Effective Date: 28 August 2023 (updated 24 March 2024)

1. Introduction

Welcome to Zemobo Limited (“we”, “us”, or “our”). We are committed to protecting your privacy and providing transparency regarding how we collect, use, and safeguard your personal information. This Privacy Policy outlines the practices and procedures we follow in relation to the information we collect through our website and services, including Hang Five (https://playhangfive.com/).

2. Information We Collect

We collect various types of information from you, including:

  • Usage Data: We gather information about how you interact with our products and services. This may include data about your device, browser, IP address, and interactions with our website.

3. How We Use Your Information

We use the collected information for the following purposes:

  • Improving Our Products: We use Mixpanel, Google Analytics and Honeycomb to analyze user interactions and better understand how our products are used. This helps us enhance user experience and make informed decisions about product development. We use Split to manage rolling out new features to make sure they’re working properly for you.
  • Advertising: We use NitroPay to provide advertising on Hang Five. Their privacy policy is available at https://nitropay.com/privacy
  • Surveys: We use Formbricks to conduct user surveys from time to time. Their privacy policy is available at https://formbricks.com/privacy-policy

Our legal basis for processing your personal information is your consent, as well as our legitimate interest in improving our products and services. By using our website and services, you consent to the collection and processing of your information as described in this Privacy Policy.

5. Sharing Your Information

We may share your information with third-party service providers who assist us in analytics and product improvement. These providers are contractually obligated to maintain the confidentiality and security of your information.

6. Data Retention

We will retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

7. Your Rights

  • Right to Access: You have the right to request access to the personal information we hold about you.

  • Right to Rectification: You can request corrections to inaccurate or incomplete personal information.

  • Right to Erasure: You have the right to request the deletion of your personal information.

  • Right to Object: You can object to the processing of your personal information for certain purposes.

You can exercise these rights in the first instance by emailing us at privacy@zemobo.com.

8. Security

We take appropriate security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction.

9. Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy, please contact us at privacy@zemobo.com.

10. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy to reflect changes in our practices. We will notify you of any material changes through our website or other communication methods.

For California Residents: CCPA Information

Rights and Choices

The CCPA provides consumers located in the state of California with certain rights regarding their personal information and data. The following section describes those rights and explains how to exercise them:

Access to Specific Information and Data Portability Rights

You have the right to request that Zemobo Limited discloses certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (as described in the section “Exercising Access, Data Portability, and Deletion Rights”), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called data portability request)
  • If we sold or disclose your personal information for a business purpose, two separate lists disclosing:
    • Sales, identifying the personal information categories that each category of recipient purchased, and
    • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or imposing penalties.
  • Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.
  • Any CCPA-permitted financial incentive we offer will reasonably relate to your value and contain written terms that describe the program’s material aspects.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at privacy@zemobo.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access of data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Information We Collect

Our websites, emails (with your consent, where required by law), and other products, services and platforms collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our websites, apps, emails, and other products, services and platforms may have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category Collected
A. Identifiers YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) YES
C. Protected classification characteristics under California or federal law NO
D. Commercial information. YES
E. Biometric information. NO
F. Internet or other similar network activity. YES
G. Geolocation data. YES
H. Sensory data. NO
I. Professional or employment-related information. NO
J. Inferences drawn from other personal information. YES

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a newsletter or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we or our third-party service providers will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders and requests.
  • To provide, support, personalize, and develop our websites, emails, and other products, services and platforms.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
  • To personalize your website, apps, emails, or other product, service or platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, apps, emails, and other products, services and platforms.
  • To help maintain the safety, security, and integrity of our websites, apps, emails, and other products, services and platforms, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our websites, apps, emails, and other products, services and platforms.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
  • We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third-party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see ‘Sales of Personal Information’ below). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales (see ‘Sales of Personal Information’ below).

We may share your personal information with the following categories of third parties:

  • Subsidiaries and affiliates.
  • Contractors and service providers.
  • Data aggregators.
  • Third parties with whom we partner to offer products and services to you.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • [Category A: Identifiers.]
  • [Category B: California Customer Records personal information categories.]
  • [Category F: Internet or other similar network activity.]
  • [Category G: Geolocation Data.]
  • [Category K: Inferences drawn from other personal information.]

Sales of Personal Information

  • In the preceding twelve (12) months, we have not sold any personal information.