Privacy Policy

Last updated: September, 2021

Zeppto and its affiliates  (collectively “Zeppto”, “we” and “us”) respect your privacy.
This Global Privacy Policy describes the types of Personal Data we collect through our Services and via our online presence, which include our main website at zeppto.co, as well as services and websites that we enable Internet users to access (collectively, our “Sites”). This policy also describes how we use Personal Data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices.

This policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third-parties carefully.

1. Overview

Zeppto obtains Personal Data about you from various sources to provide our Services and to manage our Sites. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User” or “Zeppto User”), or a customer of a User (“Customer”). If you are a Customer, Zeppto will generally not collect your Personal Data directly from you. Your agreement with the relevant Zeppto User should explain how the Zeppto User shares your Personal Data with Zeppto, and if you have questions about this sharing, then you should direct those questions to the Zeppto User.

​2. Personal Data We Collect

a. Personal Data that we collect about you.
Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites and Services will be apparent from the context in which you provide the data. In particular:
When you sign up for Zeppto Services we collect your full name, email address, and other personal information (if any).
When you fill-in our online form to contact our sales team, we collect your full name, work email, country, and anything else you tell us about your project, needs and timeline.

When you respond to Zeppto emails or surveys we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Zeppto. If you contact us by phone as a Zeppto User, we may collect additional information in order to verify your identity.
If you are a Zeppto User, you will provide your contact details, such as name, postal address, telephone number, and email address. As part of your business relationship with us, we may also receive financial and personal information about you, such as your date of birth and government identifiers associated with you and your organization (such as your social security number, tax number, or Employer Identification Number).
If you are a Customer of a Zeppto User, when you make payments or conduct transactions through a Zeppto User’s website or application or device we provide, we will receive your transaction information. Depending on how the Zeppto User implements our Services, we may receive this information directly from you, or from the Zeppto User or third parties. The information that we collect will include payment method information, purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. The Zeppto User will determine the payment methods that it enables you to use, and the payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you by the Zeppto User. When you make a transaction, we may also receive your name, email, phone number, billing or shipping address and order ID. We may also process your pseudonym used for your account, your client account number and client account password to complete your order with the Zeppto User.

When we conduct fraud monitoring, prevention, detection, and financial compliance activities or provide such services to our Zeppto Users, we will receive Personal Data from you (and your device) and about you through our Service and from our business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may collect Personal Data about you and use technology to help us assess the risk associated with an attempted transaction by you with a Zeppto User.

You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

b. Information that we collect automatically on our Sites.
Our Sites use cookies and other technologies to function effectively. These technologies record information about your use of our Sites, including:
Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.

We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We may use Google Analytics on our Sites to help us analyze Your use of our Sites and diagnose technical issues.

To learn more about the cookies that may be served through our Sites and how You can control our use of cookies and third-party analytics, please see our Cookie Policy.

3. How We Use Personal Data

We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.

These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:
It’s 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 (for example, when we provide a service you request from us);
It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
You give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
We need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

4. How We Disclose Personal Data

Zeppto does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.

a. Zeppto. We share Personal Data with other Zeppto entities in order to provide our Services and for internal administration purposes.

b. Service providers. We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf.

c. Our Zeppto Users and third parties authorized by our Zeppto Users. We share Personal Data with Zeppto Users as necessary to maintain a User account and provide the Services.

d. Corporate transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

f. Compliance and harm prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Zeppto, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

5. International Transfers of Personal Data

The personal information we collect is stored and processed in the European Union, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

6. Your Rights and Choices​

You have choices regarding our use and disclosure of your Personal Data:

a. Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

b. How you can see or change your account Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by contacting us.

c. Your data protection rights. Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:
The right to request confirmation of whether Zeppto processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
The right to request that Zeppto rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
The right to request that Zeppto erase your Personal Data in certain circumstances provided by law;
The right to request that Zeppto restrict the use of your Personal Data in certain circumstances, such as while Zeppto considers another request that you have submitted (including a request that Zeppto make an update to your Personal Data); and
The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.
Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.

d. Process for exercising data protection rights. In order to exercise your data protection rights, you may contact Zeppto as described in the Contact Us section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

If you are a Customer of a Zeppto User, please direct your requests directly to the Zeppto User. For example, if you are making, or have made, a purchase from a merchant using Zeppto as a payment checkout service, and you have a request that is related to the payment information that you provided as part of the purchase transaction, then you should address your request directly to the merchant.

How We Respond to Do Not Track Signals: your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, we do not respond to this type of signal.​

7. Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

8. Contact Us

The website https://www.zeppto.co, the website https://www.safeconnecty.com, and the associated services are provided by Zeppto (Comeone) SAS, a company incorporated in France (registration number 847 816 543) having its registered office at 94 rue de villiers, 92300 Levallois Perret, France

To exercise your rights and control your personal information as aforementioned, you can contact Zeppto (Comeone) SAS at legal@zeppto.co

9. Changes to this policy

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the bottom of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through your Zeppto Dashboard, email address and/or the physical address listed in your Zeppto account.

This policy is effective as of 1 September 2021.