This Privacy Policy agreement was last updated on July^, 2025

Turnip Media Private Limited ("TMPL") values your privacy. In this Privacy Policy ("Policy"), we describe the information that we collect about you when you visit TMPL’s mobile application (and website, if any) (“Zaps”), and use the services available on Zaps ("Services"), and how we use and disclose that information.

If you have any questions or comments about the Privacy Policy, please contact us at [email protected]. This Policy is incorporated into and is subject to the TMPL’s Terms of Use, which can be accessed at https://zaps.gg/terms. Your use of Zaps and/or Services and any personal information you provide on Zaps remains subject to the terms of the Policy and TMPL's Terms of Use.

In terms of the Information Technology (Intermediaries Guidelines) Rules, 2011 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, any grievance or complaint may be intimated to Pooja Dubey, Grievance Officer, who may be reached at [email protected]. The complaint shall be redressed within a period of 1 (one) month.

A. Collection of Your Personal Information

1. COLLECTION OF PERSONAL INFORMATION

“Personal information” is defined to include information that whether on its own or in combination with other information may be used to readily identify or contact you such as: name, address, email address, phone number etc.

We collect personal information from users who are desirous of posting Submitted Content on Zaps. This information is partially or completely accessible to all visitors using Zaps.

You may log into Zaps through your phone number. If you do so, you must verify your phone number through an OTP. At the time of logging in, user data such as name, gender, profile picture etc., shall be asked as input and from the user. Such information gathered shall be utilized to ensure greater customer satisfaction and help a customer satiate its needs. The type of personal information that we collect from you varies based on your interaction with Zaps.

We may also collect personal information that you post in your Submitted Content such as profile, feedback, and any comments or discussions you post in any blog, post, or other correspondence site on Zaps. TMPL reserves the right to access the posts posted on the platform. These can be used for but not limited to monitor and prohibit abuse, safeguard the rights of the users, resolve disputes etc.

2. COLLECTION OF AUTOMATIC INFORMATION, USE OF COOKIES AND OTHER TRACKING DEVICES

We and our third party service providers, which include ad networks, use cookies, web beacons, and other tracking technologies to collect information about your use of Zaps and Services, such as your browser type, your ISP or operating system, your domain name, your access time, the URL of the previous website you visited, your page views, your IP address, and the type of device that you use. We also track how frequently you visit Zaps and use our Services. We use this information (including the information collected by our third party service providers) for website / application analytics (including to determine which portions of Zaps are used most frequently, what our users like/do not like), to assist us in determining relevant advertising (both on and off Zaps), to evaluate the success of our advertising campaigns, and as otherwise described in this policy. Currently, we do not honour browser requests not to be tracked.

We may obtain your device ID, which is sent to TMPL's servers and used in fraud prevention efforts.

Cookies. We and our third party service providers collect information from you by using cookies. A cookie is a small file stored on user's computer hard drive containing information about the user. The cookie helps us analyze web traffic or informs you about your use of a particular website. Cookies allow web applications to respond to you as an individual, tailoring its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. When you visit Zaps, we may send one or more cookies (i.e., a small text file containing a string of alphanumeric characters) to your computer that identifies your browser.

Some of these cookies may be connected to third-party companies or websites. The terms of use of such cookies are governed by this Policy and the privacy policy of the relevant third party company or website. For example, Google measures the performance of advertisements by placing cookies on your computer when you click on ads. If you visit Zaps when you have such cookies on your computer, we and Google will be able to tell that you saw the ad delivered by Google. The terms of use of these cookies are governed by this Policy and Google's Privacy Policy.

Disabling Cookies. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you disable cookies you may be prevented from taking full advantage of Zaps because it may not function properly if the ability to accept cookies is disabled.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with Zaps to, among other things, track the activities of Zaps visitors, help us manage content, and compile statistics about Zaps usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

B. How TMPL Uses the Information Collected

1. HOW PERSONAL INFORMATION IS USED

We collect your personal information and aggregate information about the use of Zaps and Services to better understand your needs and to provide you with a better Zaps experience. Specifically, we may use your personal information for any of the following reasons:

To provide our Services to you, including registering you for our Services, verifying your identity and authority to use our Services, and to otherwise enable you to use Zaps and our Services;
For customer support and to respond to your inquiries;
For internal record-keeping purposes;
To process billing and payment, including sharing with third party payment gateways in connection with TMPL's products and Services;
To improve and maintain Zaps and our Services (for example, we track information entered through the "Search" function; this helps us determine which areas of Zaps users like best and areas that we may want to enhance; we also will use for trouble-shooting purposes, where applicable);
To periodically send promotional emails to the email address you provide regarding new products from TMPL, special offers from TMPL or other information about TMPL that we think you may find interesting;
To contact you via email, telephone, facsimile or mail, or, where requested, by text message, to deliver certain services or information you have requested;
For TMPL's market research purposes, including, but not limited to, the customization of Zaps according to your interests;
We may use your demographic information (i.e., age, postal code, residential and commercial addresses, and other various data) to more effectively facilitate the promotion of goods and services to appropriate target audiences and for other research and analytical purposes;
To resolve disputes, to protect ourselves and other users of Zaps and Services, and to enforce our Terms of Use;
We also may compare personal information collected through Zaps and Services to verify its accuracy with personal information collected from third parties; and
We may combine aggregate data with the personal information we collect about you.

From time to time, TMPL may use personal information for new and unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change regarding information previously collected, TMPL shall make reasonable efforts to provide notice and obtain consent of any such uses as may be required by law.

We want to help you understand how Zaps App processes your personal data, as well your options when it comes to managing it. It’s important that you also understand how Zaps App protects your images .

The following bullets highlight a few key details about the app and our security measures:

Zaps App is a photo editing app. It enhances photos by improving aspects such as image resolution and colors. Also, it gives you the ability to generate new images with AI.
Zaps App’s technologies are not used to identify or authenticate people in the images or .
You retain control over the images you upload, enhance, and generate using Zaps App . We don’t sell, trade, or claim ownership of any of your images or —no matter whether you use Zaps App to edit your existing images or or to generate new ones.
Your images are never used to train our AI technologies
Your images are safeguarded with appropriate security measures, following privacy and data protection laws and industry standards. This includes encryption and cloud storage for enhanced security.

To know how we process your personal data when using Zaps App, please refer to below

The following activities are always performed when you use our app. This means that if you decide to access the app and make use of its features, your personal data will be used for the purposes listed in this section. If you choose not to provide your personal data, you won’t be able to use the app.

a) Service delivery

We use your personal data to enable you to use the app, and to provide you with its functionalities. Examples of using the app include editing and enhancing your photos, and generating AI images of yourself. Examples of the functionalities provided include the information shown to you about the app and your editing process, and the suggestions made about the best photos to edit.

Categories of data. The following data is used:

User identifiers (such as Apple ID) and mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users)
Device information (such as device model, device type, OS version, device language, device name, and region)
Information about your subscription
Information about your interaction with the app
Images that you upload, and images generated by the app (such as enhanced photos and AI images). To edit photos or generate AI images, the app needs access to your library and your camera. You have to expressly allow this access through the request pop-up that appears on your device. When you allow access to your library and upload the first image for AI generation, Zaps App may find and automatically select other images in your gallery that feature the same person represented in the uploaded image. Until you decide to upload such images, the images don’t leave your device and are not stored on our servers.
Metadata and other information extracted from the images that you upload for enhancement (for example, gender, age, skin tone)
Information about faces in the images you upload, including, for example, information that estimates the location and shape of facial features (”face data”). Depending on the applicable law of your jurisdiction, face data may be considered biometric data. We use face data only to enhance your photos and create the AI images you request, unless you specifically consent to other processing of this data. In no instance does Zaps App process face data to identify or authenticate people in images or you upload.

Legal basis. These activities are based on the contract we have with you (Article 6.1.b GDPR). However, if you upload images that include people other than yourself, the activities described above are based on your legitimate interest in using the app (Art. 6.1.f GDPR). The processing of face data to perform these activities is based on your consent (Article 9.2.a GDPR). If you upload images that include minors, you as the holder of parental responsibility also consent to the processing of face data related to them.

Storage. We apply different retention periods depending on the categories of data and the purposes it is used for.

Enhancement:

Images that you upload and enhanced images are deleted after one (1) day from upload or enhancement.
Face data processed to enhance your photos is deleted immediately after the enhancement.

AI generation:

Images that you upload are retained for up to twenty (20) days (if you have a subscription to Zaps App ) or up to seven (7) days (if you do not have a subscription to Zaps App ) from your most recent use of the Zaps App feature to generate AI images. In any case, they will be deleted after two (2) years from the upload.
Face data processed to generate AI images are retained, in order to ensure the functioning of Zaps App 's generative AI features, for up to twenty (20) days (if you have a subscription to Zaps App ) or up to seven (7) days (if you do not have a subscription to Zaps App ) from your most recent use of the Zaps App feature to generate AI images. In any case, it will be deleted after two (2) years from the generation.
AI images generated by Zaps App are retained for up to seven (7) days from the generation.

After the retention periods indicated above, the data will be deleted from our servers and those of our service providers, unless you have specifically consented to other processing of this data.

We retain the other categories of personal data described above for a maximum of three (3) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. After this period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

b) Service improvement

Your personal data may be used to improve and develop our products and services. For example, we may process your data to conduct statistical analyses or other research activities to optimize our features and provide you with new ones.

Categories of data. The following data is used:

User identifiers (such as Apple ID) and mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users)
Device information (such as device model, device type, OS version, device language, device name, and region)
Information about your subscription
Internet and network activity information (such as IP address, and information about network usage, Internet connectivity, latency, failures, crashes, and error logs)
Information about your interaction with the app
Inferences we generate and other related information about your use of and experience with the app (such as your responses to in-app surveys and your feedback if you take part in our interviews)
Metadata and other information extracted from the images that you upload for enhancement (for example, gender, age, skin tone)
Your gender (if you choose to share this information with us)

Legal basis. These activities are based on our legitimate interest to improve our products (Article 6.1.f GDPR). You can find information concerning the collection of personal data through analytics tracking technologies in the section In-app tracking technologies.

Storage. We retain personal data processed for this purpose for a maximum of three (3) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Upon the expiry of the retention period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

d) Troubleshooting

We use your personal data to ensure the quality and the proper functioning of our apps by analyzing, preventing, and correcting failures and bugs, and to prevent the illicit use or misuse of the app.

Categories of data. The following data is used:

User identifiers (such as Apple ID) and mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users)
Device information (such as device model, device type, OS version, device language, device name, and region)
Internet and network activity information (such as IP address, and information about network usage, Internet connectivity, latency, failures, crashes, and error logs)
Inferences we generate about your usage of the app

Legal basis. These activities are based on our legitimate interest to ensure the quality and the proper functioning of our service (Article 6.1.f GDPR).

Storage. We retain personal data used for this purpose for a maximum of one (1) year from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Upon the expiry of the retention period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

e) Profiling

We analyze information about you and the way you use the app to create your user profile. We use the user profile to improve our products, develop new features, and provide you with relevant offers and a customized in-app experience. For example, we may use your data for the following activities:

To conduct user experience research activities (such as A/B testing)
To customize offers and the in-app experience
To conduct in-app surveys
To measure the effectiveness of our advertising campaigns and make them more relevant
To customize information and marketing communications

Categories of data. The following data is used:

User identifiers (such as Apple ID) and mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users)
Information about your interaction with the app
Inferences we generate about your use of and experience with the app
Your answers to the surveys and the data included in such answers
Your gender (if you choose to share this information)

Legal basis. These activities are based on our legitimate interest to improve and customize our services (Article 6.1.f GDPR).

Storage. We retain personal data used for this purpose for a maximum of three (3) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Upon the expiry of the retention period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

When performed, the following activities are performed only with your consent. This means it’s up to you to decide whether or not to provide your personal data, and you have the right to withdraw your consent at any time. If you choose not to provide your data, you’ll still be able to enjoy the app's services and features.

a) Editing Improvement & AI training

In some jurisdictions, only with your consent, we may use personal data to improve our photo-video editing and generative features in Zaps App and other apps provided by us and our subsidiaries and to offer a better service. For example, we may use your images to train and validate our photo-video editor algorithms.

Categories of data. The following data is used:

Images you upload
Face data processed to generate AI images
Enhanced images and AI images generated by Zaps App

While face data may be considered biometric data in some jurisdictions, the technologies we implement in the app don’t identify or authenticate people in the images or you upload, nor are we training our technologies to do so. We don’t collect or use face data of US-based users to improve our photo-video editing and generative features, nor to train our photo-video editor algorithms.

Legal basis. Where this activity is performed, it is based on your consent (Article 6.1.a GDPR and Article 9.2.a GDPR). Without your explicit consent, we don't perform this activity. You can check and update the permissions you've granted at any moment in the app’s privacy settings.

Storage. When we retain images that you upload, face data, images enhanced, and AI images generated by Zaps App for the purpose of improving our photo-video editing and generative features, this data is retained for a maximum of one (1) year from the collection. After this period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

b) Image generation improvement

Only with your consent, when you report issues about the AI generation, we may use your images to check and rectify the reported issues and improve the generation of future images.

Categories of data. The following data is used:

Images you upload when reporting issues about the AI generation

Legal basis. This activity is based on your consent (Article 6.1.a GDPR).

Storage. We retain the data used for this purpose up to thirty (30) days from the upload.

c) Marketing

We use your personal data to carry out marketing activities and to send you information and marketing communications about our apps (such as tips, offers, and newsletters) through emails and push notifications.

Categories of data. The following data is used:

User identifiers (such as Apple ID) and mobile identifiers (such as IP address, device identifiers, and custom identifiers that we generate to identify our users)
Information about your interaction with the app
Inferences we generate about your use of and experience with the app

We’ll send you push notifications only if you grant the relevant permission by enabling push notifications on your mobile operating system settings.

Legal basis. These activities are based on your consent (Article 6.1.a GDPR). Without your explicit consent, we don't perform these activities. You can check and update the permissions you've granted any moment in the app’s privacy settings. When we use your email to send you information about products and services related to or similar to the app (“soft opt-in”), the legal basis is our legitimate interest (Article 6.1.f GDPR).

Storage. We retain personal data used for this purpose for a maximum of two (2) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Upon the expiry of the retention period, unless any legal obligations require that the data is retained for longer, the data is either deleted or anonymized.

d) Targeted advertising

We use third-party tracking technologies to serve you personalized ads. You can find more information on how these third parties use your personal data by reading their privacy policies linked in the section In-app tracking technologies.

Categories of data. The following data is used:

User identifiers (such as Apple ID) and mobile identifiers (such as IP address, IDFA, AAID, device identifiers, and custom identifiers)
Information about your interactions with the app
Advertising data (such as ad conversion information and advertisements seen)
Your ad tracking choices and consent to receive personalized ads (if granted), and inferences about your interests and preferences

IDFA (on iPhone or iPad) and AAID (on Android devices) are unique device identifiers provided by the operating system that allow advertisers to track and identify a user for advertising purposes. You can turn off this tracking from your mobile settings by following these steps:

On iOS and iPadOS 14.5, go to Settings > Privacy & Security > Tracking and tap to turn off or turn on “Allow Apps to Request to Track” or “Permission to Track” for a specific app. On previous iOS or iPadOS versions, go to Settings > Privacy > Advertising and turn on “Limit Ad Tracking.”
On Android devices, go to your device's Settings app or the Google Settings app > Services > Ads and turn on “Opt out of Ads Personalization.”

Legal basis. The collection of your personal data through third-party profiling tracking technologies is based on your consent (Article 122 of the Italian Privacy Code). To learn more, see the section In-app tracking technologies.

Storage. To learn more about the retention period of the data used for this purpose, see the third parties’ privacy policies linked in the section In-app tracking technologies.

Although it doesn’t happen by default, your personal data may be processed in certain extraordinary circumstances that aren’t related to the functioning of the product. These extraordinary circumstances are as follows:

a) Extraordinary circumstances: For compliance with legal obligations

Your personal data may be used to comply with our legal obligations, including requests from public authorities, and to prove that we have complied with them, such as in the event of a request from a public authority.

Categories of data. We may process any kind of information that may be required by law or under the instructions of public authorities.

Legal basis. When this activity is required by a specific legal obligation, your personal data may be used to the extent required to comply with the legal obligation itself (Article 6.1.c GDPR). When the applicable law leaves some discretion in assessing the appropriate way to comply with it, your personal data is used based on our legitimate interest to prove our compliance (Article 6.1.f GDPR).

Storage. We retain personal data used for this purpose for a maximum of five (5) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Specific legal obligations might require different retention periods and, in such cases, those different periods will apply. Upon the expiry of the retention period, the data is either deleted or anonymized.

b) Extraordinary circumstances: For defense

Your personal data may be used to establish, exercise, or defend our rights and those of our employees, and to carry out corporate transactions or operations. For example, your data may be processed in the event of bankruptcy, merger, acquisition, reorganization, and sale of assets or assignments, and the due diligence related to any such transactions.

Categories of data. We may process any kind of information necessary to ensure the correct execution of the activity.

Legal basis. This activity is based on our legitimate interest to establish, exercise, or defend our rights, and to carry out corporate transactions or operations (Article 6.1.f GDPR).

Storage. We retain personal data used for this purpose for a maximum of ten (10) years from your most recent interaction with the app, or from the expiration of your subscription. If you access the app after your subscription has expired, the retention period starts from this most recent interaction. Specific legal obligations might require different retention periods and, in such cases, those different periods will apply. Upon the expiry of the retention period, the data is either deleted or anonymized.

C. Electronic Newsletters, Invitations, Polls and Surveys

At our sole discretion, TMPL may offer any of the following free services on Zaps, which you may select to use or receive at your option. Certain of the following services may require you to provide additional personal information as detailed below:

1. ELECTRONIC NEWSLETTERS

We may offer a free electronic newsletter to users. We will gather the email addresses of users who sign up for Zaps for the newsletter mailing list. Users may remove themselves from this mailing list by opting out of receiving newsletters during the registration process, by following the link provided in each newsletter that points users to a subscription management page where the user can unsubscribe from receiving newsletters or by changing their preferences in their settings page.

2. "SEND TO A FRIEND"

Zaps users can voluntarily choose to electronically forward a link, page, or document to someone else by clicking "send to a friend." To do so, the user must provide his or her email address, as well as the email address of the recipient. The user's email address is used only in the case of transmission errors and, of course, to let the recipient know who sent the email. The information is not used for any other purpose.

3. POLLING

We may offer interactive polls to users so they can easily share their opinions with other users and see what our audience thinks about important issues, Services, and/or Zaps. Opinions or other responses to polls are aggregated and are not identifiable to any particular user. We may use a system to "tag" users after they have voted, so they can vote only once on a particular question. This tag is not correlated with information about individual users.

4. SURVEYS

We may conduct user surveys from time to time to better target our content to Zaps users. We will not share individual responses from these surveys with any third party. We will share aggregate data with third party service providers, partners, and other third parties. We also will post aggregate data containing survey responses on Zaps; that data may be viewed and downloaded by other users of Zaps.

D. Security

We employ procedural and technological security measures, which are reasonably designed to help protect your personal information from unauthorized access or disclosure. TMPL may use encryption, passwords, and physical security measures to help protect your personal information against unauthorized access and disclosure. No security measures, however, are 100% complete. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or private communications will not be collected and used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. TMPL is not responsible for the unauthorized use of your information or for any lost, stolen, compromised passwords, or for any activity on your Account via unauthorized password activity.

Your password is the key to your Account. When creating your password you should use unique numbers, letters, special characters, and combinations thereof. In addition, DO NOT disclose your password to anyone. If you do share your password or your personal information with others, you are solely responsible for all actions taken via your Account. If you lose control of your password, you may lose substantial control over your personal information and be subject to legally binding actions taken on your behalf. Thus, IF YOUR PASSWORD HAS BEEN COMPROMISED FOR ANY REASON, YOU MUST IMMEDIATELY NOTIFY TMPL TO CHANGE YOUR PASSWORD.

E. Disclosure

We may share the information that we collect about you, including your personal information, as follows:

1. INFORMATION DISCLOSED TO PROTECT US AND OTHERS

We may disclose your information including Personal Information if: (i) TMPL reasonably believes that disclosure is necessary in order to comply with a legal process (such as a court order, search warrant, etc.) or other legal requirement of any governmental authority, (ii) disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) reasonably necessary to enforce this Privacy Policy, our Terms of Use etc. (iv) disclosure is intended to help investigate or prevent unauthorized transactions or other illegal activities, or (v) necessary or appropriate to protect our rights or property, or the rights or property of any person or entity.

2. INFORMATION DISCLOSED TO THIRD PARTY SERVICE PROVIDERS AND BUSINESS PARTNERS

We may contract with various third parties for the provision and maintenance of Zaps, Services and our business operations, and TMPL may need to share your personal information and data generated by cookies and aggregate information (collectively, "information") with these vendors and service agencies. For example, we may provide your information to a credit card processing company to process your payment. The vendors and service agencies will not receive any right to use your personal information beyond what is necessary to perform its obligations to provide the Services to you. If you complete a survey, we also may share your information with the survey provider; if we offer a survey in conjunction with another entity, we also will disclose the results to that entity.

3. DISCLOSURE TO NON-AFFILIATED THIRD PARTIES IN FURTHERANCE OF YOUR REQUEST

Your request for services may be shared with third party websites with whom we have a contractual relationship in order to provide your request with maximum exposure. The post on the third party website will include the details of your request, including your location, and other contact details. Interested bidders, however, will be able to click on your request on such third party site, and will be directed to Zapss where they will have access to your contact details (Partial or complete), as would any other service provider on Zaps interested in bidding on your request.

4. DISCLOSURE TO OTHER USERS OF ZAPS

If you are a Streamer, the information that you post (other than your payment information) is available to other users of Zaps and our Services. Comments that users post to Zaps also will be available to other visitors to Zaps (see our discussion of User Generated Content below). In addition, we will post the results (in aggregate form) of surveys to Zaps. If you are a Viewer, certain information and any Submitted Content shall be available to all other visitors to Zaps.

5. INFORMATION DISCLOSED TO LAW ENFORCEMENT OR GOVERNMENT OFFICIALS

We will disclose your information, including, without limitation, your name, city, state, telephone number, email address, user ID history, quoting and listing history, and fraud complaints, to law enforcement or other government officials if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority.

6. IN THE EVENT OF A CHANGE OF CONTROL OR BANKRUPTCY

In the event that TMPL undergoes a change in control, including, without limitation, a merger or sale of all or substantially all of TMPL’s assets to which Zaps relates or other corporate reorganization in which TMPL participates, and is thus merged with or acquired by a third party entity (a "Successor"), TMPL hereby reserves the right to transfer the information we have collected from the users of Zaps and/or Services to such Successor.

In addition, in the event of TMPL’s bankruptcy, reorganization, receivership, or assignment for the benefit of creditors, or the application or laws or equitable principles affecting creditors' rights generally, TMPL may not be able to control how your information is transferred, used, or treated and reserves the right to transfer the information we have collected from the users of Zaps and/or Services to non-affiliated third parties in such event.

7. INFORMATION DISCLOSED AT YOUR REQUEST

We may share your personal information with other Users to whom you explicitly ask us to send your information or if you explicitly consent to such disclosure upon receipt of a specific Service.

F. Links to External Websites

Zaps may contain links to other websites or resources over which TMPL does not have any control. Such links do not constitute an endorsement by TMPL of those external websites. You acknowledge that TMPL is providing these links to you only as a convenience, and further agree that TMPL is not responsible for the content of such external websites. We are not responsible for the protection and privacy of any information which you provide while visiting such external websites and such sites are not governed by this Policy. Your use of any external website is subject to the terms of use and privacy policy located on the linked to external website.

Information we receive from third-party sites you connect to our Service:

We may receive personal information about you from third parties and combine that with the information we collect through Zaps. We may obtain information, including personal information, from third parties and other sources. Similarly, when you interact with us through a social media site or third-party service, such as when you like, follow, or share Zaps content on Facebook, Twitter, Instagram, or other sites, we may receive information from the social network, including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties. The data we receive from these third-party sites is dependent upon that third party’s policies and your privacy settings on that third-party site. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Zaps.

G. Updating, Deleting and Correcting Your Personal Information

You may choose to restrict the collection or use of your personal information in the following ways:

You can review, correct and delete your personal information by logging into Zaps and navigating to your preferences page in "Edit Profile." You must promptly update your personal information if it changes or is inaccurate. Typically, we will not manually alter your personal information because it is very difficult to verify your identity remotely. Nonetheless, upon your request we will close your Account and remove your personal information from view as soon as reasonably possible based on your Account activity and in accordance with applicable law. We do retain information from closed Accounts in order to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations of any User, enforce our Terms of Use, and take any other actions otherwise permitted by law that we deem necessary in our sole and absolute discretion. You should understand, however, that once you publicly post Submitted Content or any other information onto Zaps, you may not be able to change or remove it. Once we have deleted or removed your Account, you agree that TMPL shall not be responsible for any personal information that was not included within your deleted and/or removed Account that remains on the Website.

H. What Choices Do I Have Regarding Use of My Personal Information?

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your Account or any Services you have requested or received from us.

I. Third-Party Ad Networks

We participate in third party ad networks that may display advertisements on other websites based on your visits to Zaps as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third party cookies and other technologies are governed by each third party's specific privacy policy, and not by TMPL’s Policy. We may provide these third-party advertisers with information about your usage of Zaps and our services, as well as aggregate or non-personally identifiable information about visitors to Zaps and users of our service.

J. User Generated Content

We invite you to post content on our Website, including your comments, feedback, pictures, and any other information that you would like to be available on Zaps. If you post content to Zaps, all of the information that you post will be available to all visitors to Zaps. If you post your own content on Zaps, your posting may become public and TMPL cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

L. Privacy Policy Updates

THIS POLICY IS CURRENT AS OF THE EFFECTIVE DATE SET FORTH ABOVE. TMPL MAY, IN ITS SOLE AND ABSOLUTE DISCRETION, CHANGE THIS POLICY FROM TIME TO TIME BY UPDATING THIS DOCUMENT. TMPL WILL POST ITS UPDATED POLICY ON ZAPS ON THIS PAGE. TMPL ENCOURAGES YOU TO REVIEW THIS POLICY REGULARLY FOR ANY CHANGES. YOUR CONTINUED USE OF ZAPS AND/OR CONTINUED PROVISION OF PERSONAL INFORMATION TO US WILL BE SUBJECT TO THE TERMS OF THE THEN-CURRENT POLICY.