, as defined under the CCPA.

    • How to Exercise CCPA Rights : To exercise the access and deletion rights described above, please submit a request to us by sending an email to data-privacy@zappistore.com or a letter to the physical address above. Only you, or a person or business entity registered with the California Secretary of State that you authorise to act on your behalf (an "authorised agent"), may make the requests set forth above. The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorised representative of that person.

    • Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

    • Inaccurate Data: you have the right to have inaccurate personal information about you corrected.

    • Limit of Disclosure: where applicable, you have the right to limit the use and disclosure of sensitive personal information collected about you.

API data deletion

Who this applies to

This section explains how to request deletion of data Zappi holds about you, your business, or advertising accounts you administer, including data Zappi receives from third-party advertising platforms (Meta Platforms, TikTok) when acting as a data processor on a customer's behalf — see our [API Data Use Addendum](https://www.zappi.io/web/privacy-policy-api-addendum/) for the data flow.

It is relevant to:

- Administrators of advertising accounts that Zappi has accessed under a written agreement with a Zappi customer

- Creators and publishers whose organic post or video identifiers appear in a customer's analytics through this integration

- Anyone exercising rights under the UK GDPR with respect to data Zappi processes

How to make a deletion request

Send an email to **data-privacy@zappistore.com** with the subject line "Data deletion request" and include:

- A clear description of the data you want deleted, including the relevant identifier (an advertising account ID, advertiser ID, creator handle, organic post identifier, or your Zappi user-account email)

- Reasonable evidence of your authorisation to make the request — for example, a screenshot of your administrator role in Meta Business Manager or TikTok Business Center, or written confirmation from another administrator on the account

- Any context that helps us identify the data (the Zappi customer it was processed on behalf of, or the approximate date range)

Our response

We will acknowledge your request within 7 days of receipt and complete deletion within 30 days, in line with Article 12(3) of the UK GDPR. If your request is complex, or if we need additional information to verify your identity or authorisation, we may extend the deadline by up to two further months and will tell you within the first 30 days if this applies.

Deletion covers Zappi's primary data store, derived analytics, reports, exports, search indices, and caches. Data may persist for a short period in encrypted backups, subject to a rotation window of up to 30 days [TO BE CONFIRMED], after which it expires.

Once deletion is complete, we send a confirmation to the email address the request was made from. Deletion is permanent.

Meta and TikTok data specifically

Where the request relates to data Zappi has received from Meta Platforms or TikTok through the API integrations described in the API Data Use Addendum, the same workflow applies. Deletion from Zappi's systems does not affect data held by Meta or TikTok themselves; to request deletion from those platforms, please contact Meta or TikTok directly through their privacy controls.

Zappi Cookie Policy

• Information about our Use of Cookies

  • Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site

• What are Cookies?

  • A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

• We use the following Cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

• You can find more information about the individual cookies we use and the purposes for which we use them below:

  • Google Analytics

    • These may track how long you spend on the site and the pages you visit, which helps us produce engaging content

    • For more information on Google Analytics cookies, see the official Google Analytics page

  • FullStory

    • These allow us to track user behaviour, allowing us to ensure our site is easy to use

    • For more information on FullStory cookies, see their official Terms of Service page

  • Drift

    • These allow us to connect with and manage sales leads and potential sales opportunities from visitors to our site

    • For more information, please see the Drift privacy policy on their website.

• Further Information

  • Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies;

  • You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Glossary

• Lawful Basis

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at data-privacy@zappistore.com;

  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract;

  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

• Third Parties

  • Internal Third Parties

    • Other companies in the Zappi group who are based in South Africa, the United States and Singapore and provide technology, sales and business support services.

  • External Third Parties

    • Service providers acting as processors based in the United States who provide software and support services;

    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in South Africa and the United States who provide consultancy, banking, legal, insurance and accounting services;

    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Your Legal Rights

• You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;

  • Withdraw consent at any time where we are relying on consent to process your personal data. 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.

This policy applies only to the following:

• New vulnerabilities or previously unreported vulnerabilities are in scope

• Any other concerns / issues concerning Zappi

Please do not report the following:

• Theoretical exploits with no proof of concepts;

• Vulnerabilities of system capacity e.g conducting multiple requests that overwhelm the site;

• Weaknesses of Transport Layer Security (TLS) configurations; and / or

• Where our systems may not fully align with "best practice" e.g email configuration that may be considered suboptimal.

Reporting a security vulnerability

If you believe you have discovered a vulnerability, hacking attempt or any malicious activity please email security@zappistore.com.

In the email, please include the following details

• Please use the following subject heading for the email: Responsible Disclosure;

• The location of the vulnerability e.g website / webpage; and

• A description of the type and class of vulnerability e.g Cross Site scripting. At this stage please do not include any details that would allow the issue to be replicated. Zappi will make contact with you to share these details over an encrypted channel.

Before reporting a vulnerability we ask you to read this document carefully to ensure that you understand our Responsible Disclosure Policy and are acting in compliance with it.

Reporting any other issues / potential privacy concerns

If you are aware of any other security or privacy concern to Zappi please email privacy@zappistore.com

Bug Bounty

At Zappi we make every effort to acknowledge and recognize reporters of qualifying vulnerabilities. Unfortunately at present we do not offer a paid bug bounty program however we do strive to offer some form of appreciation to individuals and security researchers who report vulnerabilities according to this policy. People who report a qualifying vulnerability will receive acknowledgement and recognition from us.

Our Commitment

Once you have emailed security@zappistore.com you will receive an email acknowledging your report. Our Information Security Team aims to respond back to you within 24 hours.

When the Information Security Team receives the report, we will work to triage the vulnerability as soon as possible. We will contact you as soon as we can to give feedback on whether the vulnerability had been previously discovered and whether further information and details of the vulnerability will be required from you. Once we have determined the risk clarification of the vulnerability our team will prioritize the vulnerability and address it accordingly.

Once the vulnerability has been resolved / scheduled for resolution we will notify you and ask for confirmation that our identified solution sufficiently covers the vulnerability. During this time we will provide you with an opportunity to give feedback to the team on the vulnerability resolution.

Any information you share with us will be used in the strictest confidence and will be used to help us improve our offering. We will also offer the opportunity to be included in our acknowledgements page to any reporter of a qualifying vulnerability

Guidance for Responsible Disclosure

Security researchers must not

• Take actions that may result in privacy violations, degradation of user experience, disruption to production systems and services and destruction of data during security testing;

• Access unnecessary amounts of data, in most cases 4 or 5 records are sufficient to demonstrate a vulnerability;

• Violate the privacy of Zappi users, employees, contractors or systems

• Knowingly post, transmit, upload, link, send or store malicious software on our platform; and

• Communicate any vulnerabilities or associated details via processes or methods that are not specified within this document to third parties.

If at any stage you are unsure whether the actions you are planning on taking are acceptable please contact our security team for guidance security@zappistore.com

Legalities

This policy does not give you permission to act in any manner which is illegal or which will cause Zappi to be in breach of any of its legal obligations, including but not limited to;

• The General Data Protection Regulation 2016/679 (GDPR) and the Data Protection Act 2018;

• Zappi Terms of Use and Privacy and Cookie Policy; and

• Copyright, Designs and Patent Act, 1988

For US based security researchers and individuals any actions that are conducted in adherence to this policy will be considered as authorized conduct under the CFFA. Similarly for UK based security researchers and individuals, any actions that are conducted in adherence to this policy will be considered as authorized conduct under the Computer Misuse Act.

We will not seek the prosecution of any security researcher who reports in accordance with this policy and in good faith any security vulnerabilities that are in scope as specified above. In the case of a genuine accidental violation of our Responsible Disclosure Policy, we will also not seek the prosecution of these individuals.

This document complements our Privacy and Cookie Policy.

Feedback

If you would like to provide feedback or suggestions on this policy please contact our security team at security@zappistore.com.