SERVICE PRIVACY POLICY

Introduction

This Privacy Policy ("Policy") describes the privacy practices for the Service (comprising he ZeroD Application and the Website), which is owned and operated by Upstream ("Company" or "We"). This Policy applies only to information we may collect or that you may provide when you purchase, download, install, register with, access or use the Service, in e-mail, text and other electronic communications set through or in connection with this Service and any other sources.

This Policy does not apply to information that we collect offline or on any other Company apps or websites, including websites you may access through this Service or you provide to or is collected by any third party. Our websites and apps and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with or use this Service. By downloading, registering with or using this Service, you agree to this Policy. This Policy may change from time to time. We will add express notifications to the Website whenever changes to the Policy are applied. Your continued use of this Service following such notification is deemed to be acceptance of those changes and means that your consent to this Policy remains valid, so please check the Policy periodically for updates. The most current version of the Policy will govern our use of your information and will always be at the Service website.

Children under the Age of 13

The Service is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at itsupport@upstreamsystems.com. The service provides a quick guide for parents on how to protect children when using mobile devices.

Information We Collect and How We Collect It

We may collect information from and about users of the Service directly from you when you provide it to us and/or automatically when you use the Service. For example, when you visit the Website, get authenticated via MSISDN into our Service, interact with USSD/SMS notifications, or visit a third-party website, application, or service.

Information You Provide to Us.

When you download, register with or use this Service, we may ask you provide information by which you may be personally identified, such as name, e-mail address, telephone number, geolocation, mobile device identification number, or any other identifier by which you may be contacted online or offline ("personal information"), or that is about you but individually does not identify you.

This information includes: (i) Information that you provide by filling in forms on the Service. This includes information provided at the time of using the Service subscribing to promoted services presented on the Service, posting material, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the Service; (ii) records and copies of your correspondence (including e-mail addresses and phone numbers), if you contact us; (iii) Your responses to surveys that we might ask you to complete for research purposes; (iv) Details of transactions you carry out through the Service and of the fulfillment of your orders (note that you may be required to provide financial information before placing an order through the Service); (v) Your search queries on the Service; and (ix) Other types of interaction that may be available via the Service.

By visiting the Website, you provide us with your phone number and you agree to receive text messages to that number from us. We may use your contact information to send you information about our Service, to market to you, to help prevent spam, fraud, or abuse, and to help others find your chat username, including through third-party services and client applications. You may also unsubscribe from a Service notification by sending a specific Keyword to a shortcode, as presented on the notification message.

You may be able to provide information to be published or displayed ("Posts" or "Posted") on public areas of websites you access through the Service (collectively, "User Contributions"). Your User Contributions and Posts may be transmitted to others at your own risk. The Service reserves the right to do moderation of User’s content uploaded onsite. The Service may modify or block User’s content as long as it does not comply with Terms of Use (e.g. hate speech) and Policy (e.g. reveal a MSISDN). We cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot guarantee that your User Contributions will not be viewed by unauthorized persons. The Service broadly and instantly disseminates your public information to a wide range of users, customers, and services, including search engines, developers, and publishers that integrate with the Service, and organizations.

Automatic Information Collection and Tracking.

When you download, access and use the Service, it may use technology to automatically collect certain information, including but not limited to:

· Usage Details. When you access and use the Service, we may automatically collect certain details of your access to and use of the Service, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the Service. These may include your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, or cookie information. We also receive log data when you click on, view or interact with links on our Service, including links to third-party applications. We use log data in order to customise the content presented to you, including ads. We keep log data as needed for the purposes described in this Policy for a minimum period of 180 days.

· Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information and the device's telephone number.

· Stored Information and Files. The Service also may access metadata, tags and other information associated with other files stored on your device.

· Location Information. The Service may collect real-time information about the location of your device, in order to provide customized features, such as the local weather forecast.

We also may use technologies to collect information about your usage of the Service over time. We do not respond to web browser "do not track" signals.

Information Collection And Tracking Technologies.

The technologies we use for automatic information collection may include:

· Cookies. Like many websites, we use cookies and similar technologies to collect additional website usage data and to improve our Service. A cookie is a small file placed on your mobile device. We may use both session cookies and persistent cookies to better understand how you interact with our Service, to monitor aggregate usage by our users and web traffic routing on our Service, and to customize and improve our Service.

It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your mobile device / mobile web browser. However, if you select such setting configuration you may be unable to have full access and functionality on certain parts of our Service.

· Web Beacons. Pages of the Service or our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-party Information Collection

When you use the Service or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include: advertisers, ad networks and ad servers, analytics companies, your mobile device manufacturer, your mobile service provider, etc.

These third parties may use tracking technologies to collect information about you when you use this Service. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps and other online services or websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

The Service is supported by advertising. We may use the information described in this Policy to help make advertising more relevant to you, to measure its effectiveness, and to help recognize your devices to serve you ads on and off of the Service. We prohibit advertisers from targeting ads based on categories we consider sensitive, such as race, religion, politics, sex life, or health.

Our partners may share information with us such as a browser cookie ID, mobile device ID, mobile phone number (MSISDN), as well as demographic or interest data and content viewed or actions taken on a website or app.

Our partners may enable us to collect similar information directly from their website or app by integrating our advertising technology.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

· Provide you with the Service and its contents, and any other information, products or services that you request from us.· Give you notices about your airtime, data and credit status or subscription, including expiration and renewal notices.

· Carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection.

· Notify you when Service updates are available, and of changes to any products or services we offer or provide though it.

The usage information we collect helps us improve the Service and deliver a customized experience by enabling us to:

· Estimate our audience size and usage patterns. We may keep track of how you interact with links across our Service, including our USSD/SMS notifications, third-party services, and client applications, by redirecting clicks or through other means.

· Store information about your preferences, allowing us to personalize the Service according to your individual interests.

· Speed up searches.

· Identify you when you use the Service.

We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you.

The Service may provide certain features that allow you to communicate privately. In this case we will store and process your communications, and information related to them. When using the private (non-public) communication services, please remember that recipients may copy, store, and re-share the content of your communications. This information may enable cross-posting or otherwise help us improve the Service, and is deleted from our Service within 180 days of your disconnecting from our Service.

We may use the information we collect to display advertisements to our advertisers' target audiences. If you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated and de-identified information about our users without restriction. In addition, we may disclose personal information that we collect or you provide:

· To our subsidiaries and affiliates.

· To contractors, service providers, content providers, and other third parties we use to support our business, such as Google Analytics. We may share your private personal information with such service providers subject to obligations consistent with this Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.

· To third parties to personalize services and products offered to you.

· To fulfill the purpose for which you provide it.

· For any other purpose disclosed by us when you provide the information.

· With your consent.

· To comply with any court order, law or legal process, including to respond to any government or regulatory request.

· To enforce our rights arising from any contracts entered between you and us, including the Terms of Use, this Policy.

· If we believe disclosure is necessary or appropriate to protect our rights, property, or safety or that of our customers, users, contractors or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Accessing, Correcting and Deleting Your Information

You can request and obtain removal of your Posts and User Contributions by contacting us on itsupport@upstreamsystems.com, with your request and specifying the particular content you seek to remove. We may not accommodate a request to change or delete any information if we believe such action would violate any law or legal requirement or cause the information to be incorrect. Removal of your content from the Service does not ensure complete or comprehensive removal of such content from the Service as copies may remain viewable in cached and archived pages, or might have been copied or stored by other Service users. You may not opt out of Service-related communications, such as account verification, purchase confirmations and administrative messages, so long as you are registered with the Service. As we develop our business, we might buy or sell businesses or their assets, or engage in transfers, acquisitions, mergers, restructurings, changes of control, or other transactions. In such transactions, customer information generally is one of the transferred business assets and your information may be subject to such a transfer. In such case, you will be notified are entitled to opt-out if you do not wish your data to be part of the transferred data. The data in question will be returned, deleted and or destroyed according to your instruction. Also, in the unlikely event of a bankruptcy, your information may be transferred to a bankruptcy trustee or debtor in possession and then to a subsequent purchaser.

Social Media Plug-ins

We may integrate social media application program interfaces or plug-ins ("Plug-ins") from social networks, including Facebook, Twitter, Instagram, Tumblr, Pinterest and others, into the Service. Interacting with a Plug-in will transmit information directly to that Plug-in's social network and that information may be visible by others on that platform. Plug-ins are controlled by the respective platform's privacy policy, and not by our Policy.

Data Security

The safety and security of your information also depends on you. We will never ask you to publicly expose personal information nor reveal personal communication details such as your phone number or your email address.

You should not share your private information details (e.g. phone number) with anyone. The transmission of information via the Internet and mobile platforms is not completely secure. While we take reasonable precautions to protect your personal information, we cannot guarantee the security of your personal information. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Contact Information

If you have any concern or complaint about privacy on the Service, please contact us at Upstream, Marylebone House, 52 – 54 St John Street, London EC1M 4HF, United Kingdom or contact us at itsupport@upstreamsystems.com. We will do our best to respond to you in a timely and professional manner in order to answer your questions and resolve your concerns.