Wrap App Privacy Policy

Zoebean, LLC (“us,” “we,” or “Company”), provider of the “Wrap App,” is committed to respecting the privacy rights of its customers, visitors, and other users of the Company mobile application (the “App”), Company website (the “Site”) and any other websites, features, applications, widgets or online services that are owned or controlled by Company and that post a link to this Privacy Policy (together with the App and Site, the “Service”), as well as any information Company collects offline in connection with the Service. We created this Service Privacy Policy (“Privacy Policy”) to give you confidence as you visit and use the App, and to demonstrate our commitment to fair information practices and the protection of privacy. This Privacy Policy is only applicable to the Service, and not to any other websites that you may be able to access from the App or Site, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at the following privacy@thewrapapp.com.

Please note that certain features or services referenced in this Privacy Policy may not be offered on the Service at all times. Please also review our complete Terms of Service including but not limited to Terms of Use, which governs your use of the Service, and which is accessible at all time at Terms.

1. Information Collection

Information You Provide to Us

  • Personal Information: In the course of using the Service, we may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”). Examples of Personal Information include your name, email address, company address, billing address, and phone number.

  • Identity Verification: We may collect Personal Information, such as your date of birth or taxpayer identification number, to validate your identity or as may be required for use in third-party payments processing or by law, such as to complete tax filings. We may request documents to verify this information, such as a copy of your government-issued identification or photo or a billing statement.

  • General Audience Service: The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than the age 18. If we become aware that a child younger than 18 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that we have collected Personal Information from your child, please contact us at: privacy@thewrapapp.com. You may not use the Service if you are under 18 years old.

  • Payment Information: If you use the Service to make or receive payments, we will also collect certain payment information, such as credit card or other financial account information, and billing address. This functionality is not currently part of the Service, but may be at a future date.

  • Non-Identifying Information/Usernames: We also may collect other information, such as zip codes, demographic data, information regarding your use of the Service, and general project-related data (“Non-Identifying Information”). We may aggregate information collected from Company registered and non-registered users (“Company Users”). In some cases, we may render Personal Information including Optional Demographic Data into a form of Non-Identifying Information referred to in this Privacy Policy as “Hashed Information.” This is typically accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not identify you directly, but it may be used to connect your activity and interests.

  • Combination of Personal and Non-Identifying Information: Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information, but Company will treat the combined information as Personal Information

  • Collection of Third-Party Personal Information: We collect the following personal information from you about your contacts or friends: First name, last name, and email address when you provide it to us for the purpose of adding your contacts to a message room.

  • Optional Demographic Data: We may request certain demographic data from you when you sign up for the Site or Service or after signing up for the Site or Service. Your election to provide such requested information is entirely optional and will not in any way affect your use of the Site or Service. Such optional information may include but is not limited to your age, gender, race, ethnicity, level of education, sexual orientation, and income level. All such information shall be deemed “Optional Demographic Data” herein. For all categories of Optional Demographic Data, you shall have the option to select “prefer not to say.” Please see the last bullet point in Section 2, subsection “We Use Information We Collect” below to learn how we use the Optional Demographic Data collected.

You do not have a statutory obligation to provide us with any information, but you may have a contractual obligation to do so, and if we do not receive certain information from you, then we will not be able to provide our Service to you. If you have any questions regarding whether provision of information is mandatory and the consequences for withholding such information, please contact us using the contact information below.

Information Received from Third Parties

We also may receive information about you from third parties. For example, we may supplement the information we collect with outside records or third parties may provide information in connection with a co-marketing agreement or at your request (such as if you choose to sign in with a third-party service). If we combine the information we receive from others with information we collect through the Service, we will treat the combined information as described in this Privacy Policy.

Information Collected Automatically

We and our third-party service providers, including analytics and third-party content providers, may automatically collect certain information from you whenever you access or interact with the Service. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, and to improve marketing, analytics, and site functionality.

The information we collect also includes the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Service. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Service, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the device used to access the Service.

Company and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movement around the website, the desktop app, and the mobile app, and to gather demographic information about our user base as a whole. The technology used to collect information automatically from Company Users may include the following:

  • Cookies: Like many websites, we and our marketing partners, affiliates, analytics, and service providers use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use both persistent cookies that remain on your computer or similar device (such as to save your registration ID and login password for future logins to the Service and to track your compliance with the Company Terms of Service) and session ID cookies, which expire at the end of your browser session (for example, to enable certain features of the Service, to better understand how Company Users interact with the Service and to monitor aggregate usage by Company Users and web traffic routing on the Service). You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functionality of the Service.

  • Web Beacons: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as “web beacons” and/or “tracking tags” to help us keep track of what content on our Service is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Service, to monitor how Company Users navigate the Service, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.

  • Embedded Scripts: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as an Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.

In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.

User Profiles

You will be required to create a profile, which consists of information about you, and may include but is not limited to Personal Information, photographs, examples of your work, information on work previously performed via the Service and outside the Service, including your username (“Profile”). The information in your Profile may be visible to other team members on your project (“Wrap Project”) while using the Service, depending on the permission levels assigned by the team administrator for your Wrap Project (the “Project Admin”), and shall not be visible to the general public. You may edit certain information in your Profile via your account and may choose to limit who is able to view certain content you post to your Profile. If, in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us at support@thewrapapp.com.

Identity Verification

Before you can complete registration on the Service, or at any time thereafter, we may request or re-request identity verification. Without limiting the manner in which we request identify verification, we may require you or your parent or guardian if applicable to participate in a video call after submitting your government issued ID to enable us to confirm that you are indeed the individual in the ID. We may record such video calls and take screenshots of the user during the call. Company may use the information obtained from Identity Verification for purposes of verifying your identity, enforcing our Terms of Service and other agreements, and preventing fraud.

2. Use of Information

WE USE INFORMATION WE COLLECT:

  • To provide and improve the Service, complete your transactions, address your inquiries, process your registration, verify the information you provide is valid, and for compliance and internal business purposes.

  • To contact you with administrative communications and Company newsletters, marketing or promotional materials (on behalf of Company or third parties) and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the instructions in the Your Choices and Rights section, below.

  • To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online.

  • To administer and develop our business relationship with you and, if applicable, the corporation or other legal entity you represent.

  • To enforce and comply with the law, including to conduct an investigation, to protect the property and rights of Company or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify Company Users.

  • For the purposes disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

  • With regard to the Optional Demographic Data: We may store such information that you opted to provide to us, however, such Optional Demographic Data will not be visible to other members or to the public. The Optional Demographic Data will be used for internal reporting purposes to further improve the App and Service, including, as needed, by those third-party providers in the manner outlined in section 5 of this Privacy Policy. We will never share your Optional Demographic Data in connection with their personal identity or for any purpose other than defined herein. If any Optional Demographic Data becomes Hashed Information, then all applicable Privacy Policy provisions for Hashed Information will apply.

We use your Personal Information for the purposes described above:

  • To Honor Our Contractual Commitments to You.

  • For Our Legitimate Interests. In many cases, we handle Personal Information on the grounds that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

    • Providing our App and Service.

    • Analyzing and improving our business.

    • Communications, including marketing and responding to your inquiries about our services.

    • Addressing information security needs and protecting our Users, Company, and others.

    • Managing legal issues.

  • To Comply with Legal Obligations. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.

3. Data Retention

Unless you request that we delete certain information (see Your Choices and Rights below), we retain the information you submit to verify your identity using two-factor authentication with confirmation links sent to your provided email address; upon confirmation of your identity, we retain other information we collect for at least 5 years. Your information may persist in copies made for backup and business continuity purposes for additional time. If you choose to provide us with Personal Information, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you.

4. Information Sharing & Disclosure

We may share aggregated Non-Identifying Information and we may otherwise disclose Non-Identifying Information (including, without limitation, Hashed Information) to third parties. We do not share your Personal Information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in to or opt-out of such sharing. We may also share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy, or in the following circumstances:

 

  • Service Providers: We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of Company’s features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf.

  • What Happens If You Agree to Receive Information from Third Parties or Request that We Share Your Information: You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of an SNS or similar interactive feature or third-party application, that we share information about you with a third party and we will typically do so under those circumstances.

  • Legal and Investigative Purposes: Company will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of Company or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.

  • Internal and Business Transfers: Company may share information, including Personal Information, with any current or future parent, subsidiaries or affiliates, primarily for business and operational purposes. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.

  • Sweepstakes, Contests, and Promotions: We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.

 

5. Third Party Analytics Providers, Ad Servers & Similar Third Parties

Company works with (or may in the future work with) analytics service providers, bug-tracking providers, network advertisers, ad agencies, and other vendors to provide us with information regarding traffic on the Service, including pages viewed and the actions taken when visiting the Service; to serve our advertisements on other websites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Service as well as other websites or services, they may set and access their own tracking technologies on your device, and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other online websites and services. We may also share certain Non-Identifying Information with these parties, including Hashed Information, in connection with the services they provide to us. In the current iteration of the Service, Company does work with ad services or serve ads to Company Users. If you wish to opt out of interest-based advertising if and when it becomes supported, please contact support@thewrapapp.com

6. Your Choice and Rights

Registered Company Users may update their choices regarding the types of communications you receive from us through your online account. You also may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications. You may opt-out of receiving text messages by contacting support@thewrapapp.com with your request. Registered Company Users who access the Service by using a Company mobile application may, with permission, receive push notifications. Similarly, registered Company Users who access the Service by using certain desktop browsers may, with permission, receive push notifications. Notification preferences can be modified in the settings menu for the mobile application or the applicable browser.

Upon request Company will provide you with information about whether we hold any of your personal information. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. You may access, correct, or request deletion of your personal information by making updates to that information or by contacting Company through your online account. If you request to access all personal information you’ve submitted, we will respond to your request to access within 30 days or as otherwise required by law. If your information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Service. If you would like to close your account in our system, you can do so through the Company Service (once you have logged in, visit settings / user settings, and then click on the close my account link), or by contacting support@thewrapapp.com with your request.

We will use commercially reasonable efforts to honor your requests for deletion; however, certain information will actively persist on the Service even if you close your account. In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes). Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor Company can delete all copies of information that has been previously shared with others on the Service.

 

7. Security

Company takes commercially reasonable steps to help protect and secure the information it collects and stores about Company Users. All access to the App and the Site is encrypted using industry-standard transport layer security technology (“TLS”). But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your Personal Information, Company cannot ensure and does not warrant the security of any information you transmit to us.

8. Links to Other Sites

Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.

 

9. Public Profile

The profile you create on our Site or App will not be publicly accessible unless otherwise indicated. Your Project Admin may change the privacy settings and sharing permissions of your profile within a given Wrap Project through the account portal. 

 

10. Changes to This Policy

Company may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are substantial changes to the way we treat your Personal Information, we will display a notice through the Services prior to the change becoming effective. We may also notify you by email, in our discretion. However, we will use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy.

 

11. Contacting Us

If you have any questions about this Privacy Policy, please contact us at privacy@thewrapapp.com or by mail addressed to Company, Zoebean, LLC, 456 Clementina St., San Francisco, CA 94103. Dalia Burde is head of compliance, and you may direct your requests to her attention.

 

12. Supplemental Privacy Notice for California Residents

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once each calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately preceding calendar year.

To obtain this information, please send an e-mail message to privacy@thewrappapp.com with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide in response the requested information to you at your e-mail address. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only required information will be included in our response.

Under California’s “Eraser Button” law, California residents under age 18 who have registered to use the Service may request removal of content they have posted. To make a request, please send an e-mail message to privacy@thewrapapp.com.