PRIVACY NOTICE FOR WALLPAPERZ

1.   Introduction

 

1.1        This document (“Privacy Notice”) describes how ZONEofTECH treat Personal Data you provide to us via the WallpaperZ app or that we collect about you resulting from your use of the WallpaperZ app (we refer to the WallpaperZ app as “WallpaperZ”).

 

1.2        We are ZONEOFTECH LTD trading as ZONEofTECH (“ZONEofTECH,” “we”, “us” or “our”) a company incorporated in England, with company number 09832631 and a registered office address at Lantern House, 39 Duke Street, Chester, United Kingdom, CH1 1RP.

 

1.3        We are the controller of your Personal Data that we have collected.

 

1.4        If you have any questions about this Privacy Notice or our data protection practices, please contact us at the following address: dataprotection@wallpaperzapp.com.

 

2.   Personal Data

 

2.1        We are providing this Privacy Notice because we have collected certain Personal Data (as defined below) about you related to your use of WallpaperZ.

 

2.2        In this Privacy Notice, “Personal Data” includes any information that directly or indirectly identifies you personally that is supplied to us or otherwise collected in conjunction with your use of WallpaperZ, as well as information generated from your use of WallpaperZ.

 

2.3        We keep our Privacy Notice under regular review. This version was last updated on 7 June 2023.

 

2.4        Third party links. WallpaperZ may, from time to time, contain links to and from third party websites and services (such as URL’s contained within user generated content). Please note that such third party websites and services may have their own privacy policies. ZONEofTECH does not accept any responsibility or liability in relation to such third party websites, services or privacy policies (or for any personal data that may be collected through such third party websites or services).

 

3.   Categories of Personal Data that we may collect about you

 

3.1        We collect, use, store and transfer different kinds of Personal Data about you which we have identified as follows:

Registration data:

If you choose to register a WallpaperZ account with ZONEofTECH using your email address, registration data includes:

·       your name (if provided) and email address.

If you choose to register a WallpaperZ account via the “Sign In with Apple” or “Sign In with Google” functionality:

·       unless you specify otherwise (i.e. by choosing to share such information during the registration process if prompted), we do not process your name or email address.

Profile data:

If you are a wallpaper designer collaborating with us and have chosen to create a WallpaperZ profile:

·       profile data you provide may include Personal Data including your bio text, profile photos, country, URLs and your social media links.

Usage data:

Usage data is data relating to how you use WallpaperZ (which may include certain Personal Data), such as:

·       details of your in-app transactions including subscriptions for premium content (however ZONEofTECH do not collect or process any of your financial data);

·       wallpaper image keywords you have requested via WallpaperZ (to the extent requests contain any Personal Data);

 

·       analytics data (which may contain Personal Data) including your IP address, device model, operating system details, details of wallpaper images you downloaded from WallpaperZ (or in the case of Android only, details of wallpaper images you have applied to your device).

Marketing and communications data:

If you choose to opt-in to WallpaperZ mailing lists, marketing and communication data will include your email address and name (if provided).

 

3.2        Special categories. We do not collect any special categories of Personal Data about you (such as 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), or any information about criminal convictions and offences.

 

3.3        Minors. Please note that WallpaperZ is not directed to individuals under the age of 16, and we request that such individuals do not provide Personal Data through WallpaperZ.

 

4.   How is your Personal Data collected?

 

4.1        We use different methods to collect Personal Data from and about you including through:

 

(a)  Direct interaction with you: You may provide Personal Data directly to us by completing forms or submitting/uploading Personal Data during your use of WallpaperZ. Please note that communications and emails you send to us independently (outside the functionality of Wallpaperz) are not addressed under this Privacy Notice.  

 

(b)  Automated collection: Usage data (as described above) is automatically collected via WallpaperZ.

 

(c)  Via third parties: Certain Personal Data about you may be sourced from third parties or processed by third parties via third party technologies used within WallpaperZ. See clause 8 for more details.

 

5.   What is the legal basis and purpose for holding your Personal Data?

 

5.1        The table below sets out our purposes for processing your Personal Data and the lawful bases we rely on to carry out such processing.

Purpose of processing activity

Lawful basis for processing

To provide WallpaperZ: We own, operate and manage WallpaperZ for iOS and Android devices. WallpaperZ provides a fun and intuitive way to view and download high-resolution 8K background wallpapers onto your device. WallpaperZ also features certain in-app purchase functionalities. From time to time we may launch WallpaperZ on additional operating systems.

 

•  Necessary for the performance of our contract with you, or to take steps prior to entering into a contract with you.

 

To communicate with you: This includes communicating with you regarding your account registrations, login credentials, confirmations of in-app transactions you make (such as subscriptions for premium content), and communicating legal notices.

•  Necessary for the performance of our contract with you, or to take steps prior to entering into a contract with you.

 

•  Your consent, where you have requested specific information from us, such as through our customer service team or support contacts details referenced in this Privacy Notice.

 

For marketing purposes: If you have chosen to opt-in to WallpaperZ marketing mailing lists (and/or subscribed to WallpaperZ marketing content via social media platforms), this includes sending you marketing communications about WallpaperZ in accordance with your marketing preferences and/or applicable data protection laws.

•  Your consent, collected when you place an order or subscribe through other means.

 

•  Where permitted by applicable data protection laws, we may rely on our legitimate interests instead of consent (where our legitimate interests are to pursue business development initiatives and keep you informed of relevant offers).

 

Usage: This includes understanding how users are using WallpaperZ; improving WallpaperZ; and calculating applicable royalties relating to applicable third party content licensors.

•  Where permitted by applicable data protection laws, we may rely on our legitimate interests instead of your consent (where our legitimate interests are to improve WallpaperZ and to make correct calculations of applicable royalties to applicable third party content licensors).

 

Legal claims, exercising legal rights and complying with legal obligations: This includes:

·       allowing us to establish, exercise or defend legal claims in potential or actual legal proceedings;

 

·       allowing us to exercise or perform any right or obligation which is conferred or imposed on us by applicable law); and

 

·       allowing us to comply with any applicable legal obligation, including obligations to retain your data for a certain period of time.

•  Necessary for our legitimate interests in pursuing legal claims.

 

•  Necessary to comply with an applicable legal obligation.

Security features: This includes protecting the security of WallpaperZ.

•  Necessary for our legitimate interests.

M&A: This includes sharing data with potential WallpaperZ investors and/or carrying out M&A activities.

•  Necessary for our legitimate interests.

 

6.   How long do we keep your Personal Data?

 

6.1        We only retain your Personal Data for as long as is reasonably necessary to fulfil the purpose for which it was originally collected, or as otherwise required by applicable legal obligations. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. If we continue to retain your Personal Data in accordance with a legal obligation, any further processing of your data will be limited to compliance with such legal obligation.

 

6.2        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 obligations.

 

7.   Your rights as a data subject

 

7.1        You have important rights in relation to your Personal Data that we hold and process, which you may request to exercise by contacting us (using the details provided in clause 1.4). Those rights are:

(a)         Right of access: You have the right to request a copy of the Personal Data that we hold about you.

 

(b)         Right to withdraw consent: Where processing is based on consent, you have the right to withdraw that consent at any time.

 

(c)         Right of rectification: You have a right to correct Personal Data that we hold about you that is inaccurate or incomplete.

 

(d)         Right to be forgotten: In certain circumstances you can ask for the Personal Data we hold about you to be erased from our records.

 

(e)         Right to restriction of processing: Where certain conditions apply you have a right to restrict the processing of your Personal Data.

 

(f)          Right of portability: In certain circumstances you have the right to have the Personal Data we hold about you transferred to another organisation.

 

(g)         Right to object: You have the right to object to certain types of processing such as processing based on legitimate interests or direct marketing.

 

7.2        It is important to note that these rights are subject to certain limitations and exceptions. For example, there may be circumstances where we will not be able to delete information that is required to maintain our business purpose or that is required to facilitate your continued use of WallpaperZ. All the above requests will be forwarded on to other parties holding and processing your data where legally required.

 

7.3        We have a legal obligation to respond to all legitimate requests within one month. Occasionally it could 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.

 

7.4        For more information about your Personal Data rights for UK residents, please visit the Information Commissioner Office for the United Kingdom’s website.

 

8.   Sharing with third parties

 

8.1        We pass your Personal Data on to some or all of the third-party service providers contracted by us to help provide WallpaperZ’s functionalities, as set out in the table below:

 

Third party

Description

Apple

·       To provide the Sign in with Apple login functionality.

·       To provide in-app transaction functionalities (via Apple’s App Store).

Google

·       To provide the Sign in with Google login functionality.

·       To provide in-app transaction functionalities (via Google Play).

RevenueCat

·       To automate the calculation of app downloads across different platforms (including to calculate applicable third party content licensor royalties).

 

8.2        In addition, we may share your Personal Data with third parties who support our business such as other companies in our corporate group, marketing service providers, IT service providers, payment processing providers, professional advisors such as legal advisors, accountants, auditors and insurers, potential investors in or purchasers of our business (and relevant advisors). 

 

9.   International data transfers

 

9.1        WallpaperZ is available in the following countries, which may be updated from time to time: UK, USA, Canada, all EU Member States, and India.

 

9.2        We are based in the UK and we may sometimes transfer your Personal Data to countries outside the UK. In those cases, we will comply with applicable laws designed to ensure the privacy of your information. We may transfer your information to our third party service providers located outside the UK. We will only transfer your Personal Data where the UK government has decided the particular country ensures an adequate level of protection of your Personal Data under Article 45 of the UK GDPR, or there are otherwise appropriate safeguards in place, or a specific exception applies under relevant data protection law.

 

9.3        We may transfer your Personal Data to Canada or the EU based on applicable adequacy regulations.

 

9.4        We may transfer your Personal Data to the USA or India using appropriate transfer mechanisms such as Standard Contractual Clauses (“SCCs”) adopted by the European Commission (including appropriate supplementary measures), and if applicable the UK Addendum to the EU SCCs.

 

9.5        To obtain a copy of the SCCs, please contact us (using the contact details provided in clause 1.4 above).

 

10. Complaints

 

10.1     If you wish to raise a complaint on how we handle your personal data, you can contact us using the details provided in clause 1.4 above.

 

10.2     You have the right to make a complaint to the Information Commissioner Office (ICO), the UK regulator for data protection issues (www.ico.org.uk) at any time, should you not be satisfied with our response. Their Help Desk number is 0303-123-1113.