Privacy Policy

What does this Privacy Policy Cover

Zapper respects your privacy and is committed to protecting your Personal Information.
We want to be transparent with you about how we collect and use your Personal Information in making available (i) the Zapper website at
www.zapper.com (the Site),
(ii) the Zapper free download QR Code applications for the App Store (iPhone), Google Play (Android) and AppGallery (Huawei), (the App), and (iii) Zapper’s related online and mobile services as described in the Terms of Use available at
https://zapper.com/termsofuse
(together with the Site and the App, the Services) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

Third party links.

This Privacy Policy aims to give you information on how Zapper collects and processes your Personal Information through your use of the Services, including any data you may provide through the Services.

This Policy explains how we obtain, use and disclose your personal information, in accordance with the requirements of the Protection of Personal Information Act (“POPIA”).

We will post any modifications or changes to this Privacy Policy on this page.

We respect your privacy and your personal information and for this reason, we take all reasonable measures, in accordance with this Policy, to protect your personal information and to keep it confidential, even when you are no longer our customer.

Who we are and how to contact us

Who we are.

This Privacy Policy is issued on behalf of Zapper Marketing (Southern Africa) (Pty) Ltd so when we mention “Zapper”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company(ies) in Zapper Marketing, its subsidiaries and associated companies responsible for processing your Personal Information.

How to contact us.

You can contact us by emailing: support@zapper.com. Questions, comments or concerns regarding this Privacy and Cookie Policy or our use of your Personal Information are welcomed.

Your rights relating to your Personal Information

Your rights in connection with your Personal Information

Under certain circumstances, by law you have the right to:

Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information 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 Information where you have exercised your right to object to processing (see below).
Object to processing of your Personal Information. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Information for direct marketing purposes.
Request the restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of Personal Information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Information. We will provide to you, or a third party you have chosen, your Personal Information 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. This right only exists where we are relying on consent to process your Personal Information (Consent Withdrawal). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Services. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details shown here Who We Are and How to Contact Us

Typically, you will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information 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.

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.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Information, please contact us at: support@zapper.com.

We will reply to your complaint as soon as we can.

Marketing communications preferences

Zapper will not send you any marketing communication via SMS or email. The only communications we need to send to you is to notify you of changes to our terms and conditions and policies, updates, security alerts, and support and administrative messages regarding the Services.

If you give us permission, we may use your personal information to tell you about products, services and special offers from us or other companies that may interest you. We will do this through email, text message (SMS), social media platforms or notify you on your mobile applications. If you later decide that you do not want us to do this, please contact us through our customer service channels to stop this service.

What Personal Information we collect

All the Personal Information we collect, both from you and from third parties about you, is outlined in the table below.

Before you read that table, it might be useful to explain what Personal Information is. The POPIA definition of Personal Information can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.

It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed)

However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

Category of Personal Information collected	What this means
Identity Data	First name, surname, date of birth, facial recognition via forward-facing camera.
Contact Data	Email address and telephone numbers.
Financial Data	Payment card details.
Transaction Data	Any details about payments to and from you and other details of services you have purchased from us. Data in respect of your transactions with third parties.
Service Data	Your data that you provide to us when you report a problem or ask a question in respect of our Services or when you request further services from us. If you contact us, we may keep a record of that correspondence.
Technical Data	This includes: Device information: We may collect information about the device you use to access the Services, including your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile network information, telephone number and other technology on the devices you use to access our Services. Location information: When you use one of our location-enabled Apps or Services, we may collect and process data about your actual location. Log information: We may automatically collect and store certain information about your use of the Services in server logs, including but not limited to internet protocol (IP) addresses, internet service provider, clickstream data, browser type and language, viewed and exited pages and date or time stamps. Unique application numbers: When you install or uninstall an App containing a unique application number or when such an App searches for automatic updates, that number and information about your installation, for example the type of operating system, may be sent to us.
Special Category of Personal Information	Application \ User Account Profile Picture.

Aggregated Data

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 Information, but once in aggregated form it will not constitute considered Personal Information as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data to calculate the percentage of users accessing a specific Services feature. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

Special Categories of Personal Information

The Zapper application has a feature to upload an image against your profile after a successful registration. This image is collected and stored on our system but never shared.

How we use your Personal Information and why

We will only use your Personal Information for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Information for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

Without your personal information, we may not be able to provide or continue to provide you with the products or services that you need.

What is our legal basis for processing your Personal Information?

In respect of each of the purposes for which we use your Personal Information, we will rely on one of the following legal bases:

Where we need to perform a contract we are about to enter into or have entered into with you (Contractual Necessity).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (Legitimate Interests). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (Compliance with Law).
Where we have your specific consent to carry out the processing for the Purpose in question (Consent).

We will process your personal information if you give us your consent willingly or in accordance with the law. You give your consent to us through the use of our product and services.

We will only disclose your personal information if:

the law requires it;
we have a public duty to disclose the information;
our or your legitimate interests require disclosure; or
you agreed that we may disclose your information.

Generally we do not rely on your Consent as a legal basis for using your Personal Information, other than in the context of direct marketing communications.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Information.

Purpose	Category(ies) of Personal Information involved	Why do we do this	Our legal basis for this use of data
Account Creation	Identity Data Contact Data Technical Data	To register you as a new customer.	Contractual Necessity.
To process payments (and their associated services and functionalities)	Identity Data Contact Data Financial Data Transaction Data	To process and deliver your order including manage payments, fees and charges.	Contractual Necessity.
Fraud Prevention	Identity Data Contact Data Transaction Data Financial Data	To keep our services and associated systems operational and secure.	Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our services and ensuring we are within our processing obligation with our payment service providers.
Troubleshooting	Identity Data Contact Data Service Data Technical Data Transaction Data	To track issues that might be occurring on our systems and to notify you of updates and security alerts.	Legitimate Interests. It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Services and associated systems and services.
Data analysis, and improvements to our Services	Identity Data Contact Data Service Data Behavioural Data Technical Data	To carry out audits and data analysis to identify usage trends, improve the Services and improve the effectiveness of our communications.	Legitimate Interests. It is in our legitimate interests that we are able to use audit and data analysis to improve the Services and improve the effectiveness of our communications.
Customer Services	Identity Data Contact Data Service Data Technical Data	To provide customer service, including to respond to your enquiries and fulfil any of your requests for information in respect of the Services.	Contractual Necessity.
Personalisation	Identity Data Service Data Behavioural Data Technical Data	To personalise your experience on the App by presenting information tailored to you and your geographic location.	Legitimate Interests. It is in our legitimate interests that we are able to provide a more personalised service to you to improve your experience of the Services.
Marketing	Identity Data Contact Data Marketing and Communications 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 services and offers may be relevant for you.	Legitimate Interests. We have a legitimate interest in providing you with updates on our Services, including in-App promotions, upcoming events, and other news about products and services offered by us and related offers where you have purchased or shown interest in similar services from us.
Compliance with law and regulation	All relevant data	We may use data as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our regulators; (c) to respond to requests from public and government authorities; (d) to enforce or apply this Privacy and Cookie Policy or our Terms of Use; (e) to protect our operations; (f) to protect our rights, privacy, property or safety, and/or that of you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.	Depending on the circumstances, our legal basis may be: Compliance with a legal obligation to which we are subject; Necessity to protect your vital interests or those of another person; Legitimate interests.

What happens when you do not provide necessary Personal Information?

Where we need to process your Personal Information either to comply with law, or to perform 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 the functionalities of the Services).

In this case, we may have to stop you using our Services have with us but we will notify you if this is the case at the time.

Personal Information from Third Party Sources

In addition to the Personal Information that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Information from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Third party data source	Publicly available?	Category(ies) or other types of Personal Information received.
Social Media	Yes	Identity Data Contact Data
Our Affiliates	No	Identity Data Contact Data

How we use cookies & other tracking or profiling technologies.

Cookies.

What are cookies?

We may collect information using cookies. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site. Other than our Site, our Services do not use cookies.

We use two broad categories of cookies:

first party cookies, served directly by us to your computer or mobile device; and
third party cookies, which are served by our partners or service providers on our Site.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Type of cookie	Purpose
Strictly Necessary Cookies	These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and require you to re-enter your password after a certain period of time has elapsed to protect you against others accidentally accessing your account contents. 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	These cookies are used to recognise you when you return to our Site and allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site which you can customise. 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 visit our Site. We also use these cookies to obtain information about your visit, including items you viewed or searched for, page response times and download errors.
Analytics and Performance Cookies	These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, for example, by ensuring that users are finding what they are looking for easily, as well as to gather broad demographic information and to monitor the level of activity on our Site. We also use these cookies to obtain information about your visit, including the full Uniform Resource Locators (URL) clickstream data, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from webpages. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

Type of cookie

Purpose

Strictly Necessary Cookies

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and require you to re-enter your password after a certain period of time has elapsed to protect you against others accidentally accessing your account contents. 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

These cookies are used to recognise you when you return to our Site and allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site which you can customise. 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 visit our Site. We also use these cookies to obtain information about your visit, including items you viewed or searched for, page response times and download errors.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, for example, by ensuring that users are finding what they are looking for easily, as well as to gather broad demographic information and to monitor the level of activity on our Site. We also use these cookies to obtain information about your visit, including the full Uniform Resource Locators (URL) clickstream data, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from webpages.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.

You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the settings, help tools or edit facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and http://www.youronlinechoices.com/uk/.

In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en-GB

To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout and download and install the linked add-on for your current web browser. The Google Analytics Opt-out Browser Add-on is available for Microsoft Internet Explorer, Google Chrome, Mozilla Firefox, Apple Safari and Opera.

Please note that certain 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. If you would like to disable these “third party” cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to that third party’s website and setting your cookie preferences to stop any further cookies being written to your device.

Who we share your Personal Information with.

The table below describes who we share your Personal Information with, what we share and why we share it.

Recipients	Category(ies) of Personal Information we share.	Why we share it
Our Affiliates	Identity Data Contact Data	Our affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison etc).
Service Providers	Identity Data Contact Data Technical Data	Our service providers provide us with IT and system administration services and KYC services.
Professional advisers	Identity Data Contact Data	Our lawyers, bankers, auditors, and insurers provide consultancy, banking, legal, insurance and accounting services.
Regulators and other authorities	Identity Data Contact Data	Authorities may require reporting of processing activities in certain circumstances
Analytics Providers	Behavioural Data Technical Data	Our analytics providers will use this information for the purpose of evaluating your use of our Sites, compiling reports on Site activity and providing other services relating to Site activity and internet usage. Our analytics providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on our analytics providers’ behalf.

Data transfers

We endeavour to ensure that people to whom we provide Personal Information hold it subject to appropriate safeguards and controls.

We will not disclose your personal information to external organisations that are not our service providers, unless you gave us your consent, or unless we may do so by law, or if it is necessary for the conclusion or performance of our agreement with you.

Sometimes we will process your personal information in other countries, either to carry out your instructions or for ordinary business purposes. These countries may not have the same level of protection. We will only process your personal information with your consent. If necessary, we will ask the party to whom we transfer your personal information to agree to our privacy principles, associated policies and practices.

How we keep your Personal Information secure.

We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Information to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Information breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Information.

How long we store your Personal Information.

We will only retain your Personal Information for so long as we reasonably need to use it for the purposes set out above How we use your Personal Information and why, unless a longer retention period is required by law (for example for regulatory purposes).

The table below shows our standard retention practices:

Category of Personal Information	Retention period
Technical Data	For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see How we use your Personal Information and why)
Service Data	For so long as you remain a customer of ours.
Contact Data	For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see How we use your Personal Information and why)
Transactional Data	For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see How we use your Personal Information and why)

Third party links.

This Services may include links to third-party websites, plug-ins and applications. We are not responsible for the privacy or other practices of any such third parties. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Information. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Services, we encourage you to read the privacy policy of every site you visit.

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