PRIVACY POLICY

Last Updated: 12th March, 2023

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Zuddl is committed to building a strong and long-lasting relationship with you based on trust and clarity, which requires safeguarding and respecting your privacy and choices. Thus, We have set our full privacy policy (“Privacy Policy”) below.

Your Privacy is important to us. This Privacy Policy has been designed keeping your best interests in mind. 

Our Privacy Policy explains how we treat Your data and privacy when you access and/or use the website. You agree and acknowledge that We may access, collect, use, treat and disseminate your data according to this Policy. 

This Privacy Policy should be read alongside, and in addition to, our Terms of Use which can be found at https://www.zuddl.com/terms-of-use (“Terms of Use”)

Applicability: 

This Privacy Policy applies to You in the event that You are: 

  • Accessing and/or using any of Our products
  • Registering on the Website for accessing and/or using any of Our products
  • Requesting a demo for Our products through the Website
  • Accessing the Website or any content thereof; and/or 
  • Simply viewing, surfing and/or browsing the Website. 

Scope of this Privacy Policy:

This Privacy Policy applies only to the actions of Zuddl, its Users and End User with respect to the Website. It does not extend to any website that can be accessed from this Website including but not limited to any links that we may provide to social media websites. 

For the purposes of the applicable Data Protection Laws, Zuddl is the “data controller”. This means that Zuddl determines the purposes for which, and the manner in which, your Data is processed. 

Definitions:

Any Capitalized terms used in this Privacy Policy shall have such meaning as assigned hereunder or under the Terms of Use. 

“Zuddl” or “We” or “Us” means Joyn Experiences Inc a Delaware corporation, with a place of business at 2529 las Palmas Lane Plano TX 75075, and Joyn Zuddl Experiences Pvt Ltd, Hyderabad India.

“CCPA” means California Consumer Privacy Act, 2018;

“CPRA” means California Privacy Rights Act.

“Cookies” means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website;

“Data” means collectively all Information that you submit to Zuddl via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

“Data Protection Laws” means any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, CCPA/CPRA and any other laws, regulations and secondary legislation placed by nations from where the User is; 

“End User” means any person who enquires, accesses, engages with or places a request on our Website;

“GDPR” means the General Data Protection Regulation (EU) 2016/679;

“Personal Information” shall have the same meaning as defined under ‘Data Collected’;

“Sensitive Personal Information” shall have the same meaning as defined under ‘Data Collected’;

“User” or “You” means any person who accesses or uses the Website, if You are an enterprise, the definition includes authorized persons who use the Website on your behalf;

“Website” means the website that you are currently using at www.zuddl.com, and any sub-domains of this website unless expressly excluded by their own terms and conditions. 

Data collected:

Traffic Data, Personal Information and such other Data as may be collected by us pursuant to Your or the End User’s use of the Website or provided to us by You or the End User by way of any sort of communication (“Information”). The User and End User agree and acknowledge that the collection of such Information is essential for providing effective services to you. 

Personal Information: means any information that identifies or is unique to You or the End User and includes but is not limited to contact data and demographic data. The Personal Information collected by Zuddl is enlisted in Schedule I.  Users and/or End-Users residing in the state of California may write to us at security@zuddl.com to learn more about the specific categories of personal information We are going to collect from the User/End User and the purpose for the same. Residents of California, under the provisions of CCPA/CPRA,  have the rights request information from us regarding the manner in which we share certain categories of “personal information” we collect, the specific business purposes for collecting such information and the categories of third parties with whom such information can be shared. For more information, please get in touch with our team at security@zuddl.com. Sensitive personal information refers to information that does not identify an individual, but is related to an individual and communicates information that is private or could potentially harm an individual should it be made public. Sensitive personal information is included in the definition of Personal Information. 

Traffic Data: means any data generated by the End User or You, or the End User’s or Your computer, computer system, device, program or network that forms part in a chain of communications indicating the communication’s origin, destination, route, format, intent, time, date, size, duration, or type of underlying service, which Zuddl may automatically track and collect when End User accesses the Services, including IP Addresses; Domain Server Details; and/or other information with respect to Your or End Users device with the Website, Products, Services and other applications.

On all the mobile apps (Android and iOS) Published by Zuddl, the users can update their profile with any personal information and/or can click profile photos from the camera or upload from their devices, and these images may be uploaded to our servers in compliance with SOC2, GDPR, CCPA,CPRA and ISO/IEC 27001:2013. This is not mandatory and users can choose to not have a profile picture.

Zuddl may use third party software or applications on the Website for improving its service to You. Such third-party software and applications may collect Information from You. The privacy policy of such third parties are not governed by this Privacy Policy. Kindly refer to their respective privacy policy to learn more. 

Use of Data:

The Data We collect from You or End Users will be used for one or more of the following purposes to render our services more effective: 

  • Internal record keeping;
  • Assist you in accessing or using our products and/or services;
  • Preventing any potentially illegal activity and preventing screening of any undesirable or abusive activity;
  • Monitor, maintain, troubleshoot and/or improve Our products and services and any associated features, including evaluation or devising new features; 
  • Performing statistical and/or analysis on the Data;
  • Analyse and measure User and/or End User behaviour and trends; 
  • Use the information collected in such other form and manner to maintain the quality, effectiveness and standard of Our Website, products and services; and
  • Contact for market research purposes including transmission of marketing materials that may be of interest to you whether by soft-opt-in or by opt-in methods. 
  • soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
  • for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we will provide.

We collect and store Personal Information in a segregated manner, however the same is used in an aggregated manner for the following purposes: 

  • To build user profiles and marketing profiles; 
  • To aid strategic development, data collection and analytics; 
  • To manage Our relationship with our advertisers, partners or any third parties; and 
  • To audit usage of Our products and services. 

Confidentiality, Disclosure and Transfer:

Zuddl uses its best effort to keep confidential any information that it receives from You or End User, which Zuddl may, in its reasonable opinion consider confidential, except the following: 

  • Zuddl does not sell personal data.
  • Such Data that was already known to Zuddl prior to receiving it from the End User; 
  • Such Data that was received from such third party which is not subject to similar confidentiality restrictions; 
  • Such Data that is independently developed by Zuddl; and/or
  • Such Data is required to be disclosed by law. 

Zuddl reserves its rights to disclose Data to any Person, in accordance with its Privacy Policy, if, in its reasonable opinion, falls within the following: 

  • Zuddl’s Group companies and/or affiliates;
  • Zuddl’s employees, agents and/or professional advisors – to provide information with respect to the enquiry and to provide any additional information which appears to be within the realm of the enquiry; 
  • Third party service providers who provide services to Us which require the processing of personal data; and
  • Third party payment providers who access payments made over the Website. 

Security: 

Zuddl strives to protect Personal Information during transmission and receipt by following generally acceptable industry standards, including the International Standard IS0 27001, GDPR,CCPA/CPRA and SOC2 Type 2 on “Information Technology-Security Techniques-Information Security Management System – Requirements”

Zuddl’s security practices and procedures include measures to deal with any suspected data breach and are periodically reviewed and audited by a certified auditor approved by the Government. In the event that You or End User has any reason to believe that there has been a data breach, kindly inform Zuddl on security@zuddl.com

Although Zuddl makes best possible efforts to transmit and store all the Data collected in a secure operating environment that is not open to the public, due to the nature of the internet, Zuddl cannot guarantee that there will be no unintended disclosures of the Data. 

End User or You may be redirected to third party web sites or servers for the provision of services.  The Privacy Policy of such third party applications, websites, servers, etc may be different from Zuddl’s privacy policy and will therefore not be governed by this Privacy Policy. 

Data Retention: 

Unless a longer retention period is required or permitted by law, Zuddl will only hold Data on Our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy.

Change of Business Ownership and Control: 

Zuddl may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Zuddl. Information provided will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Information for the purposes for which it was originally given to Us.


We may also disclose Information to a prospective purchaser of Our business or any part of it.


In all of the above instances, we will take steps to ensure that Your privacy is protected.

Transfers outside the European Economic Area: 

This section of the Privacy Policy applies to You only if You are in the EEA. 

Data which we collect from you may be stored and processed in and transferred to countries outside of the EEA. For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organisation in receipt of the Data is based in the United States of America.

To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Cookies

Cookie is a small data file that is sent to or accessed from Your device when You use the Platform (“Cookies”). The use of Cookies helps us to assist Your use of certain aspects of the Platform. You can delete Cookies at any time, or You can set Your device to reject or disable Cookies. We may use information from Cookies for the following purposes:


  1. Traffic monitoring;
  2. IP address from which You or End User access the Website;
  3. Type of device and operating system used to access the Website;
  4. Date and time of Your or End Users access to the Website;
  5. Pages that You or End User visit.


Revisions to Privacy Policy

We reserve the right to update and revise this Privacy Policy at any time. You or End User can determine if this Privacy Policy has been revised since the last visit by referring to the Last Updated date at the top of this page. You and/or End User should therefore review this Privacy Policy regularly to ensure that You/End User are aware of its terms and amendments. Use of the Platform constitutes acceptance of the terms of the Privacy Policy as amended or revised by Us.

Acceptance and rights

You/End User accept this Privacy Policy by accessing, using or engaging with the Website. 

You have the following rights in relation to your Data and shall be duly notified of the completion of the following, should you opt to choose one or more of the following: 

  • Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
  • Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
  • Right to erase - the right to request that we delete or remove your Data from our systems.
  • Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
  • Right to data portability - the right to request that we move, copy or transfer your Data.
  • Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: security@zuddl.com. Users or End Users residing in the state of California may contact us via email at security@zuddl.com. Please note that Zuddl will not discriminate against any of its Users and/or End Users for reason of them having exercised any of the aforementioned rights. 

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Legal Disclaimer:

We, our officers, directors, employees, affiliates and agents will not be liable for any acts or omissions of a third party, or for any unauthorized interception of data or breaches attributable in full or in part to the acts or omissions of third parties, or for damages associated that result from the operations systems, equipment, facilities or service provided by third parties that are interconnected with the servers.

A special note about Children: 

The Services under this Platform are not directed towards children under 18 years of age. They are not allowed to register with or use the services or provide their personal data, either on their own or on behalf of an enterprise. If We discover that We have collected Information from a child under 18, We will delete that Information immediately. 

Jurisdiction: 

This Privacy Policy will be governed and interpreted according to the laws of India (for all South East Asian countries) and United States (for rest of the world, excluding South East Asian countries). All disputes arising under this Privacy Policy will be subject to the exclusive jurisdiction of the Courts of Delaware United States/ Hyderabad, India and no other place whatsoever, and You specifically and irrevocably consent to the jurisdiction of such courts. 

Grievance Redressal:

If You find any discrepancies or have any grievances in relation to the collection, storage, use, disclosure, and transfer of Your Information under this Privacy Policy, please contact us security@zuddl.com